Last month, DWR director Mark Cowin announced that computer modeling showed an additional 700,000 acre-feet of water could have been sent to exporters since November 1 if the peripheral tunnels had been in place. The argument is that with North Delta diversions, less water would be pumped from the South Delta, so smelt would not be harmed and pumping would not be restricted.
That’s nonsense, according to Bill Jennings, Executive Director of the California Sportfishing Protection Alliance. Jennings has produced a white paper showing why the peripheral tunnels being advocated by BDCP will NOT eliminate massive fish kills at export facilities.
The fish screens in the South Delta are obsolete, based on 60-year-old technology that has resulted in massive fish losses year after year for decades. The CALFED Record of Decision required construction of state-of-the-art fish screens at existing South Delta facilities, and these were supposed to be in place for operation and testing by mid-2006. But the State and Federal Project Contractors refused to pay for them, rejecting a strategy that might have allowed for the reliable exports they wanted with less harm to fish.
The most recent BDCP documents available estimate that even with the tunnels, 50% of State and Federal Project exports would come from the existing South Delta diversion facilities in average water years and as much as 75-84% in dry and critical water years. That’s because of flow requirements and biological constraints affecting diversions from the Sacramento River. But even recognizing that exporters will continue to rely on South Delta diversions, BDCP does not contain new South Delta fish screens.
BDCP does provide for fish screens at the new North Delta diversion points. But no one knows if these screens will actually work. The design is experimental and has never been used anywhere else. Nearly two dozen studies will be necessary to determine if the design will work and can be legally permitted, and half the studies can’t be done until after the facility has been constructed. If the screens don’t work at that stage, experience tells us that the diversions will go ahead anyway.
The peripheral tunnels plan does nothing to reduce fish kills. Not only that, but the draft Effects Analysis Summary of Effects says that under BDCP, for some runs in some years, we could actually see INCREASED entrainment in the South Delta of juvenile steelhead, Chinook salmon, Longfin smelt, and Sacramento spittail. The BDCP Effects Analysis for the proposed North Delta pumps is cursory and speculative, not supported by feasibility studies or design work and with no established operational criteria.
Whatever other benefits the peripheral tunnels might claim, there is just no evidence at all that they will benefit fish. And if they don’t benefit fish, how can the state and federal fish agencies issue permits for the project?