Why the Draft Environmental Impact Statement (DEIR) of the Ministry of Water Resources on Proposed Delta Tunnel Project Rejects Consideration Any Are there operational alternatives to increasing flows in and out of the delta to protect salmon and the environment?

After all, as the State Water Commission concluded in 2009, for more than a decade, state and federal agencies have repeatedly concluded that:[t]The best available science suggests that current flows are insufficient to protect public trust resources. The Delta’s minimum water quality and runoff requirements in the Bay Delta Water Management Plan have not been substantially updated since 1995, and since 2008 the State Water Commission has implemented outdated and inadequate flow requirements that have created an environmental crisis. has been working to update the In 2018, the Board published a framework for completing the Bay Delta Plan’s updated water quality standards. This calls for increased delta runoff and suggests improving upstream reservoir storage and temperature management. 2 million acre feet per year). Additionally, the State Water Authority’s CEQA scoping comments on the Delta Tunnel, consistent with the State Water Authority’s 2018 framework, urge DWR to consider one or more operational alternatives to increase flow through the delta. explicitly instructed to

While there is no dispute that the proposed construction of the Delta Tunnel will have significant impacts on Delta residents and communities over the years, the impacts of the Delta Tunnel project on fish and wildlife will depend on how the project is implemented. depends crucially on how it is operated. When was it diverted and how much was left in the environment? When NRDC proposed an alternative to his single tunnel portfolio in 2013, a key factor was environmental protection operations that would reduce water diversion from the delta in most years. The operating standards of existing and proposed new infrastructure such as the Delta Tunnel are critical to the survival and extinction of many native fish species, including native salmon schools and the thousands of jobs that depend on their health. It makes a difference.

But inexplicably, DWR’s DEIR refuses to consider it. Any Operational alternative. To make matters worse, DWR’s proposed Delta Tunnel operations are more environmentally friendly than those required by the National Marine Fisheries Service and other agencies for their proposed twin tunnel project (California WaterFix) only a few years ago. protection is severely inadequate. This letter to his DWR last year. As a result, all DEIR alternatives will increase water exports from the Delta by an average of about 500,000 acre-feet per year. This includes a significant increase in water diversion in dry and extremely dry years (200 to 300,000 acre feet per year). As the DEIR table below shows:

Since this project does not include an environmental operating basis, DEIR’s modeling (see pages ES-71 to ES-74) is based on the winter and spring salmon season traversed by the Delta Tunnel (and all alternatives). concluded that it reduces the survival rate of Reduce delta, longfin smelt abundance, increase numbers of entrained and killed delta smelt, and worsen ecological conditions in estuaries (reduce delta runoff in dry and very dry years) – see Table 5A-B3.3.4.4) -D.). Conditions in the Gulf Delta are dire for native fish and wildlife, but DEIR shows that the Delta Tunnel project, at least in its proposed operation, will make the delta even worse.

If that is not enough, DEIR will not consider climate change impacts when assessing whether proposed projects and alternatives will cause significant impacts under CEQA. Instead, the CEQA analysis is based on observed hydrological conditions from 1922 to 2015 and does not take into account climate change impacts that have been documented and observed over the past century. These include increased air and water temperatures, early runoff, and increased frequency and magnitude. Drought and sea level rise. The DEIR includes an appendix modeling the impacts of the Delta Tunnel, including projected climate change impacts in 2040, when the Delta Tunnel first becomes operational,

These long-term analyzes are conducted outside of CEQA requirements and provide information on future environmental conditions once the transportation facility is operational. Because these analyzes are provided for informational purposes, no significant CEQA conclusions on potential impacts are provided and mitigation measures are not recommended to mitigate potential impacts.

(DEIR, Chapter 4, 4-5 to 4-6). This approach appears to be in clear violation of DWR’s 2018 guidance on climate change analysis and is not CEQA compliant.

The fact that increased flows into and out of the Gulf Delta is necessary to protect and restore the health of this endangered ecosystem, combined with the fact that the State Water Commission’s 2018 Framework for Gulf Delta Water Quality Management Ignore the fact that it is a reasonably foreseeable update of the plan. Considerable – contradicts CEQA. To be fair, Delta Tunnel’s DEIR isn’t the only CEQA document in his refusal to consider operational alternatives to protect the environment. In the coming weeks, we will highlight several other flawed environmental analyzes of the Gulf Delta project. All of these suggest diversion of the same water. Scientifically authoritative update to other delta water targets for delta runoff in the Bay Delta Water Management Plan.

Like an ostrich sticking its head in the sand, the delta tunnel DEIR’s attempt to simply ignore the fact that salmon and other native species need cleaner water flowing into the delta annihilates biological sciences. There is nothing to do.