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Stay safe and well

We hope all of you are staying safe and well.

In this stressful time of a world pandemic, we do not think it is also a time to have to worry about anything except our families, our communities, and our businesses.

The Delta Tunnel(s) project has always caused a lot of angst for we who live in the Delta and love the Delta. The groups who have been fighting the tunnel are pleading with the organizations that are still trying to rush this new destructive Single Tunnel project through to stop, let people focus on the important issues in their lives, and not add more stress.

We haven’t been pushing for our members to submit comments on the Single Tunnel Notice of Preparation (NOP) which were originally due tomorrow, it just didn’t seem right. Instead, groups have been pushing the DWR to delay. Fortunately, because of pushback, the DWR moved the comment period end from March 20 to April 17. Still, that’s only 10 days after the current “Shelter in Place” ends and, unfortunately, the shut-down is likely to be extended. We think the DWR needs to just cancel the Single Tunnel efforts until this coronavirus crisis is behind us.

If you are bored at home and want to keep track of when things are due and any updates, go to our Event Tracker tab. The top part of that page gives info on upcoming events, like the current April 17 comments due date and where to send comments. Below that is our history of events. We’ll try to keep that page current.

And there are some new developments we’ll be sending out.

But if you are like Karen and I, we are having trouble focusing on anything with all of our family worries right now. So the most important thing is to stay safe and well!

Karen Mann, President
Jan McCleery, Past President

Delta Conveyance Project Scoping Comment Period Reminder

Thanks again to everyone who showed up at one of the Single Tunnel Scoping Meetings. This reminder came out from DWR today that people can send in more comments on the Single Tunnel Plan up until March 20. Details below:
___________________________________


March 13, 2020
Delta Conveyance Project
Scoping Comment Period Reminder

___________________________________
Next Friday, March 20, marks the close of the scoping comment period on the Notice of Preparation (NOP) for the development of an Environmental Impact Report (EIR) for modernized water infrastructure in the Sacramento-San Joaquin Delta. The scoping period provides an opportunity for public and agency comment on the scope and content of the California Environmental Quality Act review, including the potential environmental impacts of a proposed single tunnel conveyance project and range of alternatives that will be analyzed in the EIR. Modernizing Delta conveyance is part of the state’s Water Resilience Portfolio, which describes the framework to address California’s water challenges and support long-term water resilience and ecosystem health.

The NOP and related availability and informational materials can be viewed online or at one of these locations.

How to Comment:

All comments received during the scoping period will be considered in the development of the Draft EIR. DWR is seeking public input on the scope of issues to be addressed in the EIR and input about alternatives that meet the project’s objectives. Comments may be submitted in several ways:

Email: DeltaConveyanceScoping@water.ca.gov
Mail: Department of Water Resources, Attn: Renee Rodriguez, P.O. Box 942836, Sacramento, CA 94236
Fillable online form: View Form
Comments must be received electronically or postmarked on or before March 20, 2020.

Muck by any other name is still muck

I still remember when the Department of Water Resources (DWR) caused such a public uproar about the muck ponds from tunnel construction (aka the “spoils” removed from under ground) that would be left throughout the Delta from tunnel construction.

What is tunnel muck? In 2013, the Bay Delta Conservation Plan (BDCP) said it was “plastic mix consisting of soil cuttings and soil conditioning agents (water, air, bentonite, foaming agents, and/or polymers/ biopolymers)”. Yuck. Muck (their term, not mine).

To solve their problem with muck, they did a global edit on their 40,000 page BDCP Plan to change the word “muck” to “RTM” or “Reusable Tunnel Material.” Voila! That sounds nicer, doesn’t it? Then they spent years in marketing campaigns and other efforts to look for nice uses of the “RTM”. They even want to use it to fill in Franks Tract as a tidal marsh.

On Page 10 of the January 31 report by the Independent Technical Review (ITR) Committee, a group of engineers advising the DCA (that’s the Delta Conveyance and Design Construction Authority), Section 4.2 Tunnel Material states:

Based on ITR experience, soft ground tunnel material is not a commodity (has no residual value) and is difficult to dispose or find a use for. These two factors were part of the reasons the ITR recommends (above) moving the alignment closer to industrialized land, close to multiple modes of transport, to handle removal of it in the most economical manner.

