The twin water tunnels project Gov. Jerry Brown is touting is not a permissible project under the Endangered Species Act, says the environmental group Friends of the River.
In a letter to federal and state agencies trying to get approval for the Bay Delta Conservation Plan with the twin tunnels at its heart, the group says the 35-mile-long tunnels – each large enough to fly a small plane through, would not just drain water from the Sacramento River before it could flow into the Sacramento-San Joaquin Delta, they would threaten the existence of five species of fish that teeter on the brink of extinction.
The BDCP would adversely modify designated critical habitat for at least five endangered and threatened fish species, Friends of the River say.
“Extinction is forever. The fish face an extinction crisis,” the group says in its preliminary “comment letter” on the 40,000-plus page public draft Bay Delta Conservation Plan and public draft Environmental Impact Report/Environmental Impact Statement issued in December.
“The Water Tunnels would divert enormous quantities of water from the Sacramento River near Clarksburg,” the letter says, shipping it to the south for diversion to the Central Valley and State Water Projects.
“As a result of this massive diversion, enormous quantities of water that presently flow through the Sacramento River and sloughs to and through the Sacramento-San Joaquin Delta would not reach the Delta, and flows would be reduced in the Sacramento River and sloughs,” says the letter.
“Also, there would be adverse cumulative effects ranging from rising sea levels and reduced snowpack and runoff due to climate change to changes in upstream reservoir operations and current preservation of flows for fishery purposes all the way upstream to the Shasta, Trinity, Oroville, and Folsom reservoirs,” it says.
Friends of the River say despite the massive amount of paper in the draft proposals, the state has failed where it matters most: with the facts.
“The public and the decision-makers now have what they do not need: 40,000 pages of advocacy from the consultants including self-serving speculation that the adverse effects of reducing flows in the Sacramento River, sloughs, and Delta will be offset,” says the letter. “The public and the decision-makers do not have what they do need and are entitled to by law: the federal agency Biological Assessments and Biological Opinions required by the ESA and NEPA [National Environmental Policy Act\,” says the letter.