The Delta Stewardship Council has posted a Draft Interim Plan and an invitation for comments. Click here for a copy. Send comments to firstname.lastname@example.org. The Interim Plan will be in effect until the “Delta Plan” replaces it and becomes an enforceable document. Comments received by May 12 will be included in the Council’s May 27-28 meeting packet. Items received after May 12 will be considered in the later June Council meeting.
Two-Gates – They’re Back
Draft Plan item V:
“(a) Continue working on the rapid science study for the Two-Gates Fish Protection Project”
“(b) Construct and implement the Two-Gates …”
First, if it is a “rapid” science study will it be comprehensive? Second, there is no qualifier that said if the scientific study showed gates weren’t effective, don’t construct them. Constructing the gates is a step of its own. There’s no Environmental Impact Report (EIR) step listed or any other updated project plan. There’s nothing that addresses the safety, boating, and economic issues raised by our communities. Looks to me like it’s another attempt to ram rod the Two-Gates project even though the US Department of the Interior stated (see the AJR 38 Bill Analysis) that they were concerned with the lack of scientific study, the escalating cost of the project, and the potential impacts of the project as raised in over 1400 comment letters.
The Two-Gates project as it was originally scoped in the USBR FONSI should not be included in this plan.
The Delta isn’t a Plumbing Fixture
The Plan is heavily focused on the Delta as the primary solution for the entire state’s water needs. Step 1 of the plan should be to determine the amount of flow required to maintain a healthy Delta ecosystem. Once that is determined, the rest of the plan can be finalized. Specific steps should be included to minimize the amount of water the state needs from the Delta such as reducing evaporation from the Aqueduct, desalination plants, agriculture conservation, and groundwater clean-up.
The goal “Support for agriculture” needs clarification. As seen in Sen. Feinstein’s proposed Amendment to the Jobs Bill, some are quick to propose changing priority water rights and put the Westlands farmers to the front of the line ahead of Delta farmers and others who hold senior water rights. The plan needs to include maintaining farmers’ priority water rights.
In addition, “Support for agriculture“ needs to be qualified.
1. There are currently lands with high levels of selenium being farmed. This has resulted in wildlife deformities and causes significant issues for downstream Delta farmers.
2. Some crops like cotton and rice consume more water than others. The plan needs to support balancing the economic value of agriculture to the State with negative impacts to the state water supply
3. Some farmers leverage their water rates to resell at a profit. This should be eliminated by mandating no profiteering from reselling water rights.
Programs to encourage farmers to switch to crops needing less water, eliminate farming on selenium-filled land and eliminate reselling water rights should be added to this plan.
Recognition of Delta Communities’ Needs
Recognition of the Delta as a home to millions and an economic basis for the communities (local agriculture, fishing, boating, home values, local businesses) needs to also be specifically considered and supported by this plan. As shown by the Two-Gates project, these project do not include consideration for the Delta communities. Furthermore, there is no oversight by Delta legislators or funding for that oversight as part of the plan. The five Delta County supervisors have requested funding – that should be part of the plan.
We encourage anyone with concerns about this becoming the Interim Delta plan send comments to email@example.com. If you share the concerns above, copy them or revise to describe your specific concerns/recommendations.