CSPA files scoping comments on the EIR/EIS for the
Sacramento-San Joaquin Bay Delta Conservation Plan
By Jerry Neuburger
May 30, 2008. In comments sent to Ms. Barbara McDonnell,
Chief of the Division of Environmental Services
Department of Water Resources, CSPA's Executive
Director, Bill Jennings,
called the Habitat Conservation Plan (HCP) portion of
the Sacramento-San Joaquin Bay Delta Conservation Plan (BDCP),
"the most ambitious and far-reaching Habitat
Conversation Plan (HCP) ever envisioned coupled with a
massive scheme to change the hydrology of the Central
Valley."
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CSPA's
Bill Jennings |
However, Jennings, commenting for CSPA, found
numerous and fatal flaws in the plan as it is now
proposed. Among those are the inconsistencies of
protecting and restoring listed species and a conveyance
plan involving a massive public works project that will
change the hydrology of the estuary and tributary
waterways. Further, the plan guarantees water delivery
to the south state, a basic inconsistency with habitat
preservation. The plan does not consider recent court
rulings regarding the Endangered Species Act and does
not conform to the governor's Delta Vision statement.
Numerous other faults were found which lead Jennings to
conclude, "The plan is little more than a Bay-Delta
Conveyance Plan masquerading as an HCP."
A list of recommendations for revision were submitted
which include that the plan, "Incorporate a
comprehensive ecological analysis," to identify
targeted species, identify and evaluate alternative
water supplies and delivery systems, analyze and
quantify the Delta needs, and propose full mitigation
for "take" of species protected pursuant to
the California Endangered Species Act. A number of
additional recommendations were made regarding water
sources, flow and their effect on the delta and the
habitat of the creatures living there.
Summing up, Mr. Jennings stated, "The enormous
and unprecedented scope of the proposed scheme will
require the most ambitious and detailed environmental
document ever assembled."
The complete document may be found at: Scoping
Comments for the EIR/EIS for the Sacramento-San Joaquin
Bay Delta Conservation Plan