On December 16, the San Francisco Baykeeper and 13 partner organizations filed comments with the California Department of Water Resources on the draft environmental impact report (DEIR) for Governor Gavin Newsom’s Delta Conveyance Project, AKA the Delta Tunnel.
The organizations represent a wide range of conservation, Indigenous, fishing, and Delta community interests. The organizations include the Natural Resources Defense Council, the Bay Institute, California Sportfishing Protection Alliance, Defenders of Wildlife, Pacific Coast Federation of Fishermen’s Associations, Institute for Fisheries Resources, Save the Bay, Restore the Delta, San Francisco Baykeeper, Golden State Salmon Association, Save California Salmon, California Indian Environmental Alliance, Friends of the River, and the Planning and Conservation League.
The groups say the DEIR “fails to comply with CEQA and must be substantially revised and recirculated in order to provide the public and decisionmakers with accurate information regarding the potential environmental impacts of the proposed project and alternatives.”
“Like the two failed proposals that came before it, Governor Newsom's latest conveyance plan would divert water from the Sacramento River through a tunnel bored under the Delta,” according to the SF Baykeeper. “A similar tunnel project proposed by Newsom's predecessor, Governor Jerry Brown, was withdrawn in 2018 following intense criticism of the cost and negative effects on the environment.”
"If constructed, the Delta Conveyance would be a death sentence for our region’s fisheries and for communities that rely on those fish for food, recreation, and cultural practices,” said Baykeeper Senior Scientist, Jon Rosenfield, PhD, in a statement. “Despite overwhelming evidence that the San Francisco Bay estuary’s water quality and fishes are declining fast—and that more flows from Central Valley rivers need to reach San Francisco Bay to avert an ecological disaster—Governor Newsom’s tunnel proposal will decrease flows to the Bay.”
"California’s plan for operating this new tunnel adopts rules established by the Trump administration’s ‘extinction plan.’ The state’s own analysis demonstrates that the tunnel’s water diversions will damage the environment, even beyond the harm that’s currently being caused by the Trump plan. The fact that his new water diversion will lead to worse outcomes than Trump’s extinction plan should tell Californians all they need to know about Governor Newsom’s latest proposal,” he stated.
"This Governor likes to talk about changing the dialogue around California’s 'water wars,' but his new tunnel plan demonstrates once again that his administration accepts the false dichotomy that water supplies must come at the expense of our struggling ecosystems and communities. California should invest heavily in local and regional water supply projects that reduce reliance on water exported from the Delta, in compliance with existing state policy. Investing in municipal water recycling, conservation, and agricultural water use reforms would increase California’s resilience to climate change, generate good jobs, and provide some relief to struggling fish and wildlife, and the communities that rely on them,” Rosenfield concluded.
On December 14, Restore the Delta also submitted detailed comments on the DEIR for the Delta Conveyance to the California Department of Water Resources. Read the comment letter and attachments by Restore the Delta.
According to the group, “The proposed project would construct new water intake facilities on the Sacramento River in the north Delta to fill a single tunnel with diverted freshwater flows. That water would be shipped to large farming operations and water wholesalers south of the Delta. The Delta Conveyance project would divert up to 6,000 cubic feet of water per second. The project is estimated to cost between $16-40 billion and won’t be completed until at least 2040.”
“The California Department of Water Resources should be embarrassed by the lack of climate change planning in the DEIR for the proposed Delta Tunnel,” said Tim Stroshane, Policy Analyst, Restore the Delta. “The DEIR was out of date for climate change science when it was released in July 2022. If completed in 2040 it will be obsolete then.”
“Meanwhile, California will have spent big money on a project the state will be unable to use as Delta water levels rise. Instead, we should invest in the resilience of Delta environmental justice communities and the rest of the state for flood and water supplies, reducing the big projects’ reliance on the Delta for future water needs, using water use efficiency and water recycling, and increasing local and regional water supply self-sufficiency to ward off drought and megafloods,” added Stroshane.
“DWR has learned nothing since California WaterFix,” stated Barbara Barrigan-Parrilla, Executive Director, Restore the Delta. “Their sales pitch, that the tunnel is a climate project, is built on incomplete data and faulty analysis. They have continued their pattern of erasing how the project will impact Delta urban environmental justice communities. And they are minimizing how construction will ruin small Delta farming towns, and the natural resources essential to the cultural and spiritual practices of historic Delta tribes. The tunnel is a failed idea that nobody supports, except for the Department of Water Resources.”
Here are some highlights from Restore the Delta’s comments:
Environmental impact of Tunnel:
“Reviewing the Executive Summary, we count 17 significant and unavoidable impacts of the proposed Tunnel project on the environment. Among these impacts will be loss of prime agricultural farmland, loss of local non-tribal cultural resources, transportation and air quality impacts, and painful loss of tribal cultural resources. There are other impacts omitted, belittled, or greenwashed by the Tunnel DEIR.”
Flow and salinity impacts when Tunnel in operation:
“The Tunnel Project has region-scale impacts on the Delta, should it be built. The Tunnel DEIRacknowledges that a major operational impact will be, reducing Sacramento River flows (and hence flows to its distributaries in north and central Delta channels) and reducing the estuary’s ability to repel tidal salt waters which are ever-present (see Attachment 9 to this letter). Such operational impacts will have economic and ecological impact on the Delta region, and a Community Benefits Program must be developed to mitigate the economic and ecological effects of Tunnel operations on Delta communities, especially environmental justice communities.”
Failure to consider alternatives:
“DWR in particular is hide-bound in its loyalty to a Delta conveyance approach eclipsed by the emerging and growing effects of extreme heat and extreme storms.
“A huge failure of imagination by DWR is on display in this DEIR. Each of these alternatives is vulnerable to the slings and arrows of expected climate change effects, which we will go into further below when commenting on project modeling methods and results. But what we see displayed in the Tunnel DEIR is a complete failure of state water officials to imagine alternative approaches these last few years since the demise of California WaterFix in early 2019.”
Faulty consideration of Delta Environmental Justice impacts:
“We are deeply disappointed that DWR resorted to ignoring its ‘Your Delta, Your Voice’ Survey as a basis for informing how and what kind of environmental, environmental justice, and community impacts the Delta Tunnel Project would impose on the Delta EJ community both of the direct Legal Delta and of the Delta Region as a whole. It is plainly obvious that 1) the Legal Delta as well as the Delta Region are bona five environmental justice communities, with relatively small proportions of white and wealthy populations; 2) Delta residents AND Delta region community members rely substantially on the Delta directly, and the north Delta in particular, for subsistence fishing, and it is thus an environmental impact to have both fishing spots taken away from anglers and fish removed from the vicinity for North Delta Intakes construction activities; and 3) in the operational phase, lost flows in the Delta will increase salinity in the Delta as it reduces flows in north and central Delta channels, and thereby contributing to the spread of harmful algal blooms which will disproportionately injure Delta people who rely on fishing and broad outdoor activities to enjoy the Delta. In sum, the Delta Tunnel Project will harm such beneficial users of water as fish, outdoor water-contact recreation, and environmental justice communities.”