ITR cautions that the “reusability” of such material should not be over-sold within the project team, as no experience exists (within the ITR members) where material from a soft ground tunnel has been used as structural fill.

That sounds like a big “no” for planning on leaving the stuff around the Delta.

Are we finally rid of the Through-Delta Tunnel Route?

I love the Delta and our scenic waterways.

We’ve never thought it made any sense to put a major construction project through the heart of the Delta, on Delta islands and in small waterways beloved by boaters and for recreation.

Now we’re finding out that the Independent Technical Review (ITR) Committee, a group of engineers advising the DCA (that’s the Delta Conveyance and Design Construction Authority) January 31 report says:
“The consensus among the ITR was that the Central Corridor [aka the “Through-Delta” route] is logistically impractical and the ITR does not recommend this corridor be further studied.” (Page 6 of the linked report gives the details).
Just as we’ve been saying.They elaborated:

The shaft locations are located a significant distance from Interstate 5, accessible by only farm roads with hindrances such as narrow weight-restricted bridges and single lanes. This makes supporting large operations, which requires a constant transfer of materials and people in and out, impractical and expensive as well as difficult to price. In addition, addressing safety, including hospital access and tunnel safety duplication, creates a costly layer or redundancy without definitive costs. While it was recognized that extensive roadway, levee, and likely barge improvements could be constructed as part of the project for the Central Corridor, the ITR offered:

  • The cost of improvements to provide reliable and safe access and egress at each site would exceed the cost of additional length of tunnel required for the East alignment.
  • Levee re-build, barge, and site preparation & stabilization is temporary work, and much of it (e.g. barge facilities) will require removal;
  • Labor and construction safety costs, regardless of improvements, are too uncertain to price due to the location and distance from any shaft on the Central Alignment to developed land/communities.

The ITR Committee is actually pushing for a different route even further East than the Single Tunnel’s Eastern Corridor, closer to I-5 for construction transportation and onto more solid ground than Delta Islands. That would be a huge win for the Delta communities and makes sense, but could have cause new, unanalyzed impacts along that route.

Regardless, that doesn’t correct the other issues with the WaterFix that have been carried through into the Single Tunnel plan. We know that the intake locations in the north will destroy legacy communities there. The location has nothing to do with the “best” location for intakes but instead because DWR has an existing water right at these locations and will not have to go through the process of initiating a new water right if it selects these locations. This is not a lawful reason to exclude consideration of other locations. We know that location of the intakes next to legacy communities is not acceptable.

STCDA believes newer, modern technologies like desalination, recycling, and conservation for L.A. Replacing turf landscaping (green lawns) in southern California with drought tolerant landscaping would save more water than is annually diverted from the Delta. That plus investing in ground water table recharge for the Central Valley, not a tunnel, are the right solutions to help those areas of the state reduced reliance on the Delta through improved regional self-reliance which is a top priority for the Newsom administration. Newsom needs to drop the tunnel plan in favor of modern alternatives.

Save the Date – May 8

Important Milestones DWR is conveniently forgetting

A California Department of Water Resources (DWR) Scoping Meeting Slide:

Some of us would like to start with some earlier milestones:

  • June 8, 1982 – The voters soundly reject the California Proposition 9, the Peripheral Canal Act.
  • August 27, 2014 – DWR announce postponement of the BDCP Tunnels due to comments received. “The comments revealed that certain areas of the plan need additional study.”
  • August 28, 2014 – The EPA submits a 43-page report warning that the Delta Tunnels could violate Federal law.”
  • July 10, 2015 – Revised BDCP Plan (now called the “California Water Fix”) was released with only the Tunnel portion. Another plan, “EcoRestore” is the habitat restoration plan. [Comment: Has anyone heard anything about EcoRestore in the last five years? Crickets.]

