Form Letter for BDCP Public Comment Letter: Funding

One example BDCP response letter which you can share and personalize for your own response. Go back to our main page on how you can submit a public comment for the BDCP.

(Note: You can also submit this by email to

BDCP Comments
Ryan Wulff, NMFS
650 Capitol Mall, Suite 5-100
Sacramento, CA 95814

Dear Mr. Wulff:

Before take permits can be issued under a habitat conservation plan, funding must be shown to be sufficient for all proposed activities, and all financial contributors and planned allocation of funds must be identified. You should be very skeptical of any Implementing Agreement that BDCP planners eventually submit, given the fact that they have been unable to give the public a reasonable amount of time to evaluate the funding proposal before the close of the EIR/EIS comment period.

The State and federal water contracts argue that the twin tunnels should be built because they have spent a quarter of a billion dollars on producing a Bay Delta Conservation Plan draft and environmental documents, including paying millions of dollars to consultants, holding years of meetings, and making dozens of presentations. However, they admit that the engineering for the actual tunnels is only 10% complete. This provides a poor basis for estimating the cost of building the twin tunnels that are the centerpiece of this habitat conservation plan.

It is therefore not surprising that urban and agricultural users that would be the beneficiaries of BDCP are balking at paying for these tunnels that cannot guarantee them more water. Now that the whole state sees the effect of prolonged drought, it is obvious to users that the tunnels could not even guarantee a more reliable supply of less water, even if water quality protections for fish and people are suspended. Metropolitan Water District member agencies in Southern California are looking for their own water supply alternatives and could opt out of taking SWP water, making MWD unable to meet its financial obligations. Similarly, agricultural users in the San Joaquin Valley have made it clear that they will not be able to afford the cost of water delivered by the tunnels. If contractors cannot meet their financial obligations for the project once it is built, taxpayers will end up paying.

As far as funding the actual habitat restoration portion of the plan, the water contractors have redefined ecosystem work as a public benefit and are counting on federal assistance and bond funding to pay for it. But there is absolutely no guarantee that Californians will approve a water bond this year or in the future, or that any bond they do approve will include funding for BDCP. Furthermore, it is highly doubtful that Congress will fund $4 billion toward a habitat conservation plan for California as described in the BDCP presently.

No one wants to pay for this ill-conceived infrastructure project, so I encourage the fisheries agencies to refuse to issue permits that would enable it to go forward.

Related Posts