Delta Plan: Ambitious document, serious flaws

The big news this week with the Delta Stewardship Council (DSC) is that everyone who wants to comment on the 2,000-and-some page Draft Environmental Impact Report (DEIR) for the Draft Delta Plan has until February 2 to do it.

Restore the Delta has commented in detail on some portions of the DEIR as part of comprehensive comments by the Environmental Water Caucus, and we have also associated ourselves with comments by South Delta Water Agency, the Central Delta Water Agency, San Joaquin County, California Sportfishing Protection Alliance, California Water Impact Network, law firms representing commercial fishing and environmental interests, Local Agencies of the North Delta (LAND), and the City of Stockton.

The comments we are submitting independently highlight these points:

  • The Delta Plan and the DEIR do not include measurable or otherwise quantifiable targets for flows into and through the Delta, for increased fish populations, or for improved Delta water quality.
  • The DEIR does not examine and elucidate how incorporation of the BDCP into the Delta Plan will impact the scope and the effects of the Delta Plan on the Delta ecosystem and Delta communities; moreover, the DEIR fails the CEQA requirement for examination of inconsistencies between the Delta Plan and the BDCP.
  • The Delta Plan and DEIR do not reconcile statutory duplications and conflicts between BDCP operations and implementation of the Delta Plan.
  • The Delta Plan and the DEIR are incomplete because the legislative mandate to evaluate and incorporate the Economic Sustainability Plan into the Delta Plan has not been completed.

The Plan, consequently, does not meet the needs of Delta communities, the Delta ecosystem, or California citizens, who are clamoring for government agencies to fulfill their missions efficiently and in a cost effective manner.  Without analysis of the BDCP, and incorporation of the Economic Sustainability Plan, the Delta Plan and the DEIR are premature and incomplete, and fail to serve the public interest.


The 5th draft of the Delta Plan itself (on which the DEIR is based) came in for scrutiny at the DSC meeting last week from John Kirlin and Bob Twiss, who are in charge of writing the 6th draft. They highlighted and identified central themes and listed the stakeholder groups associated with those themes. While retaining their own credibility and objectivity, Kirlin and Twiss were quite critical of the draft.  They stated several times that they had not begun work on the 6th draft.

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