“The struggle of man against power is the struggle of memory against forgetting.”
– Milan Kundera
Taking advantage of a crisis
Most people except some overwrought San Joaquin Valley congressmen and the Speaker of the US House of Representatives realize by now that there’s no water for farming right now because THERE’S NO WATER. Even if we had twin tunnels today, there would be no water to put in them.
Reservoirs serving agricultural users were in good shape earlier this year (and those serving Southern California urban users still are). But the Department of Water Resources and the Bureau of Reclamation pumped a lot of water out of reservoirs north of the Tehachapis this past summer, gambling that we would see fall and winter rains and a healthy snowpack rather than another year of drought. They lost the gamble.
This failure of prudent water management has provided both the state and the federal governments with an opportunity to try to wring more water from California’s oversubscribed water system. Governor Brown’s Drought Declaration suspends CEQA environmental regulations and instructs the State Water Resources Control Board to “immediately consider petitions requesting consolidation of the places of use of the State Water Project and Federal Central Valley Project, which would streamline water transfers and exchanges between water users within the areas of these two major water projects.”
Meanwhile, Congressman Devin Nunes and fellow San Joaquin Valley congressional representatives are pushing federal legislation to maximize pumping from the Delta (But guys, there’s hardly any water to pump!) and to suspend the Central Valley Project Improvement Act (CVPIA), which is intended to restore the San Joaquin River. Here’s a summary. The main target seems to be the CVPIA, and they’re declaring open season on striped bass and American shad.
Facts that Nunes and company don’t care to hear
California Water Research has produced some fact sheets on the current drought, updating earlier work by California Water Research on the same subject. Covered are Delta exports (NOT greatly reduced due to ESA restrictions); agricultural jobs in Mendota (not significantly changed, according to statistics from the California Employment Development Department); Westlands soil (full of salt and going out of production); and Westlands water supply (groundwater severely depleted and contaminated).
Not enough water for salmon, either
Down the Valley, they’ve been complaining for years about a Congress-induced drought that they blame on Endangered Species Act restrictions on pumping. You’ll hear Westlands Water District representatives ask why those restrictions haven’t actually helped fish.
More water has been promised to export users than can be reliably supplied, especially in a dry year, and unsustainable levels of water have been pumped. So fish would be much worse off without endangered species pumping restrictions. Says CSPA Executive Director Bill Jennings, “Salmon have been suffering from a manmade drought for decades and this year’s lack of rainfall exacerbates the problem.”
CSPA, Golden Gate Salmon Association, Pacific Coast Federation of Fishermen’s Associations and Coastside Fishing Club have asked state and federal fishery and water officials to convene an urgent meeting to save California Central Valley Chinook salmon runs from the drought. These groups are asking the officials to meet with key leaders from the fishing community (commercial and recreational) along with non-government fishery scientists and other stakeholders, to map out a drought action plan.
“All four of the Central Valley Chinook runs are in immediate peril due to the drought and a large percentage of the 2013 production may be lost if no action is taken,” said Marc Gorelnik of the Coastside Fishing Club. Drought has left rivers and reservoirs extremely low during this critical time for incubating fall run salmon eggs and out-migrating fry. Other wild juvenile salmon, including the listed winter and spring run Chinook, are still rearing in the upper portions of rivers waiting for unlikely winter and spring pulse flows to aid in their downstream migration to the sea.
“Because of the drought, we may need to capture and transport wild and hatchery salmon juveniles to get them safely out of the rivers and into the lower delta or bay,” said John McManus, executive director of GGSA. “We’ve already lost a major portion of the salmon eggs laid in Central Valley rivers and streams in late 2013 because water flows were drastically cut which left the eggs high and dry.”
We would hate to see another salmon fishing closure like the one we saw in 2008 and 2009. But that could happen if there are not enough salmon from this year to return to spawn.
The tunnels that would be dry
The BDCP Public Open House Meetings are moving dutifully forward (“Inform the public? Check it off.”) People who attend these meetings can pick up some materials they might otherwise have to download and print at their own expense if they wanted a paper copy. And they can get their very own CD of the 40,000+ pages of the BDCP Plan and the EIR/EIS.
After this week, there are no more open houses in the Delta region until the one in Clarksburg on February 12. Between now and then, the BDCP road show is visiting Los Angeles, Ontario, and San Diego. It is disheartening to see how much misinformation the folks down south are going to get from all the glossy booklets and displays. They’ll hear, for example, that BDCP will result in a 52% increase in protected land in the Delta (Protected from whom? For what?) and that 11 fish species will “benefit” (but there’s no provision for the actual recovery of endangered species).
Some of the BDCP people at the open houses are just the foot soldiers of the effort, and they’ll record your comments and valiantly try to answer your questions. (One young woman tried to explain that the tunnels would be 100 feet underground when the shiny foam board display beside her clearly said 150 feet.) Some of the people there to answer questions are consultants, confident that they have the answers. It appears that they would all be more comfortable chatting with each other than with the public, whom they seem to outnumber.
The generals of this effort, meanwhile, are managing the campaign in their usual arrogant way. This language has been added on the BDCP website under “Correspondence” after the paragraph including “The BDCP encourages public participation”:
“In order to maintain the integrity of the formal public review period, incoming correspondence will not be available via the website beginning December 13, 2013 through the close of the public comment period April 14, 2014.”
Since the purpose of the Draft NEPA and CEQA process is to identify and respond to the pertinent environmental issues and alternatives, this restriction on publishing letters critical of aspects of the plan is troubling. Comments are submitted to the federal agency, NMFS, but the EIR/EIS was issued by the State, and the State maintains the website. This has the effect of obscuring the process.
Nevertheless, don’t hesitate to submit comments. Maven’s Notebook has a helpful Road Map to the documents. Try not to be intimidated. Just plunge into any area that interests you, start reading, and comment on anything that strikes you as important. Cite chapters, sections, pages, wording.
Using modeling to stack the deck
At its most recent meeting, the Delta Independent Science Board viewed a presentation by an independent consultant who had been commissioned by a group of Northern California and other non-exporter water agencies (including Friant Water Authority, Contra Costa Water District, and EBMUD) to evaluate the CALSIM modeling used in BDCP. (CALSIM is a water resources simulation model for evaluating operational alternative of large, complex river basins).
The details of the evaluation have not yet been published. What is clear, though, is that DWR used CALSIM modeling from 2009 when 2013 modeling was available to them, and that they didn’t consult with reservoir operators about how operators would likely behave in response to climate change (what would be their “adaptation measures”).
Using 2013 data and input from operators, the independent consultant determined that the BDCP EIR/EIS underestimates by 200,000 AF the total exports (41% according to the presentation) and overestimates Delta outflow by 200,000 AF (34%). Also, BDCP does not accurately reflect the location of diversions from the Delta under updated modeling assumptions.
In other words, the independent modeling analysis determined that the analytical tools underlying the BDCP documents released in December are flawed, and they are flawed in ways that underestimate exports and overestimate outflows. Exporters could actually expect more water than they have said they could, and they would actually release less to the estuary and the Bay.
We should have more information about this when the independent modeling analysis is published.
The cheerier export picture may explain why the Westlands board of directors now appears willing to spend $500 million more on tunnel construction planning.
And finally, here are some photos to remind us all why we continue to fight on behalf of the Delta.