7/29/14: Draft Bay Delta Conservation Plan (BDCP) Would Devastate San Francisco Estuary, Central Valley Rivers, and Water Quality

SAN FRANCISCO, CA, July 29, 2014 Today, The Bay Institute released a comprehensive review of the draft Bay Delta Conservation Plan (BDCP) and its associated environmental documentation (draft Environmental Impact Statement and Environmental Impact Report). BDCP is a proposed Habitat Conservation Plan and Natural Community Conservation Plan that is billed as a means of restoring the Delta ecosystem, including its imperiled salmon, steelhead, and sturgeon populations, while also improving the reliability of water supplies for the water agencies in the San Joaquin Valley and southern California that export water through the giant state and federal water project pumps in the south Delta.  A key feature of the BDCP is a proposal to construct two extremely large tunnels under the Delta that would convey water from the Sacramento River directly to existing export pumping facilities.

To secure a 50 year operating permit, the BDCP must demonstrate that it will restore the health of the San Francisco Estuary and conserve the fish and wildlife in the Plan Area, maintain water quality conditions in the Delta and downstream, and comply with the requirements of a host of environmental laws, including the California Natural Community Conservation Planning Act, the state and federal Clean Water and Endangered Species Acts, the Delta Reform Act of 2009, and the Central Valley Project Improvement Act. The Bay Institute’s technical review, combined with a comprehensive legal review prepared by the Natural Resources Defense Council and Defenders of Wildlife, indicates that BDCP will not only fail to meet these requirements, but is very likely to exacerbate the crisis in the Delta.

“The Draft Plan’s own analyses indicate that numerous species would decline as a result of the BDCP’s proposed operations, and those analyses were overly optimistic,” said Dr. Jon Rosenfield, a conservation biologist at The Bay Institute and lead scientific author of the review. “Some species would probably be eliminated altogether, as a direct result of proposed actions under the BDCP. This is not simply a matter of continued decline in the ecosystem due to current, unsustainable rates of water export and impacts of invasive species–the proposed BDCP will actually make things worse than the status quo.

The analysis reveals that BDCP relies on two major assumptions that its own analysis and outside reviews do not support. First, it incorrectly assumes that habitat restoration activities (particularly restoring tidal marshes and re-vegetating the banks of sections of the Sacramento River and sloughs in the Delta) can replace the essential functions of fresh water flowing into, through, and out of the Delta.  As indicated by the wealth of agency and academic papers and reviews cited in the comments, the best available science indicates that this assumption is simply wrong: conservation and restoration of native fish and habitats will require increased flow of freshwater in critical seasons as well as targeted restoration of the Delta’s once-extensive marsh, riparian, and floodplain habitats. Despite the overwhelming number of well-documented benefits of improving freshwater flow conditions in the Delta and the state’s policy of reducing reliance on freshwater exports from the Delta, the Draft BDCP instead proposes to maintain or increase unsustainable water exports and decrease flows in ecologically critical sections of the Sacramento River and northern Delta.

Second, it incorrectly assumes that building a new water diversion on the Sacramento River will significantly reduce problems, like fish kills and massive habitat degradation caused by the existing pumps in the south Delta. But the south Delta pumps will continue to operate and cause significant impacts under the plan, and the proposed new diversion on Sacramento River will cause new impacts to salmon, steelhead, and sturgeon populations. Again the best available science shows that exporting massive volumes of water from the north Delta will create new impacts to water quality and habitats in the Delta in addition to ongoing direct losses of fish. The assumed benefits of building a new diversion facility with modern fish screens do not materialize unless they are associated with reducing the total amount of water diverted–an approach completely overlooked in the Draft Plan.

“The current BDCP proposal fails to back up its claims that giant tunnels and habitat restoration will be effective in recovering and maintaining healthy populations of native fish and wildlife species and the ecosystem that supports them,” said The Bay Institute’s program director Gary Bobker. “What California needs is a plan that combines improvements in flows and habitat for the Delta ecosystem with actions to develop alternative water supplies for areas that now rely on unsustainable Delta export pumping levels. We can do better.”

Weighing in at nearly 250 pages, the groups’ review found:
  • Winter-run Chinook salmon will probably be driven to extinction by operations of the new water diversion facility proposed by the BDCP.  Planned operations would also lead to poor spawning and rearing conditions for this species in its only known spawning locations, downstream of Shasta Dam.
  • Major negative impacts to spring-run, late-fall run, and the commercially valuable fall-run of Chinook salmon would occur in the Delta, particularly downstream of the proposed new water diversion facility, and upstream.
  • Both green and white sturgeon species would be exposed to dramatically degraded conditions, upstream, in the Delta, and in San Francisco Bay.
  • Water quality in the Delta would decline as a result of the BDCP, affecting local Delta farms and key rearing habitats for ducks, geese, and myriad shorebird species.
  • Impacts to San Francisco Bay from reduced Delta outflows and diminished productivity of key estuarine habitats were largely unanalyzed by the Plan and its draft EIS/EIR, and are likely to be significant.
These and numerous other likely impacts of the proposed BDCP to environmental conditions in the San Francisco Estuary and the Central Valley rivers that feed it represent major impacts to California’s commercial fishing fleet, the Delta’s people and environment, and the quality of life in northern California that annually attracts millions of visitors from all over the world.

About The Bay Institute
The Bay Institute is the leader in protecting, restoring and inspiring conservation of San Francisco Bay and its watershed — from the Sierra to the sea. For over 30 years, The Bay Institute has developed and led scientific research, habitat restoration, education, and advocacy programs to preserve California's most important natural resource. Learn more at www.thebayinstitute.org.
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Gary Bobker | 415 272 6616 | bobker@bay.org
Jon Rosenfield, Ph.D. | 510 684 4757 | rosenfield@bay.org