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HomeMy WebLinkAbout11 APPROVE COMMENT LETTER ON THE DRAFT BAY DELTA CONSERVATION PLAN 01( Agenda Item 11 G .e, AGENDA REPORT Reviewed: a e City Manager GST1 Finance Director N/A MEETING DATE: JULY 15, 2014 TO: JEFFREY C. PARKER, CITY MANAGER FROM: DOUGLAS S. STACK, DIRECTOR OF PUBLIC WORKS/CITY ENGINEER SUBJECT: APPROVE COMMENT LETTER ON THE DRAFT BAY DELTA CONSERVATION PLAN SUMMARY The comment period on the Draft Bay Delta Conservation Plan will close on July 29, 2014. The Municipal Water District of Orange County, which the City is a member of, has requested member agencies consider submitting comments. RECOMMENDATION It is recommended that the City Council approve the attached Draft Bay Delta Conservation Plan Comment Letter and authorize the Mayor to sign the letter on behalf of the City. FISCAL IMPACT There is no fiscal impact associated with this item. CORRELATION TO STRATEGIC PLAN This agreement contributes to the fulfillment of Strategic Plan Goal D, which among other things is to work collaboratively with agencies on issues of mutual interest of concern. DISCUSSION The Sacramento-San Joaquin Delta is a critical link in the state's water supply system, and home to one of California's most important ecosystems. More than 25 million Californians and three million acres of farmland rely on water that moves through the Delta. Currently, this vital water supply is ushered through by 100-year-old, fragile levees that are vulnerable to collapse in the event of a major earthquake. If such an event were to occur, saltwater could contaminate freshwater in the Delta, and a critical source of water could be unavailable for a year or longer for two thirds of California's population. Orange County remains dependent on imported water to meet approximately 45 percent of its average annual demand, with the State Water Project (SWP) deliveries from the Delta meeting approximately half of those needs. The Delta ecosystem and water supply conveyance problems have long been recognized, and have remained in a continuing state of degradation, conflict, and stalemate. The Municipal Water District of Orange County (MWDOC) works as a resource planning agency for the majority of Orange County and has been the lead agency for review of the Draft BDCP. MWDOC has encouraged all member agencies to submit comments on the Draft BDCP to ensure a consistent message is delivered from the region. Draft BDCP Comment Letter . July 15, 2014 Page 2 Comments on the Draft BDCP are due on July 29, 2014. ►you• a• Stack, P.E. •ire t• Public Works/City Engineer Attachment: Draft Bay Delta Conservation Plan Comment Letter S:\City Council Items\2014 Council Items\07-15-2014\BDCP Letter\BDCP Comment Letter.docx Office of the City Council .Sr VY • e f July 15, 2014 tts' BDCP Comments Ryan Wulff, National Marine Fisheries Services 650 Capitol Mall, Suite 5-100 Sacramento, CA 95814 Dear Mr. Wulff: The City of Tustin is pleased to submit comments on the Draft Bay Delta Conservation Plan (BDCP), Draft Environmental Impact Report/Environmental Impact Statement (EIR/EIS) and Draft BDCP Implementing Agreement. The City of Tustin is a retail water supplier in Orange County that is governed by a publicly elected City Council. The City of Tustin Water Service provides potable drinking water to 70,000 residents through 14,150 service connections. Our supplies are a blend of groundwater provided by Orange County Water District and water imported from State Water Project and the Colorado River by the Municipal Water District of Orange County via the Metropolitan Water District of Southern California. Groundwater comes from natural underground aquifer that is replenished with water from the Santa Ana River, local rainfall and imported water. In spite of the world-class efforts of agencies in Orange County to provide greater water supply certainty for eight percent of California's population and the $200 billion economy they represent, Orange County remains dependent on imported water to meet approximately 45 percent of its average annual demand, with the State Water Project (SWP) deliveries from the Delta meeting approximately half of those needs. The Delta ecosystem and water supply conveyance problems have long been recognized, and have remained in a continuing state of degradation, conflict, and stalemate. Many years and hundreds of millions of dollars have been spent on study efforts while the delta system continues to be used for water conveyance in a manner for which it was not intended. The longer it takes to implement the resolution, the more expensive it will become. This stalemate has been punctuated by droughts, floods, economic losses, environmental degradation and litigation every decade since the construction of the SWP in the 1960's. We can no longer delay action Mayor Al Murray • Mayor Pro Tern Charles E. "Chuck" Puckett • John Nielsen • Rebecca "Beckie" Gomez • Allan Bernstein 300 Centennial Way, Tustin, CA 92780 • (714) 573-3010 • www.tustinca.org Bay Delta Conservation Plan Comments July 15, 2014 Page 2 of 4 in the Delta, and urge the State and federal government to quickly move forward with the Preferred Alternative. Failing to act