The Delta Conveyance Design and Construction Authority has completed the Engineering Product Reports for the Central and Eastern Corridor Options for the Delta tunnel, according to the February 2021 Board report. Deliverables included “engineering drawings, GIS mapbooks, and all associated technical memoranda (TMs).”  The DCA has also delivered draft documentation to DWR on the Bethany Reservoir alternative.  The information will be the basis of the conceptual engineering design for the project.

From January through August of 2020, the DCA published draft mapbooks of the Central and Eastern Corridor Options for input from the DCA’s Stakeholder Engagement Committee, and is currently publishing draft mapbooks for the Bethany Reservoir alternative.

The DCA is planning to do additional geotechnical exploration in support of the project in Spring of 2021, and is currently doing laboratory analyses of the samples obtained from the Fall 2020 geotechnical drilling, according to the February 2021 schedule. Settlement studies are also being conducted.

Delta Stakeholder Input

According to an August 26, 2020 presentation, the DCA has made the following changes to the project as a result of input from the DCA’s Stakeholder Engagement Committee:

  • Reduced site footprints throughout
  • Maximized reclamation of impacted agricultural land
  • Shifted facilities away from natural areas including Stone Lakes and Woodbridge Reserves
  • Eliminated barging and associated affects [sic] to recreational boating
  • Reduced traffic along Hwy 4 by eliminating structures
  • Reduced traffic along Byron Hwy by adding infrastructure and shifting material to rail
  • Reduced borrow requirements to reduce traffic loads
  • Added rail and expanded roads to maintain acceptable levels of service

However, some Stakeholder Engagement Committee members have been strongly critical of the DCA’s stakeholder engagement process. Karen Mann, the DCA’s South Delta Business Representative, sent a letter to the DCA in November 2020 requesting that the DCA “respond to the real issues”, including the following:

moving the intakes; disposing of the tunnel muck by hauling it to appropriate licensed disposal facilities instead of making up the name “reusable tunnel material” and dumping it on our farmland and islands […]; developing and considering a Natural Systems Alternative that would reduce the size of thekaren-mann-11.6-letter-to-mallon.pdf ( project and its intakes, reducing construction and operating impacts on Delta communities; requiring increased conservation by Water Contractors as a permit condition of any new point of diversion […]; recognizing that a primary function of the SWP is to repel salinity in the Delta and orienting the project to repel salinity in the Delta and enhance water quality in the Delta, rather than abandoning the south and central Delta to salt water […]

CEQA Alternatives

Environmental, tribal, fishing, and Delta organizations have proposed many alternatives in the CEQA scoping process, including “no tunnel” alternatives.

In a November 5, 2020 letter to the Delta County Supervisors, DWR Director Karla Nemeth, stated that a portfolio alternative would not be analyzed in the Delta tunnel EIR, stating:

While suggestions such as conservation, recycling and desalination are important elements addressed in the Water Resilience Portfolio—and a priority for many local water agencies—they would not address the fundamental project purpose to continue reliability of SWP water deliveries by protecting infrastructure from climate change and seismic threats. However, these alternative actions may be addressed by local water agencies in the absence of a Delta Conveyance Project. Therefore, DWR will include an evaluation of them as likely conditions if the project does not move forward. This “No Project” alternative will identify and analyze the effects of the additional actions that local water agencies may take under these conditions.

The Sierra Club et. al. have filed a Petition for a Writ of Mandate for DWR to rescind the resolution authorizing revenue bonds for the Delta tunnel project planning and construction, arguing that the Department of Water Resources has improperly foreclosed alternatives.

In July 2019, the Central Valley Flood Protection Board held one of many agency listening sessions on the Water Resilience Portfolio. I told the Flood Board, “For climate adaptation, the first priority for the state must be increasing resiliency of the existing built environment, and protecting vulnerable populations from catastrophic effects of climate change.” I described some of the investments the state needed to make in rehabilitating and upgrading the state’s aging dams and levees, and concluded, “Whether people are displaced in 2050, or whether they even survive, will depend on the investments we make now.”

