A coalition of conservation, public interest, and fishing groups has sent a letter to the state and federal agencies overseeing the proposed Delta Tunnels proposal asking them to either drop the plan, or develop a new Draft EIR/EIS for the project that includes newly released information.
The letter, written by Robert Wright senior counsel at Friends of the River, is addressed to the California Natural Resources Agency, the U.S. Departments of the Interior & Commerce, the U.S. Environmental Protection Agency and U.S. Bureau of Reclamation, and the Council on Environmental Quality at the White House.
The letter focuses on new information discovered by Restore the Delta through the California Public Records Act that revealed an unreleased economic analysis showing the Tunnels would require taxpayer subsidies and would export far more water from the San Francisco Bay-Delta than has been disclosed to the public. Without a full accounting of the projects costs, who will pay, and impacts to the environment, federal and state agencies have no legal way to move forward.
The letter concludes that approving the project as proposed, threatens to tarnish President Obama’s outstanding environmental legacy.
Main points in the letter:
1. Rather than water districts covering the entire cost of the Delta Tunnels, the proposal simply doesn’t pencil out without taxpayer subsidies.
“…in November of 2015, the economic consultant for the project, David Sunding of The Brattle Group, prepared a draft CalWater Fix Economic Analysis for the California Natural Resources Agency. That Economic Analysis, purporting to justify the economic feasibility of the project, assumed that the federal government or some other entity would need to provide a subsidy of $6.5 billion to make the Water Tunnels a breakeven proposition for agricultural users of the water.”
2. The amount of water that must be exported from the San Francisco Bay-Delta to make the Tunnels viable is far larger than proponents have claimed in the draft environmental documents.
“As explained by Dr. Jeffrey Michael, Director of the Center for Business and Policy Research at the University of the Pacific the subject Analysis “assumes water yields (the difference in export water delivery with and without the tunnels) are 4 times higher than in official Water Fix documents including its RDEIR/SDEIS and petition to the State Water Resources Control Board.”
3. Groups promoting the Delta Tunnels have not been truthful with the public or federal oversight agencies.
“This project reeks of misrepresentation by the proponent agencies. The public is told the beneficiary users will pay all costs of the project. In secret, the proponent public agencies have received information from their own economic consultant that a substantial public subsidy would be necessary for the project. The public is told one thing in public about water yields and corresponding impacts on the Delta and fisheries. In secret, the proponent public agencies base financial feasibility decision-making on assuming far higher water yields than disclosed to the public.”
4. Because of this new information the project in on shaky legal ground.
“That new Draft EIR/EIS must include disclosure of whether taxpayers as well as ratepayers will be paying for the project and disclosure of the true quantities of freshwater flows that will actually be diverted for the Water Tunnels. The truth needs to start. The lying needs to stop. If instead, you allow Reclamation and DWR to issue a Final EIR/EIS for this project, that will constitute failure to proceed in the manner required by law. We are confident that you will decide to honor President Obama’s legacy and our laws by proceeding in the manner required by law.”
5. President Obama’s environmental legacy is on the line.
“President Obama has established a legacy of honesty, scientific integrity, and commitment to conservation and protection of our precious natural resources. There is no acceptable reason for you to allow the California Water Fix Project to go forward at this time staining that legacy in the process of contributing to the destruction of the San Francisco Bay Delta estuary.”
Groups signing the letter are:
AquAlliance, California Sportfishing Protection Alliance, California Water Impact Network, Center for Biological Diversity, Environmental Justice Coalition for Water, Environmental Water Caucus, Friends of the River, Planning and Conservation League, Restore the Delta, and Sierra Club California.