Ah well, bygones. The list of key milestones presented by the Department of Water Resources (DWR) at the beginning of each of their Single Tunnel Scoping Meetings begins:

  • July 2017 – DWR approved a two-tunnel conveyance project (California WaterFix).
  • February 2019 – Gov. Newsom announced support for a single tunnel conveyance project.

Wait a minute here. That leaves out some very pertinent milestones.

  • November 2018 – The Delta Stewardship Council Staff recommended that WaterFix failed to meet the requirements to be incorporated into the Delta Plan. The certification for the Delta Plan was a requirement before DWR could obtain their permit for the tunnel intakes in the north. The plan should be remanded to DWR to fix. This was a big win for STCDA and others. Why did the Staff say not to sign off on WaterFix?
    • DWR didn’t use the latest “Best Available Science.”
    • The water suppliers hadn’t addressed “Reduce Reliance on the Delta through Improved Regional Water Self- Reliance.”
    • California WaterFix will have a significant adverse environmental impact.
    • WaterFix desn’t meet the Delta flow objectives.
    • And the biggie: WaterFix conflicts with land uses in existing Delta communities, conflicts with existing land uses due to impacts on cultural and historical resources, conflicts with existing Delta parks and recreation uses, traffic impacts, and conflicts with existing land uses due to noise impacts.

    The Staff recommended that the Council remand the matter to the Department for reconsideration.

  • December 2018 – Rather than wait for WaterFix to be officially ruled as “inconsistent” with the Delta Plan (hence unable to be built), DWR withdrew its certification request.

They ignored those two major milestones, significant wins for STCDA.

Then yes, in May 2019 DWR finally withdrew WaterFix. Up until that time, DWR had still been trying to pretend one tunnel would “fix” the problems with the twin tunnels and trying to move forward without writing a new plan or new Environmental Impact Report (EIR). But taken before a judge, it was clear that DWR couldn’t have it both ways. The DWR finally accepted the fact that they would need to write a new plan and a new EIR. In January they issued the Single Tunnel Notice of Preparation.

But wait . . . they didn’t “rewrite” the plan. The new plan has the same issues as the old, rejected plan. How does simply going from two tunnels to one solve the problems? Unless the Eastern Corridor is selected, all of the in-Delta impacts remain the same. And regardless of tunnel route, the impacts to the legacy communities in the North have not been corrected.

As far as “Reduced Reliance on the Delta through Improved Regional Self-Sufficiency,” a tunnel will never do that. A tunnel will increase reliance.

For L.A. to improve regional self-sufficiency, there needs to be a ten-year goal to stop pumping Delta water up over the Tehachapis to L.A. The State Water Project is the biggest consumer of electricity in the state yet, ironically, a priority of the Single Tunnel objectives to address climate change. The Delta water should be replaced with desalination, recycling, and conservation, such as replacing L.A.’s lawns with drought-resistant landscaping.

The Central Valley can reduce reliance on the Delta by desalination for Santa Barbara which now uses Delta water pumped over the coastal range. Some have proposed pumping ocean salt water pumped to the Central Valley to desalination plants there. There are plenty of areas in the Central Valley with damaged land laced with salts and selenium. More salt from a desalination plant will not be an environmental issue there. But of course, the Central Valley’s biggest issue is the loss of their aquifers. The Tulare Lake used to provide a natural percolation pond effect for those wells. At times of high rain, we should implement an approach to recharge ground water. Santa Clara Valley Water District has a good approach using Vasona Lake (water from Lexington Reservoir) as both a percolation pond and a nice park. A Tulare Lake replacement is needed. And, of course, a logical change would be to better manage what crops are right to be grown in the arid desert land there instead of orchards and almonds. To quote Dr. Michael, “As water becomes more scarce, but it may be less costly and more efficient to move crops, farm workers, and capital to more water rich locations in the Valley than it is to move water long distances out of watersheds.”

There are better alternatives to a tunnel that need to be evaluated.

Last Night’s “No Tunnel” meeting in Brentwood

First – a big thank you for everyone who showed up. We overfilled the room, standing room only. At least 100 people. We will post the pictures of the gathering before the meeting with our “No Tunnel” signs and banners.