In August 2019 I worked with a network of environmental groups to put the recommendation into a one page manifesto titled, “Principles for State Investment in Climate Adaptation,” which we submitted to the Secretary of Natural Resources. Later we found that the Office of Planning and Research’s Technical Advisory Council on Climate Adaptation had made similar recommendations in 2017.  They urged the state to

Prioritize actions that promote equity, foster community resilience, and protect the most vulnerable. Explicitly include communities that are disproportionately vulnerable to climate impacts.

But no one foresaw that one year later wildfires would burn 4 million acres in California, with hundreds of thousands displaced, and some who did not survive. Climate change is accelerating, and impacts that we thought we would see in mid-century are happening now.

It is clear from the Governor Newsom’s proposed 2021-22 budget that he grasps the urgency of the situation. The 2021-22 budget proposes billions in investments for climate mitigation and adaptation. Newsom proposes $1 billion to support the Forest Management Task Force’s Wildfire and Forest Resilience Action Plan, with investments in community hardening, wildfire fuel breaks, and resilient forests and landscapes.

There is also $183 million for flood management, including funding for the Delta Levees System Integrity Program, the American River Common Features Project, collaborative flood risk management, and emergency response in the Delta.

Funding for agriculture in the San Joaquin Valley prioritizes pro-adaptive approaches, such as “grants to support economic mitigation planning and groundwater implementation projects across critically over-drafted basins” and grants for the “incentives that help farmers reduce irrigation water use and reduce greenhouse gas emissions from agriculture pumping.”

Largely absent from the Governor’s budget are subsidies for unsustainable patterns of water use, which many powerful interests in the state have been seeking.

As California begins to make major investments in climate adaptation, this is a good start.

Posted by: Deirdre Des Jardins | December 8, 2020

CWR comments on MWD vote on funding for Delta tunnel planning

Deirdre Des Jardins, Director of California Water Research, provided these comments today to the Metropolitan Water District Board on their vote for funding for the next two years of Delta tunnel planning.

Southern California needs real solutions for climate change, not hype.  Unfortunately the only information provided for the MWD Board vote today is hype.

The preliminary benefits analysis provided to the MWD Board for this vote uses a value of 55 inches for “extreme” sea level rise.  This is the same obsolete value for extreme sea level rise used in the failed WaterFix project. Current estimates of extreme sea level rise are 2 meters to 10 feet by 2100.

The MWD Board needs to ensure that Best Available Science is used for all project approvals, including this one. The Board should request that the Delta Conveyance Design and Construction Authority analyze the performance of the proposed North Delta Intake locations with 2 meters to 10 feet of sea level rise, so that the Board can assess the risks of future salinity intrusion at the North Delta intakes.

Until this information is provided, there is no support for the assertion that this is a climate adaptation project.

For more information, see our written comments.

Posted by: Deirdre Des Jardins | November 2, 2020

“General Bond Resolution” could fund twin tunnels project in stages

Environmental groups have been strongly critical of the Department of Water Resources’ “blank check” Delta Program Revenue Bond / General Bond Resolution..  The General Bond Resolution is expected to fund Governor Newsom’s Delta tunnel project, which is currently estimated to cost $15.9 billion.

The State Water Contractors have countered that DWR is simply “validating its own authority to issue revenue bonds to raise funds.”

In reality DWR’s Delta Program General Bond Resolution goes far beyond a resolution for a single project.  It is a sweeping assertion of unlimited authority to issue bonds for an open-ended “Delta Program.”  The General Bond Resolution states

Delta Program means the environmental review, planning, engineering, design, and, if and when the Department determines to be appropriate, acquisition, construction, operation and maintenance of facilities for the conveyance of water in, about and through the Sacramento-San Joaquin Delta, subject to such further specification thereof as the Department in its discretion may adopt. Delta Program facilities may include, but are not limited to, water diversion intake structures located on the Sacramento River and a tunnel to convey water to Banks Pumping Plant.  (emphasis added.)

