STOCKTON — The Twin Tunnels – if built – will raise havoc with the Delta and cripple San Joaquin County’s economy.
In a nutshell that’s the concern of the San Joaquin County Board of Supervisors who on Tuesday reaffirmed their opposition to the Bay Delta Conservation Plan (BDCP) by approving a terse resolution and the formal submission of public comments, slamming the multi-billion dollar proposal on nearly every level.
“The Bay Delta Conservation Plan has been called the largest public works project in the history of the United States,” noted Bob Elliott, Chairman of the San Joaquin County Board of Supervisors. “It has also been called a gigantic boondoggle. Whatever its label, based upon any real and objective analysis of the scientific and economic data as well as plain common sense, it is evident that the BDCP’s twin tunnels will effectively destroy the Delta as it exists today and forever alter and negatively impact the economy and citizens of San Joaquin County,”
Supervisor Larry Ruhstaller views the Twin Tunnels as a ruse claiming to protect the environment while actually assuring reliable water deliveries for interests far removed from the Delta.
“The BDCP labels itself as a ‘comprehensive water conservation strategy’ aimed at protecting dozens of species of fish and wildlife, while permitting the reliable operation of California’s two biggest water delivery projects, Ruhstaller said. “In reality, the BDCP is an almost incomprehensively massive and expensive water delivery project thinly green-washed as a conservation strategy.
While the County has made no bones about its opposition to the BDCP, San Joaquin and its’ partners on the Delta Counties Coalition (DCC) sought to have a place at the table in the development, planning and implementation of the project. They were frozen out of the process by the State and given no decision-making authority, even though the Plan will have significant and direct impacts on the region.
San Joaquin County Board of Supervisors described some of the BDCP’s fatal flaws including:
• Denying taxpayers and ratepayers a vote regarding the public financing of the project estimated in the range of $25 billion to $60 billion.
• Omitting key and relevant information required by the law to understand how the BDCP will actually be implemented operated, and funded.
• Allowing State and Federal Water Projects to violate water-quality standards in favor of increasing exports.
• Relegating San Joaquin County to a non-voting Stakeholder Council which is simply unacceptable as a central part of a Delta Region that would sustain negative economic impacts.
“A critical component of the BDCP includes the conversion of nearly 140,000 acres of prime agricultural land to habitat, resulting in significant impacts to agricultural production in San Joaquin County,” said Supervisor Ken Vogel. “This would result in negative economic impacts on agriculture ranging from $62 million to $227 million in revenue losses per year, The BDCP clearly states that if the tunnels and the conversion of agriculture to habitat fail to recover endangered species that another conservation measure would be selected instead. This adaptive management scheme would leave in its wake hundreds of lost jobs, thousands of acres of exploited agricultural land and millions of dollars in lost revenue. That’s a pretty expensive experiment that will forever change agriculture in San Joaquin if you ask me.”
Highlights of the key points asserted are summarized as follows:
• The latest report by the Delta Independent Science Board found that a) the BDCP’s EIR/EIS failed to use the “best available science”, b) uses overly optimistic expectations and uncertain assumptions, c) is fatally flawed in other respects which thwart the statutory goals of the EIR process and undermines the projects ability to meet the requirements of California Environmental Quality Act (CEQA) and the Delta Reform Act.
• Defining the twin tunnels as a “conservation strategy” is fundamentally misleading and does not comply with Federal and State law.
• Taking more water out of the Delta has negative impacts on the health of the Delta, diminishes existing water rights, and increases the risk of destruction of Delta resources.
• The BDCP inadequately analyzes, on a CEQA project-level basis, the impacts of the twin tunnels and does not analyze at all, on a project level, the remaining 21 non-conveyance conservation measures in the Plan, as well as a reduced exports alternative.
• The BDCP relies heavily on “adaptive management” to deal with uncertain outcomes and impacts, yet the adaptive management process is not adequately developed.
• The BDCP’s stated goal to “restore and protect” the State and Federal water projects’ nonexistent ability to deliver “up to full contract amounts” is unrealistic and inconsistent with Federal and State environmental laws.
• The BDCP improperly attempts to insulate permit holders from further responsibilities, financial and otherwise, to meet Federal and State environmental laws and seeks to shift those costs to other public and private parties and taxpayers.
• The BDCP fails to establish required baselines for measuring existing environmental conditions and uses multiple inconsistent baselines for determining the future impacts of the BDCP.
• The BDCP erroneously relies on speculative future conditions half a century in the future when comparing its preferred project of the twin tunnels to alternatives, including the “no project” alternative.
• The BDCP relies on a fundamentally flawed economic impact report. The State has refused to conduct a comprehensive cost-benefit analysis utilizing Department of Water Resources’ own guidelines.
• The BDCP fails to provide for assured financing for the 21 non-conveyance “conservation measures” of the Plan, which assurance is required under Federal and State law.
“We’re all concerned about natural disasters. We should not have to worry about engineered disasters, which is what the BDCP project is. It’s time for the Administration to accept the obvious and admit that the BDCP is the wrong water strategy for California,” added Supervisor Carlos Villapudua. “ It is fatally flawed – legally, scientifically, and financially.”
The action taken by the Board of Supervisors will authorize the submission of formal comments on behalf of San Joaquin County regarding the BDCP by the current deadline of July 29.
In addition to the comments, the Board also adopted a formal Resolution reaffirming its opposition to the BDCP.