Second, a big thank you to everyone who got up and made comments. The comments were awesome.

And last but not least, a huge thank you to our champion, Michael Brodsky, STCDA’s Legal Council, who drove up from the Santa Cruz area to attend the meeting.

Here is a video clip (thanks to Bill Wells) from last night’s meeting with Michael Brodsky, STCDA Legal Council, making his comments. Brodsky stated that he wants to propose alternatives that fully achieve the project objectives where a tunnel doesn’t and with much less environmental impact than the tunnel.

Here is the entire video, thanks to Gene Beley.

The stated [Single Tunnel] project objectives are:
First, to mitigate the effect of levee failure in case of earthquake which would cause salt water to rush in and endanger water supplies. The alternative to a tunnel is the common sense answer of strengthening the levees including with setback levees and channel margin habitat that have an environmental benefit and a dual benefit of protecting water supplies.

The second objective of the project is to mitigate sea level rise caused by climate change. That can be mitigated in several ways, the most obvious of which is to allow more water to flow through the Delta and out to the sea to push back salt water. And where does that water come from? It comes from stopping exporting water over the Tehachapi Mountains which also achieves the project objective of making the SWP deliveries more reliable. They’re not reliable because you’ve promised too much water in too many places.

Why do we stop it over the Tehachapis? Because the State Water Project consumes all of the electricity generated by all of California’s hydroelectric dams plus 4 or 5 billion kilowatts of gas fired carbon-emitting power each year. The State Water Project is a climate atrocity. Gavin Newsom has to face up to that. You are required by the Public Trust Doctrine to exercise a continuing duty of supervision in the public interest. And it’s obvious that the place of use in your water rights permits south of the Tehachapi Mountains must be amended so that that place of use is eliminated.

So one of the portfolio elements will contain a planned retreat from exports south of the Tehachapi Mountains, phased out over ten years.

Other elements that are included that do not include a tunnel, as I mentioned before, would be flooding some of the islands, some of the islands the levees can be strengthen, others can be sacrificed and those islands can be flooded for habitat and also as a barrier to salt water intrusion.

And you weren’t telling the truth when you said decisions weren’t made. The Notice of Preparation defines the range of alternatives. It has been written to exclude everything except Delta conveyance. So the major decisions have been made before you go to these scoping meetings.

But we are going to insist that you study non-tunnel alternatives.

What will L.A. do without the Delta water?

Many comments addressed this, and stressed that with California bordering the ocean, an obvious solution is desalination and other more modern technologies than a tunnel.

Jan McCleery’s comments included this:
In 2009 (prior to the WaterFix/Twin Tunnels) the BDCP rejected the desalination alternative saying it was too expensive. In 2013, Dr. Jeffrey Michaels at the University of the Pacific wrote about advancements in desalination technology making it cheaper and more effective. It’s now 2020. The EIR should study as an alternative to a tunnel, a retreat from exporting Delta water over the Tehachapis, replacing that water with new sources from desalination, recycling, conservation, and replacing lawns with desert landscaping. In other words, LA should reduce reliance on the Delta through improved regional self-reliance. Replacing lawns with desert landscaping would save more water than is annually diverted from the Delta. This is common sense conservation.

(Note: The 2009 Delta Plan requires “reduced reliance on the Delta through improved regional self-reliance.)

Side-Note about Reservoir and Habitat Islands

Mr. Brodsky referred to islands in the Delta that can be flooded or used for habitat. Four Delta Islands were purchased in 2016 by Metropolitan Water District were initially purchased as part of a project where two would be flooded as in-Delta reservoirs (Bacon Island and Webb Tract) and two would be modified as habitat islands (Holland Tract and Bouldin Island). See map below:

Metropolitan Water District put out a glossy describing what they planned to do with these islands to improve the Delta:

Of course, none of that has happened.

“New” Tunnel Plan, Same Problems

Here’s an overview of how the “new” Single Tunnel Plan is the same as the old plan. And what is different (not much).

The only difference is a possible new Eastern route which goes a bit more around-the-Delta than through it. But other than a swath of purple on a map, there are no details yet about construction impacts with an Eastern tunnel route.