The Delta Program General Bond Resolution authorizes bonds to be issued for “phases” of the “Delta Program.” Governor Gavin Newsom’s two-intake, one tunnel project could be just the first “phase” of the “Delta Program.” Later phases could include a second tunnel and the other three intakes for DWR’s original five-intake, twin tunnel project.

Sacramento County’s response to the Validation Complaint explains how the General Bond Resolution goes far beyond the authorizing statute:

[DWR] is required pursuant to Water Code section 11701 to “prepare preliminary costs estimates, an estimate of the amount required to be raised for those purposes by the issuance of bonds, and statement of the probable amount of money, property, materials, or labor, if any, to be contributed from other sources in aid thereof,” and to “adopt a resolution . . . authorizing the issuance of bonds for the purpose of obtaining funds in an amount not in excess of that estimated to be required for those purposes.”  (emphasis added.)

DWR did not include any cost estimates in the General Bond Resolution, and is proposing to provide the cost estimates to the State Treasurer for each “phase” of the Delta Program in the future.

Delta Legacy Communities, Inc. argued in a separate response that “the Department’s assertion of the right to arbitrarily increase the amounts borrowed for a particular project appears to be contrary to the intent of Water Code section 11701 and is not in the public interest.”  Delta Legacy Communities further argued that “the Department’s attempted assumption of the right to issue unlimited bonds to build arbitrary, unspecified future facilities, is a de facto assumption of powers reserved to the legislature, and against the separation of powers in Article III, section 3 of the California Constitution.”

DWR is also proposing to assume the judicial power of review of compliance of the Delta Program with applicable laws, prior to issuance of the bonds.

DWR’s Validation Complaint for the Delta Program General Bond Resolution asks the court to “permanently enjoin and restrain all persons from the institution of any action or proceeding challenging, inter alia, the validity of the Resolution and … any subsequent Supplemental Resolution and the respective terms therein.”

Instead, DWR proposes to simply certify to the Treasurer that “all conditions precedent to the commencement of acquisition or construction of any Delta Program facilities…established by law have been satisfied.”

DWR did not publish the Delta Program General Bond Resolution before approving it, nor did the California Attorney General, Xavier Beccera provide any notice of DWR’s request to approve DWR’s assertion of powers by signing DWR’s Validation Complaint.  As a result, Northern California elected representatives, Delta stakeholders, Southern California ratepayers, and taxpayers had no opportunity to comment on DWR’s sweeping assertion of powers to issue unlimited bonds for the “Delta Program” without further judicial review.

Many Delta stakeholders have filed responses to DWR’s Complaint for Validation of the Delta Program General Bond Resolution, including Northern California elected representatives through a Delta / Northern Sierra County coalition filing, taxpayers through the Howard Jarvis Taxpayers’ Association, environmental, fishing, and tribal groups, Delta water agencies, Yuba City, and a community group advocating for Delta legacy communities. The responses can be found on Maven’s Notebook website.

This post was updated on November 3.


Posted by: Deirdre Des Jardins | October 12, 2020

Critical protections for endangered fish had little water cost, analysis shows

On the Sean Hannity show this week, Donald Trump told the audience,

California is gonna have to ration water. You wanna know why? Because they send millions of gallons of water out to sea, out to the Pacific … because they want to take care of certain little tiny fish, that aren’t doing very well without water, they have farms here and they don’t get water. It is so ridiculous they’re taking the water and shoving it out to sea.

But according to a 2020 fact sheet from The Bay Institute, the truth is that the 2010-2019 endangered species protections had relatively little water supply impact, much less than routine actions to protect water quality and maintain pumping infrastructure.  And the Trump administration gutted the ESA protections in December 2019.

The fact sheet states, “In 2019 scientists from the Bay Institute, the Nature Conservancy, and San Francisco Baykeeper analyzed Delta exports by the State Water Project (SWP) and Central Valley Project (CVP) and Bay inflow for the 2010-2018 water years.” Baykeeper “extended the analysis through the 2019 water year.”

