BDCP would make all this worse

One of the many gargantuan problems with the Bay Delta Conservation Plan (BDCP) is that it makes poorly-supported assumptions about available Sacramento River flows.  As the Bureau of Reclamation said in its comments on the BDCP’s environmental impact statement (EIS), “The current BDCP analysis assumes no operation impacts to upstream reservoir operations.”  But Sacramento River flows are controlled by the operation of upstream reservoirs.

If BDCP expects to provide “reliable” flows to export users, operation of the Peripheral Tunnels will have to involve operation of upstream reservoirs.  And we are seeing this year how that works, or doesn’t work. 

The Bureau already foresees environmental and water rights problems associated with federal operations vis-à-vis BDCP.   “Analysis of upstream affects (sic) may not be sufficient to serve as NEPA compliance for Reclamation to accept BiOP [the biological opinions to protect fish] depending on the outcome of pending 9th circuit appeal filed by NRDC . . . .”  And “There is a cursory statement in the beginning [of Chapter 5] that changes to operation of the CVP and SWP cannot affect senior water rights holders and that none of those supplies would be affected.  It would be helpful to have more information to support that conclusion. . . .” 

The National Marine Fisheries Service, too, is concerned about what goes on upstream to make the Peripheral Tunnels project work.  “The lack of analysis of upstream operations and related effects may render this document [the EIS] insufficient to provide NEPA compliance for the full suite of actions necessary to integrate the BDCP into CVP operations.”

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