This week, the Delta Stewardship Council (DSC) will release the draft Environmental Impact Report (EIR) for the Delta Plan. A 60-day review and comment period is required, so the DSC will not meet its deadline for completing the Delta Plan by January of 2012.
Many people think that 60 days is an unreasonably short comment period for such a broad impact analysis. The DSC has already missed its deadline – an indication of how complex the document is. It might be wise to extend the comment period to 90 or even 120 days, as suggested by Councilmember Gloria Gray. Allowing more time for input now might save costly and time-consuming litigation later.
The EIR assumes that the Delta Plan will be successful in encouraging agencies to undertake projects to achieve the coequal goals, such as new reservoirs, treatment plants, habitat areas, levee improvements, and Delta recreation facilities. It looks at typical environmental impacts for these types of projects. The Plan identified five categories of project types:
- Reliable water supply projects
- Delta ecosystem restoration projects
- Water quality improvement projects
- Flood risk reduction projects
- Delta-As-Place enhancement projects
The DSC’s PowerPoint presentation on the draft EIR is indirect in its references to conveyance alternatives, referring to them as “the Project” or “the Proposed Project.” The ability of “the Project” to meet the coequal goals will have to be determined later (when there is actually a Project and alternatives to evaluate).
However, the EIR does consider five alternatives to “the Project”:
- No Project
- Alternative 1A – based on comments from water users in export areas south of the Delta
- Alternative 1B – based on a proposal by the Ag/Urban Coalition
- Alternative 2 – based on proposals and comments by the Environmental Water Caucus and other environmental interests
- Alternative 3 – based on letters and comments from communities and interests in the Delta
The EIR analyzes alternatives in the same level of detail as “the Proposed Project.”
Notes the PowerPoint, “Projects to achieve the coequal goals are not environmentally free of charge.” This is an interesting admission, given the fact that ecosystem restoration IS one of the coequal goals. The presentation talks about “environmental impacts and tradeoffs,” proving once again that water supply reliability is the dominant value in this discussion.
Written comments can be submitted by mail or email. There will be two opportunities for public comment: November 17 and December 15, in Sacramento from 1 – 4:30 p.m. (See RTD’s calendar for updated details.) The 2,000-page EIR will be available on the DSC website as well as at county libraries around the state and on CD-ROM by request.
The schedule now calls for the DSC to consider and certify the EIR in March of 2012.
The California Association of Resource Conservation Districts (CARCD) is holding a conference at the Stockton Hilton November 8-11. Sessions include a primer on Bay-Delta issues and a panel discussion featuring representatives from the Delta Protection Commission and the Delta Stewardship Council.