The scientists’ analysis of the 2010-2019 water years showed that the previous Delta smelt protections limited exports on only 10% of days.  Since the export limits only kicked in when Delta inflows were low, the “water wasted to the sea” to protect Delta smelt was much lower — only 1% of total Central Valley runoff. Water “wasted to the sea” to protect salmon was only 2% of total Central Valley runoff.

The 2010-2019 endangered species protections kicked in at critical times for spawning and rearing of Delta smelt, and for outmigration of endangered winter and spring run Chinook salmon.  The Trump administration’s new rules eliminate all limits on the number of adult Delta Smelt that can be killed at the Delta pumps, and weaken or eliminate many protections for salmon.  The Natural Resources Defense Council called the new rules “A Plan for Extinction.”

Below are the graphs from The Bay Institute fact sheet, and their associated captions:

Limitations Governing Exports, 2010-2019: the percent of days that SWP and CVP exports in the Delta were governed by each limitation. “Water Quality Protections” consist of state regulations to protect water quality for a broad array of municipal, industrial, agricultural and environmental uses. “Endangered Salmon” consists of days when exports were limited in order to protect salmon or of days covering both salmon and smelt; “Endangered smelt” consists of days when exports were limited only for endangered smelt. “Capacity and Maintenance” consists of days when pumping was reduced due to maintenance, full canals or reservoirs, or low demand; the only reason export pumps were ever shut down completely were for capacity or maintenance reasons, not for fish and wildlife protection.

End use of 2010-2019 Central Valley Runoff: this pie chart shows percent of unimpaired runoff to San Francisco Bay from its Central Valley watershed. “Net Diversions”  consists of total diversions (Delta exports, in-Delta diversions, and diversions upstream of the Delta), minus water reuse, imports from other river basins, and releases from prior year storage. “Water Quality Protections” consist of state regulations to protect water quality for a broad array of municipal, industrial, agricultural and environmental uses. “Endangered Salmon/Smelt” consists of actions to restrict exports to prevent jeopardy to these species. “Uncapturable” consists of flows that exceeded the physical capacity of the SWP and CVP to pump, convey or store exports from the Delta; some of this water also helped to meet “Water Quality Protections” and “Endangered Smelt” needs.

(Reprinted with permission.)


Gregory J. Reis, Jeanette K. Howard, and Jonathan A. Rosenfield, 2019,  “Clarifying Effects of Environmental Protections on Freshwater Flows to—and Water Exports from—the San Francisco Bay Estuary,” San Francisco Estuary and Watershed Science 17-1: 1-22. Available at:

Posted by: Deirdre Des Jardins | July 28, 2020

Delta tunnel: DWR rejects consideration of No Tunnel alternatives in EIR

The Delta Conveyance Design and Construction Authority convened the 10th meeting of the Stakeholder Engagement Committee on Wednesday, July 22, 2020. Carrie Buckman, the Environmental Manager for the Department of Water Resources, gave a presentation on DWR’s screening of alternatives suggested in the scoping process.

Buckman summarized the Delta tunnel project objectives as follows:

  • CLIMATE RESILIENCY –Addresses climate change, extreme weather, and rising sea levels in the Delta for the SWP
  • SEISMIC RESILIENCY –Minimizes health/safety risk to public from earthquake-caused reductions in water delivery quality and quantity from the SWP
  • WATER SUPPLY RELIABILITY –Restores and protects ability to deliver SWP water in compliance with regulatory and contractual constraints
  • OPERATIONAL RESILIENCY –Provides SWP operational flexibility to improve aquatic conditions and manage risks of additional future constraints

Buckman described the No Tunnel and Through-Delta alternatives as including some combination of:

  • Increase water recycling and conservation efforts
  • Desalination facilities
  • Continued through-Delta conveyance (use of existing facilities) with improvement to Delta levees

Buckman then showed a slide which stated that the alternatives which continued to use through-Delta conveyance did not meet the project objectives of climate resiliency, seismic resiliency, and water supply reliability.