Otherwise, the same construction impacts exists at the North intakes and along the old Through-Delta route (still an option). In addition, regardless of tunnel route, the construction will leave behind muck in the Delta plus the same long-term water quality issues exist.

DCA Engineer said not to worry about gas fields in the tunnel route

Say what?

The “Central Corridor” tunnel route goes through the largest natural gas field in California, the Rio Vista gas fields. At the Stakeholder Engagement Committee Meeting on Wednesday, February 12, Karen Mann, South Delta Local Business representative, asked the Delta Conveyance Design and Construction Authority (DCA) engineer about how they tunnel through gas fields.

She asked, “Don’t you build a tunnel in a straight line?”
Kathryn Mallon, lead DCA Engineer, answered, “Yes that is what we like to do.”
Karen then asked, “What happens if you accidentally pierce a gas or water pocket underground.”
The engineer presenting the slides replied that the gas was 1,000 feet underground so no worry.

Really?


Rio Vista Gas Fields

DCA is an organization established by the water contractors, primarily Metropolitan Water District (MWD), assigned to work on the design of the Single Tunnel project.

MWD has a history of ignoring risks. MWD ignored warnings of gas fields when tunneling the Sylmar Tunnel from the Castaic Reservoir (which is Delta water) to L.A. First came the smell of gas, then the blast that killed 17 miners deep beneath the San Fernando Valley neighborhood of Sylmar.

MWD is again ignoring the risk.

For more details on tunneling through gas fields, please see California Water Research’s report on Tunnel Construction and Gas Wells

Unacceptable – Single Tunnel Plan has the same Intake Locations in the North!


Karen Mann at the Stakeholder Engagement Meeting February 12, 2020.

At the Wednesday Stakeholder Engagement Committee Meeting, Karen Mann, representing South Delta Local Businesses, read feedback from one of her stakeholders explaining why we are enraged that the new Single Tunnel Plan has the same intake locations in the North Delta:

It is clear that the intakes cannot be placed in any of the locations shown on the preliminary drawings for discussion purposes (that is in 2 of the 3 locations of previous intakes 2, 3, and 5 of California Waterfix). Extensive evidentiary showings in the prior State Water Resources Control Board hearings and Delta Stewardship Council hearings show that neither of these agencies can approve intakes in these locations because it would not be consistent with the Public Trust Doctrine (Water Board) or the Delta Reform Act (Delta Stewardship Council). It is unacceptable to locate the intakes in close proximity to Delta Legacy communities. We understand that DWR wants to put the intakes in these locations only because they claim they have an existing water right at these locations. DWR will just have to accept the reality that they are going to have to put the intakes somewhere else and initiate a new water right in order to do so.

The question is: When will begin a realistic consideration of intake locations? That is, locations other than currently being considered. Talking about intakes at the current locations is a waste of time because it cannot happen.

That sentiment is similar to what we’re saying in addition about the “Central Corridor” tunnel route (which is the same as the WaterFix “Through-Delta” Alignment) which we proved in the prior Water Board hearings and DSC hearings that the shutting down of Delta waterways to boating and recreation was inconsistent with the Delta Plan and could not be approved. Talking about construction destruction through the center of the Delta is a waste of time.

In addition, nothing has changed with the long-term issues raised about impacts to the in-Delta water quality. You can’t take the fresher water out before it flows through the estuary and expect improvements for fish survivability.

Yet, DWR moves ahead with these “Scoping” meetings expecting community input.

Why aren’t they taking the input they previously received and altering their plan to make it acceptable?

REMINDER ***CALLING ALL HANDS

Thursday, February 20, 2020, 6 p.m. – 8 p.m. Brentwood Community Center Conference Room, 35 Oak Street, Brentwood. South Delta members are STRONGLY requested to attend !!! We will be in the parking lot at 5:15 p.m. to organize.

If you can’t make that one, there is one on Wednesday, February 19, 2020, 6 p.m. – 8 p.m. Clarksburg Middle School Auditorium, 52870 Netherlands Road, Clarksburg.


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