DISB Review of Bay Delta Conservation Plan/California WaterFix Partially Recirculated Draft EIR/EIS

We have reviewed the partially Recirculated Draft Environmental Impact Report/ Supplemental Draft Environmental Impact Statement for the Bay Delta Conservation Plan/California WaterFix (herein, “the Current Draft”). We focused on how fully and effectively it considers and communicates the scientific foundations for assessing the environmental impacts of water conveyance alternatives. The review is attached and is summarized below.

The Current Draft contains a wealth of information but lacks completeness and clarity in applying science to far-reaching policy decisions. It defers essential material to the Final EIR/EIS and retains a number of deficiencies from the Bay Delta Conservation Plan Draft EIR/EIS.

The missing content includes:

1. Details about the adaptive-management process, collaborative science, monitoring, and the resources that these efforts will require;
2. Due regard for several aspects of habitat restoration: landscape scale, timing, long-term monitoring, and the strategy of avoiding damage to existing wetlands;
3. Analyses of how levee failures would affect water operations and how the implemented project would affect the economics of levee maintenance;
4. Sufficient attention to linkages among species, landscapes, and management actions; effects of climate change on water resources; effects of the proposed project on San Joaquin Valley agriculture; and uncertainties and their consequences;
5. Informative summaries, in words, tables, and graphs, that compare the proposed alternatives and their principal environmental and economic impacts.

The effects of California WaterFix extend beyond water conveyance to habitat restoration and levee maintenance. These interdependent issues of statewide importance warrant an environmental impact assessment that is more complete, comprehensive, and comprehensible than the Current Draft.