Through Delta

But the Department of Water Resources has not defined “climate resiliency” or “seismic resiliency,” so this assessment is qualitative.  And the single tunnel project that the Delta Conveyance Design and Construction Authority has been developing for the last year may not perform well with salinity intrusion from high sea level rise at 2100, as we pointed out last year.  There is no report of any analysis of the performance of the DCA’s selected intake locations with high sea level rise.

The single tunnel may also not be designed to withstand a maximum earthquake in the Delta.  DWR rescinded seismic engineering standards for the single tunnel project in June of 2019. The DCA has developed draft Conceptual Seismic Design and Geohazard Evaluation Criteria and submitted them to DWR, but has not disclosed the drafts to the Stakeholder Engagement Committee or the public.

Buckman also stated that DWR has rejected alternative local water supplies as not meeting fundamental objectives of “enabling the SWP to continue to function through challenges such as climate change, sea level rise, and earthquake risk.”

No tunnel

But local water supplies are the only supplies that are truly resilient to long term sea level rise, and may also be the only supplies that would continue to be available after a maximum earthquake in the Delta.

The Governor’s Water Resilience Portfolio should have considered the distinction between local water supply reliability and State Water Project delivery reliability, but the Water Portfolio relied on DWR’s definition of “sustainability” as reliability of Delta exports.

DWR’s exclusion of consideration of local water supplies is also contrary to the 2009 Delta Reform Act, according to scoping comments by the Natural Resources Defense Council et al NRDC et. al. commented that the “stated purpose of increased SWP water diversions from the Delta, without any investment in local and regional water supplies to reduce reliance on the Delta, is inconsistent with state law. The Delta Reform Act established state policy to reduce reliance on the Delta and to meet state water needs through investments in sustainable local and regional water supply projects, such as improved water use efficiency and water recycling. Cal. Water Code § 85022.”

This post was updated on July 28, 2020.


Posted by: Deirdre Des Jardins | July 20, 2020

Valley Water proposing to borrow $310 million on parcel tax revenues

On Tuesday, July 21, 2020, Valley Water (formerly Santa Clara Valley Water District) will consider a proposal to renew the Safe, Clean Water and Natural Flood Protection parcel tax.   The Safe, Clean Water parcel tax currently brings in about $46 million a year. The renewal will extend the parcel tax indefinitely so that the district can borrow $310 million against the Safe, Clean Water parcel tax revenue stream.

Valley Water had $506 million in revenue this fiscal year, due to reduced water sales, with $610 million in expenses.  Valley Water’s Board voted to cut $44 million from the FY 2020-21 budget and borrow $136 million against the district’s water sales revenues.   The district’s total indebtedness is currently about $979 million.

Valley Water FY 2020-21 outlays

The Safe, Clean Water and Natural Flood Protection parcel tax is the main source of funding for the district’s fish and wildlife habitat enhancement projects, but it also funds flood protection, pollution prevention, environmental education, and seismic remediation of Anderson Dam.  The April 2020 forecast for the Safe, Clean Water and Natural Flood Protection program projected a small deficit for the program starting in FY 2026, but the total was under $50M.

SCW program deficit

The Safe, Clean Water and Natural Flood Protection Program is overseen by an Independent Monitoring Committee (IMC.)   The IMC requested a status update on the program in February 2020, when staff indicated that a new resolution was needed because of a shortfall of funding for large capital projects.

The IMC is surprised that Valley Water states the need for more funding after only seven years of the fifteen year program. In the FY19 report, there is no indication that projects are underfunded or that KPIs will be unmet with projected funds. The IMC recommends the Valley Water clearly update status of SCW to citizens prior to a new funding proposal.

Valley Water declined to provide an update to the IMC on the SCW program’s financial status or projected deficits in project funding.