and move forward is not an acceptable alternative. In recent years the endangered species biological opinions for protection of Delta and Longfin Smelt and Chinook Salmon have resulted in massive cutbacks in exports by over 1.5 million acre-feet per year and without the BDCP further cuts of another 1.0 million acre-feet per year could occur with new endangered species listings according to the BDCP briefing documents. This situation is untenable and a solution must be found to stop this hemorrhaging of this critical foundational water supply to southern California. The BDCP is the best hope we have and it must be approved and implemented in a timely and cost-effective manner. We offer the following specific comments on the BDCP: 1. We strongly support the BDCP Preferred Alternative (No. 4) and oppose the No Action Alternative: It is critical to the state's economy and environment that both the State and federal government expeditiously follow through with the decision for adopting and implementing the BDCP. 2. Co-Equal Goals: The BDCP must be implemented in a manner consistent with the co-equal goals adopted by the State. Preferred Alternative (No. 4) is consistent with the Delta Reform Act of 2009's co-equal goals. 3. New Facilities and In-Delta Operational Flexibility: The modernization of the Delta conveyance system is essential in order for habitat restoration and conservation to have its intended effect; Preferred Alternative (No. 4), which incorporates the 9,000 cubic feet per second (cfs) three intake, twin tunnel conveyance system, provides the best balance between operational flexibility and modernizing the conveyance system for environmental benefit and water supply reliability. 4. Reduced Future Reliance: The 2009 Delta legislation called for water agencies to reduce future reliance on the Delta, not to become 100 percent "self-reliant". While our major efforts in these areas will continue, it is important to note that "reduced reliance" does not equate to and was never intended to require a move to 100 percent "self-reliance" and the notion of co-equal goals was never intended to result in a future with significant reduction in exports from levels achieved before the 2008 bio- opinions. 5. Plan Implementation and Regulatory Assurance: The BDCP must provide the needed implementation and regulatory structure and assurances to help achieve the co-equal goals. Bay Delta Conservation Plan Comments July 15, 2014 Page 3 of 4 a. To us, this means that it is virtually impossible to predict the outcome of the BDCP habitat restoration efforts and endangered species population dynamics, and such a standard should not be required in the DEIR/DEIS. b. Furthermore, this means that changed circumstances under the operation of the BDCP, including the potential for new species listing, be incorporated in such a manner to result in a minimum impact on future water supply exports. 6. Sound Science: It is critical that sound science is provided in order to assure the long-term success of the BDCP. We strongly support the inclusion of independent scientific investigation and research to be included in the BDCP process. 7. Cost Allocation: We support the "beneficiary pays principle" in cost allocation for all responsible parties and beneficiaries. 8. Implementing Agreement: The Implementing Agreement is a contractual, legally-binding agreement that spells out the commitments and assurances as well as the terms and conditions for on-going implementation of the BDCP. Clarity in this agreement is essential as well as the balance in implementation of the co-equal goals. 9. Economy, Environment and Water Management: The State Water Project (SWP) is critically important to the Orange County economy, environment and water management. Implementation of the BDCP is critical to Orange County's future. a. Orange County and our agency have invested heavily to diversify our water portfolio but the SWP remains a critical source of low salinity water supply that is currently unacceptably jeopardized by the lack of sustainability of the current Bay-Delta system. b. Orange County relies on the SWP to support groundwater conjunctive use programs and water recycling programs - it is an essential part of our water reliability strategy that sustains our citizens and businesses. c. We support the 9,000 cfs twin tunnel Preferred Alternative (No. 4) provided reasonable assurances are included regarding governance and future decision-making in the process. We strongly advocate for a seat at the table for the water Permittees in the various oversight groups. The investment and decision-making Bay Delta Conservation Plan Comments July 15, 2014 Page 4 of 4 must be structured to achieve a positive outcome for both the SWP and Permittees and the ecosystem restoration in a collaborative, partnership manner. It is now time for the State and Federal government to adopt and move the BDCP to implementation in order to achieve the 2009 legislation's co-equal goals of improving water supply reliability and ecosystem restoration and improved function by implementing the BDCP Preferred Alternative (4). Thank you for your time and consideration of these comments. Sincerely, Elwyn A. Murray Mayor