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Environmental Water Caucus requests extension of BDCP comment period
by Dan Bacher
Friday Dec 20th, 2013 9:30 AM
"Moreover, individual members of the public attempting to comprehend and comment on the BDCP documents would be overwhelmed. It is worthwhile noting that these documents represent 20% more pages than the 32 volumes of the last printed edition of the Encyclopedia Britannica," said Di Croce.

Environmental Water Caucus requests extension of BDCP comment period

by Dan Bacher

The Environmental Water Caucus on December 19 sent a letter to federal and state authorities asking for an 120 day extension in the public review and comment period for the Bay Delta Conservation Plan Draft Plan and EIR and EIS, noting that the 40,214 actual pages of the document represent 20% more pages than the 32 volumes of the last printed edition of the Encyclopedia Britannica.

"You may recall that in a November 21 letter to you, prior to the December 13 release of the BDCP Draft Plan and EIR/EIS, we requested that the public review and comment period be extended beyond the planned 120 days, based on the anticipated 25,000 page estimate of the BDCP documents," wrote Nick Di Croce, Co-Facilitator of the Environmental Water Caucus.

"We have now determined that there are 40,214 actual pages of the released documents and we request that you extend the public review and comment period for at least 120 additional days, due to the extraordinary size of the documents to be reviewed," he stated.

"Based on the dictated 120 day review time period, the public is being asked to review 473 pages of technical and scientific material per day during the 85 working days that are available during the public review and comment period. Additional time would be required to understand, research, and prepare comments on the voluminous documents," said Di Croce.

He pointed out that the BDCP web site provides instructions that: “Comments should identify the specific part of the document at issue and should include supporting evidence and facts.”

He also noted that NEPA regulation 40 CFR 1502.7 declares that the text of an EIS for “proposals of unusual scope or complexity shall normally be less than 300 pages.”

"As we also stated in that previous letter, it is impossible for organizations interested in thoughtfully responding to these BDCP documents to be staffed for a thorough NEPA/CEQA review based on the outlandish size of the documents to be reviewed," said Di Croce.

"Moreover, individual members of the public attempting to comprehend and comment on the BDCP documents would be overwhelmed. It is worthwhile noting that these documents represent 20% more pages than the 32 volumes of the last printed edition of the Encyclopedia Britannica," he stated.

Di Croce, representing the EWC and its 33 grassroots members, requested that the public review and comment period be extended for an additional 120 days, until August 15, 2014, based on the size of the actual documents they released on December 13.

"Without such additional time, the public’s essential role in the NEPA process of commenting on the agencies’ findings contained in the BDCP’s environmental review documents will be severely constrained," he concluded.

For more information about the EWC and its Responsible Exports Plan, an alternative to the Bay Delta Conservation Plan to build the peripheral tunnels, go to: http://www.ewccalifornia.org

The widely-criticized Bay Delta Conservation Plan proposes to construct three new intakes in the north Delta along the Sacramento River about 35 miles north of the existing South Delta pumping plants. Two 35-mile long twin tunnels would carry the water underground to the existing pumping plants that feed canals sttetching hundreds of miles to the south and west.

The release of the plan's documents takes place at a time when the enormous cost of the BDCP is coming under increasing scrutiny by water agencies, water ratepayers and the taxpayers who will pay for the tunnels. A total of $240 million has already been spent on the Bay Delta Conservation Plan - and it will take another $1.2 billion to complete the planning for the government boondoggle.

"The giant Delta water-diversion tunnels proposed by Gov. Jerry Brown need $1.2 billion more spent on planning and design before construction starts or is even assured," according to a report by Matt Weiser in the Sacramento Bee on December 7. (http://www.sacbee.com/2013/12/07/5978184/delta-water-tunnel-project-needs.html#storylink=cpy)

Scientists and tunnel opponents fear that the construction of the twin tunnels will hasten the extinction of Sacramento River Chinook salmon, Central Valley steelhead, Delta and longfin smelt, green sturgeon and other fish species, as well as threaten the salmon and steehead populations of the Trinity and Klamath rivers.

The Environmental Water Caucus includes the following organizations, Tribes and businesses:

AquAlliance
Butte Environmental Council
California Coastkeeper Alliance
California Save Our Streams Council
California Sportfishing Protection Alliance
California Rural Legal Assistance Foundation
California Striped Bass Association
California Water Impact Network
Center for Biological Diversity
Clean Water Action
Citizens Water Watch
Desal Response Group
Endangered Species Coalition
Environmental Justice Coalition for Water
Environmental Protection Information Center
Earth Law Center
Fish Sniffer Magazine
Food & Water Watch
Foothill Conservancy
Friends of the River
Institute for Fisheries Resources
The Karuk Tribe
Klamath Riverkeeper
Lower Sherman Is. Duck Hunters Association
Northern California Council, Federation of Fly Fishers
Pacific Coast Federation of Fishermen's Associations
Planning & Conservation League
Restore the Delta
Sacramento River Preservation Trust
Santa Clarita Organization for Planning & Environment
Sierra Club California
Sierra Nevada Alliance
Southern California Watershed Alliance
Winnemem Wintu Tribe