California Water Research joined South Bay environmental and fishing groups in a letter expressing concerns about the proposed parcel tax renewal. The letter states in part:

Given Valley Water’s expressed commitment to environmental stewardship, our groups are puzzled by the refusal to address our concerns that the proposed Safe, Clean Water and Natural Flood Protection (“SCW”) program renewal has significant reductions to funding commitments for habitat enhancement, compared to the existing SCW program. As explained by CalTrout in their July 14, 2020 comment letter

“Valley Water has a duty to enact the habitat enhancement measures listed in the Parcel Tax through California Fish and Game Codes and through State Water Board provisions and/or mitigation with District funds. The Parcel Tax provisions that support fish passage and habitat improvements are listed in wide-ranging categories that give Valley Water too much discretion to fund other projects in place of these required restoration activities.”

The budget projection for the second 15 years is even more alarming than the first 15 years – showing a reduction of 50% in commitments for Priority D, Restore Wildlife Habitat and Provide Open Space.

We are alarmed that Valley Water is proposing to issue $310 million in bonds on the SCW parcel tax revenues, with no list of projects that need borrowing for timely completion. Issuing 30 year bonds without any clear explanation of need is contrary to existing Board policy, which directs that debt shall only be issued when there is demonstrated need (Executive limitations section 4.7.2.)

The out-year impacts of immediately borrowing six years of parcel tax revenues on the SCW program will be severe. Funds available for capital projects in the second 15 years could be cut by up to two thirds. We are extremely disappointed to see no proposals to address the issues that the borrowing creates with long-term funding for habitat enhancement and other SCW priorities.

A majority of our groups are opposed to a resolution with no sunset date, and we believe a measure with no sunset date is unlikely to pass. For this reason, we are very disappointed to see no evaluation of an alternative with a sunset date.

We also continue to be concerned about the consolidation of $34 million in grants the existing SCW program dedicated to environmental stewardship, pollution prevention, and volunteer creek clean-ups to the single umbrella grant program in F9. No alternative has been offered to this consolidation of grant programs.

… We request that the Board address these issues and ensure that there will be sufficient funding for Valley Water to meet its duty to fund legally required habitat enhancement projects.

Posted by: Deirdre Des Jardins | July 7, 2020

MWD and Valley Water have yet to commit funds for Delta tunnel design

Metropolitan Water District has two seats on the Board of the Delta Conveyance Design and Construction Authority (DCA), and Valley Water (formerly Santa Clara Valley Water District) has one seat.  But to date, neither agency has committed to pay the DCA’s costs for the planning and engineering design for the single tunnel.

After the Department of Water Resources rescinded all approvals of the project on May 2, 2019, DWR gave the DCA a loan of $19.7 million, which allowed the DCA to continue engineering work on the project.

DCA xpenses

DCA FY 2019-20 income & expenses                             April 2020 Board packet

In August of 2019, three small desert water agencies (Santa Clarita, San Bernardino, and San Gorgonio) gave the DCA their share of the 2019/20 costs, which was $29.4 million.  The DCA’s plan was that the remaining State Water Contractors would give the DCA $101.6 million after approval of the Agreement in Principle for a Delta Conveyance amendment to the State Water Project Contracts. That did not happen, because the AIP negotiations were extended through April of 2020.  Although the DCA spent about a third of what was originally planned in FY 2019-20, the Department of Water Resources had to give the DCA a second loan of $9 million to pay expenses through the end of FY 2019-20.  There is no indication of how expenses will be paid in FY 2020-21.

DCA expenses June 2020

DCA FY 2019-20 income & expenses                            June 2020 Board packet

Although DWR has negotiated a Final Agreement in Principle with the State Water Project Contractors, the Tulare Lake Basin Water Storage District wrote Governor Newsom, requesting that the state not advance further funds to the DCA for the tunnel design.    The letter stated in part:

The most recently negotiated Agreement in Principle (AIP) for the SWP Delta Conveyance Contract Amendment was opposed by TLBWSD and at least one-third of the SWP Contractors… We do not want to participate in the DCF, and we object to DWR loaning our money to sustain the project. Given the State faces its harshest economic time in history, we ask that DCF funding by the State be placed on hold.

