Why NRDC Opposes the Bay Delta Conservation Plan

Today, in partnership with several conservation and fishing organizations, NRDC submitted extensive comments on the latest environmental analysis of the proposed Bay Delta Conservation Plan, which has been rebranded as the California WaterFix (this is the state's latest proposal to two construct two massive tunnels under the Delta, reducing flows through the largest estuary on the West Coast of the Americas). NRDC and our partners have been engaged in the BDCP process from the beginning, and we strongly supported the Delta Reform Act of 2009 which established the co-equal goals for the Delta and established state policy to reduce reliance on the Delta and invest in regional and local water supplies. Several years ago we requested that the agencies analyze a Portfolio Alternative in the CEQA/NEPA documents, which consisted of a new conveyance facility, new South of Delta storage, investments in local and regional water supplies, and operational rules to take less water from the estuary in order to protect fish and wildlife. They have refused to do so, and they were forced to admit that they inflated the costs of such an alternative.

We agree that the status quo in the Delta is unsustainable and that, in combination with climate change, existing operations of the state and federal water projects will jeopardize the continued existence of several fish species, threaten the livelihoods of the thousands fishing jobs that depend on healthy salmon runs, and lead to continued declines of the health of the Bay-Delta estuary, including the growth of toxic harmful algal blooms like Microcystis, which threaten human health and safety as well as the environment. During the current drought, state and federal agencies have waived the rules protecting fish and wildlife and water quality in the Delta, and failed to operate upstream reservoirs to protect salmon and other fisheries, driving species to the brink. Climate change is likely to make droughts more frequent and severe in the future, yet the lessons of the drought show that BDCP would actually worsen water supply and the environment: agencies would have to pay more than $1.2 billion in years like this when they get no more (and should get less) water from the Delta, yet for Delta farmers and fish and wildlife the willingness to waive the rules has destroyed any trust that a new facility would be operated according to the rules.

Yet instead of meaningfully addressing these threats and responding to the effects of climate change, the State's preferred alternative (Alternative 4A) largely ignores the effects of climate change and in many cases would make these problems worse than the status quo, for instance increasing the likelihood of harmful algal blooms in the Delta and San Francisco Bay, reducing salmon survival through the Delta, and leading to the likely extinction of several native fish species. Numerous scientific peer reviews have repeatedly confirmed that BDCP fails to use sound science.

Such an outcome is neither acceptable nor inevitable, and pretending that climate change won't affect the Delta won't make it go away. Instead, California must redouble our efforts to reduce reliance on the Delta and invest in local and regional water supplies, as State law requires. Spending tens of billions of dollars on Delta tunnels would harm fisheries and the environment, worsen water quality in the Delta, and divert much needed funding away from cost-effective investments in water recycling, improved agricultural and urban water use efficiency, groundwater cleanup, and stormwater capture. The 'fix' may be in, but the state's proposal only makes sense if you ignore climate change, science, and economics.