The State Water Resources Control Board sees problems

Thanks to Maven’s Notebook, here a summary of what the Water Board wants to see in the BDCP environmental documents.

  • Identification of all changes to water quality objectives, water rights, and other approvals that BDCP needs. 
  • Details on the scientific basis for changes that the Water Board can review independently.
  • A discussion of impacts on water rights; specifically, the Board must find that a change in point of diversion (to the North Delta, for the tunnel intakes) will not injure any legal user of water. (Given the number of legal users in the Delta, this requirement sounds impossible to meet.)
  •  Analysis of an alternative that reduces reliance on the Delta. (YES!)
  • Consideration of a broader range of outflow alternatives. The Water Board noticed that all the operational alternatives considered in the environmental documents reduced Delta outflow. “The justification for this limited range of Delta outflow scenarios is not clear given that there is strong information on the possible need for more Delta outflow for the protection of aquatic resources and the uncertainty that other conservation measures will be effective in reducing the need for flow. Specifically, recent research indicates that restoration of tidal marsh may not be feasible, possible, or effective” (emphasis added). 
  • Explanation of how the benefits of building the project “outweigh the unavoidable adverse environmental impacts” – i.e. how BDCP achieves the coequal goals.
  • Analysis of effects of multiple restoration projects, such as how constructing and implementing habitat restoration projects will affect tidal energy and its effects on fish.

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