We asked Santa Clara Valley Water District to clarify when the District would pay for the District’s share of the DCA’s FY 2019-2020 expenses.  In response, Valley Water Board Chair Nai Hsueh stated,

Valley Water has been waiting for the Delta Conveyance facility project description to be better defined prior to making additional commitments.  We are careful about how we utilize the funds provided by our ratepayers and want a reasonable understanding of benefits, costs, and assurances before providing additional funding to the project.

We also asked when Valley Water would provide funding for Valley Water’s share of the DCA’s FY 2020-21 expenses?  In response, Chair Nai Hsueh stated,

After Valley Water has received additional information regarding benefits, costs, and assurances, Valley Water will bring a decision regarding additional funding for the project to its Board of Directors for consideration.  This may include both decisions regarding providing additional funding for DCA’s FY 2020-21 expenses as well as any reimbursement to DWR.

The Delta Reform Act of 2009 does require that the “persons or entities that contract to receive water from the Delta Conveyance” enter into contracts to pay for the “costs of the environmental review, planning, design, construction, and mitigation… required for the construction, operation, and maintenance of any new Delta water conveyance facility” prior to construction.

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Posted by: Deirdre Des Jardins | June 29, 2020

Delta tunnel: DWR plans for ESA consultation under Trump administration

On June 18, 2020, the Department of Water Resources submitted an application to the US Army Corps of Engineers for a Section 404 Clean Water Act permit for the Delta tunnel.

Getting federal permits for the Delta tunnel is complicated by Attorney General Becerra’s lawsuit over the Bureau of Reclamation’s new Long-Term Operations  for the Central Valley Project.  Reclamation has reportedly refused to be the lead agency for the Environmental Impact Statement for the Delta tunnel under the National Environmental Policy Act (NEPA.)  Instead, the US Army Corps of Engineers is expected to be the NEPA lead.

The US Army Corps of Engineers is also expected to be the lead agency for developing a Biological Assessment of the Delta tunnel project for evaluation of the project under the federal Endangered Species Act.

DWR’s Section 404 Application has the following timeline for obtaining permits (p 31.)

Other permits USACE Delta tunnel

Under ENDANGERED SPECIES (p. 31-31), the Department of Water Resources states that submittal of a BA (Biological Assessment),” is anticipated for late-2020:

The federal action agency will determine if its action may affect a listed species or critical habitat and develop a biological assessment (BA) consistent with this determination. If the action is likely to adversely affect the listed species or critical habitat, the federal action agency will request formal consultation with the Services (United States Fish and Wildlife Service and National Marine Fisheries Service) and this consultation will result in the Services’ issuance of biological opinions. It is anticipated the proposed Delta Conveyance Project will have effects on listed species requiring formal consultation.

DWR will work with USACE to define the scope of the Section 7 consultation process and development of the BA. Submittal of a BA is anticipated for late-2020. Informal coordination with the Services has begun and is ongoing.

The timeline in DWR’s Section 404 application is the same as the timeline reported to the Kern County Water Agency Board earlier this year:

KCWA Delta tunnel timeline

The Bureau of Reclamation’s Endangered Species Act consultation for the Long-Term Operations of the Central Valley Project was a source of outrage by environmental and fishing groups, who characterized the Biological Opinion as dismantling protections for endangered species.  It seems likely that an ESA consultation in 2020 for the Delta tunnel will also be highly controversial.

Posted by: Deirdre Des Jardins | June 22, 2020

Delta tunnel: US Army Corps application has new Eastern alignment

On Wednesday, June 17, 2020, the Department of Water Resources (DWR) submitted an application for a Section 404 Clean Water Act permit for the Delta tunnel to the US Army Corps of Engineers.  With the application, the Department of Water Resources submitted a map of the proposed project, which included the Eastern alignment for the main tunnel, and Intakes 3 and 5 (p. 37, shown below.)

