Interim Delta Plan – Comments Due May 12

The Delta Stewardship Council has posted a Draft Interim Plan and an invitation for comments. Click here for a copy. Send comments to 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.

Send Comments

We encourage anyone with concerns about this becoming the Interim Delta plan send comments to If you share the concerns above, copy them or revise to describe your specific concerns/recommendations.

1 Response to “Interim Delta Plan – Comments Due May 12”

  1. 1 Steve Dinger May 10, 2010 at 1:33 pm

    With 1400 Opposition Responses to the 2-Gate Project, it really should be over, but its not.

    After attending meetings at Discovery Bay, Antioch and Stockton there were only two advocates for the project, Central Valley folks and the LA lobbyists.
    Many of the California legislator’s, as well as, the Delta Regional Counties were against the expensive and under-developed researched experiment. Thousands of residents were appauled at the suggestion that there would become isolation on Old River and Connection Slough from December until June….and then some.

    I believe the statement in Bill AJR38 says it best: “Murkier still is whether the Two-Gates Project would provide a feasable alternative to protections under the current Smelt BiOp while allowing INCREASED water supply exports.”

    While attending the Delta Water meetings, it became obvious to me, that the cause of the problem in the first place is being ignored, while attempting to extract greater flow of good quality water out of the Delta Region. It was drummed into our heads at the meetings that the Central Valley crop growers were needing larger and larger amounts of water in order to grow what was defined as, “The 4 High volume water usage crops, that represented less than 2-4% (lowest value crops) of the crops produced in California. The question was presented to the participants, “Can we afford to send massive amounts of water to the Central Valley to produce ‘low value’ crops?”
    Another question posed at the meetings, “Have the So. California user’s of the Delta water implemented any serious conservation or deterents for wasting water?”
    Followed by the question, “What projects or contingencies are in the works, to develop So. California’s own reliable source of precious water, in case of drought conditions like 2006-2009 in Northern California (desal etc.)?”
    These questions were answered with either NO or NONE.
    In closing, our priority concern may currently be with the 2-Gate Project, while the real Trojan Horse may very well be the other water projects that divert water closer to the American River (fresher-cleaner water) for usage to the South. Each Project has a lasting affect on our beautiful Delta Region. It would be useful when studying the impact on the Delta, to see a more synergistic view of all water projects from a historical, current, and future impact of the quality of water.
    Not one project at a time!

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