California Environmental Water Caucus Submits Comments on Bay Delta Conservation Plan and


June 11, 2014



Butte Environmental Council

California Coastkeeper Alliance

California Save Our Streams


California Sportfishing Protection


California Striped Bass


California Water Impact Network

Clean Water Action

Citizens Water Watch

Desal Response Group

Environmental Justice Coalition

for Water

Environmental Protection

Information Center

Earth Law Center

Fish Sniffer Magazine

Foothill Conservancy

Friends of the River

Food & Water Watch

Institute for Fisheries Resources

The Karuk Tribe

North Coast Environmental


Northern California Council,

Federation of Fly Fishers

Pacific Coast Federation of

Fishermen's Associations

Planning & Conservation League

Restore the Delta

Sacramento River Preservation


Sierra Club California

Southern California Watershed


Winnemem Wintu Tribe



The Environmental Water Caucus has responded to the Bay Delta Conservation Plan and its associated Environmental Impact Report with a stinging 250-page critique of BDCP’s inadequacies and multiple failures to conform to state and federal laws. Among the criticisms detailed in the Caucus’ review are that it is contrary to the Delta Reform Act of 2009, it fails to provide adequate ecological assurances under state and federal endangered species laws, it fails to assure funding for the project, and it fails to analyze reasonable alternatives to the preferred plan for huge tunnels under the Delta. Other points highlighted by the Caucus include:

· Exporting more water out of the Delta was a foregone conclusion for the main proponents of the plan, which are the powerful water districts south of the Delta. BDCP has cherry picked the science to support that objective and has created 40,000 pages of biased analytical findings to support that predetermined goal, trying to hide the real intent in the process.

· Federal and state laws require that a permissible project must contain a solid financing plan – precisely the kind of plan that BDCP lacks. Even after seven years of planning and debate, BDCP fails to spell out who will be responsible for the $50 to $60 billion cost.

Tax payers can expect to pick up most of that tab.

· The Bay Delta “Conservation” Plan has little to do with conservation. In an effort to mislead the public, BDCP disingenuously characterizes the eight-lane expressway sized tunnels that will drain the Delta of life sustaining freshwater as a “Conservation Measure”.

· Purporting to restore Delta ecosystems and protect its most vulnerable fish species, BDCP would instead further reduce natural Delta flows to San Francisco Bay, helping push listed, vulnerable salmon and resident fish species into oblivion, and officiate at the demise of California’s salmon industry.

· BDCP proffers the snake-oil hypothesis that physical habitat can substitute for water flows, while ignoring the fact that water is aquatic habitat. While BDCP analyzes the tunnels at a specific project level, habitat is only analyzed at a conceptual level. BDCP only promises to restore some acres of habitat somewhere at sometime in the future, if funding can be secured, while ignoring that most habitat restoration efforts in the past have failed to achieve predicted results.

· BDCP will degrade water quality and harm beneficial uses of water in the Delta, along with promoting wasteful and unreasonable uses of water south of the Delta, contrary to numerous state and federal water quality laws and the California Water Code.

· While BDCP trumpets the risks to California’s water supply from massive Delta levee failures due to earthquakes, BDCP lifts not a finger to address these supposed seismic levee issues.

· The current plan heightens opposition to the project, reinforcing the view that this project must not go forward.

Barbara Barrigan-Parrilla, of Restore the Delta, characterizes the BDCP as “a construction project masquerading as a habitat conservation plan”. “The plan is an omelet of distortion and half-truth intended to mislead and deceive”, according to Bill Jennings of the California Sportfishing Protection Alliance. The Environmental Water Caucus proposes an alternative that reduces water exports to a more sustainable level, in order to permit recovery of the Delta while maintaining water supplies for both Delta and south of Delta water users.

See the detailed Caucus comments at:


Conner Everts, Environmental Water Caucus, 310-804-6615

Bill Jennings, California Sportfishing Protection Alliance, 209-464-5067

Barbara Barrigan-Parrilla, Restore the Delta, 209-479-2053