USACE application map

In an accompanying announcement, the Department of Water Resources stated that the submission of the project map to the Army Corps of Engineers with the Section 404 application “is preliminary and should not be construed as a decision by DWR regarding its preferred project.” However, the evaluation of the project does represent a significant commitment of engineering resources, both by the US Army Corps and by the Department of Water Resources.

The selection of the Eastern alignment is a major change from the Central Delta alignment that has been studied for over a decade.  The change is likely driven by major logistical issues with construction of a tunnel and shafts through the Central Delta.

In December of 2019, an Independent Technical Review panel of engineers from five international tunneling companies found that the Central Corridor was logistically impractical.  The ITR panel’s report stated:

The shaft locations are located a significant distance from Interstate 5, accessible by only farm roads with hindrances such as narrow weight-restricted bridges and single lanes. This makes supporting large operations, which requires a constant transfer of materials and people in and out, impractical and expensive as well as difficult to price.

The panel further stated:

While it was recognized that extensive roadway, levee, and likely barge improvements could be constructed as part of the project for the Central Corridor… [t]he cost of improvements to provide reliable and safe access and egress at each site would exceed the cost of additional length of tunnel required for the East alignment.

One example of access issues was the construction of a tunnel shaft on Bouldin Island.  The tunnel shaft was originally planned to be 30 feet above sea level to ensure protection from 200 year floods plus sea level rise.  Since Bouldin Island is 18 feet below sea level, this would require construction of an enormous 48 foot high mound for the tunnel shaft pad.

Bouldin Island tunnel shaft

Simulated view of Bouldin Island Tunnel Shaft mound (closeup)    Source: DWR, 2018 WaterFix EIR

The Delta Conveyance Design and Construction Authority’s traffic analysis found that hauling the fill in to build the mound would require widening Highway 12 to four lanes, westbound from I-5.  A study for CALTRANS in 2006 found that widening Highway 12 to three lanes would cost over $77 million, which is over $98 million in 2020 dollars.  This was just one of extensive roadway improvements and barge landings that would be needed for the Central Delta route.

The change to the Eastern alignment has the added benefit of reducing impacts of the tunnel construction on boating and recreation in the Delta, as well as on historic Chinese and Japanese American districts in Locke and Walnut Grove.  The Eastern alignment also avoids constructing a tunnel shaft in the middle of some of the densest sandhill crane habitat on the west coast, which is shared with huge numbers of migratory waterfowl, with winter counts on Staten Island alone in the tens of thousands.

Sandhill Cranes small

Sandhill Cranes, Sacramento Delta      Source: Shutterstock   

Shifting the tunnel route to the east also significantly reduces the risks of tunnel boring. The Central Delta route tunneled under some of the most subsided islands in the Delta.  Delta Reclamation Districts and their engineers were very concerned about the risks of flooding if the tunneling compromised a levee.  They were also very concerned about the tunnel construction traffic compromising their ability to patrol levees during times of high water.

For these reasons, the selection of the Eastern alignment was greeted with celebration by the Discovery Bay based group, Save the California Delta Alliance.  However, the group did state that impacts of the Eastern alignment still need to be assessed.

The Delta Conveyance Design and Construction Authority’s traffic analysis did show unacceptable Levels of Service for traffic on Byron Highway during commute times for both the Eastern and Central tunnel alignments. The DCA is proposing to construct a new railroad spur adjacent to the Byron Highway to haul construction materials.  This would partially alleviate impacts on Byron Highway. Traffic on Highway 4 is projected to have small increases but to stay within acceptable levels of service.

Byron Highway Traffic

Eastern Alignment Traffic Analysis         Source:  DCA 5-27 presentation

The project is also expected to increase traffic on I-5 in Stockton by 1-4% during peak commute times.  The DCA’s traffic analysis projects that the Level of Service during peak commute times on I-5 will be unacceptable, but the congestion will be primarily due to pre-existing traffic.

I-5 traffic DCA

I-5 Traffic Analysis     Source:  DCA 5-27 presentation

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