Darian
06-20-2014, 08:56 AM
In it's present form, the BDCP and related documents have experienced changes and evolved into a massive 40,000 page set of documents. DWR claims to have made changes and added info in response to many of the comments received from all sources. I'm no longer trying to read all of this stuff as I'd like to get on with life. At this point, it's apparent that the BDCP has momentum and will become reality unless someone or agency steps in to stop it. I'm not holding my breath waiting for that to happen. Perhaps CSPA and/or other NGO's will be successful litigating a satisfactory outcome.
I've taken some time to review the Implementing Agreement (IA) and find it vague in parts and worrisome in others. One example of concern is issuance of "take Permits" to SWP/CVP water contractors. These permits will have a duration of 50 years, same as the length of the project. Try as I might, I can't see a reason to take that action. The only purpose I can imagine is that the permits will somehow provide the contractors with some immunity from being held accountable for their actions.... :confused: At any rate, following are some summarized observations:
In order to make the project more acceptable and more easily managed, the BDCP should be divided into two distinct and separate projects. One would be construction of conveyance facilities and the other completion of large scale eco-system restoration.
The two goals are at conflicting purposes with competing, differing priorities. In my opinion, combining the co-equal goals in the BDCP made a complex project even more difficult to understand and administer.
The list of alternatives analyzed in the BDCP EIR/EIS doesn’t include any alternatives other than those suggested by the state and/or the SWP/CVP water contractors. listing several alternatives that represent variations of the same alternative for evaluation does not amount to consideration of real alternatives.
Real property for this project is to be acquired by the state (overall footprint 67,000 plus acres). Thus, reducing or eliminating agricultural/ranching activities that occur within the project footprint now.
An agreement to reimburse county governments in the project area for revenues lost due to real property converted for BDCP activities for 50 years is un-acceptable and may be a violation of provisions of Prop 13(1979).
Funding for BDCP activities is not yet secured.
In accord with the principle of beneficiary pays, repayment costs for bonded indebtedness should be evidenced by a written promise to pay secured with the assets of SWP/CVP water contractors since they will be the major beneficiaries of the increased water diversions.
There is no guarantee that planned environmental restoration activities will be completed.
Uncertainty involving funding of Delta restoration and other project activities is due mainly to the need for approval of three or more proposed issuances of bonds, each requiring approval by a vote of the public.
Operations of SWP/CVP conveyance facilities in addition to other upstream diversions will contribute to reducing the amount of fresh water flowing through the Delta.
Releases for diversion under BDCP, eco-system health and/or controlling saltwater intrusion tends to reduce the amount of water stored in reservoirs upstream of the Delta, annually. All of this amounts to conveniently providing justification to construct additional storage (reservoirs).
Although there's a provision for funding collection/treatment of urban storm water run-off, there is no mention of providing support for collection and treatment of run-off from agricultural and/or industrial activities.
Of course, all of this is just my opinion. There's a lot more to comment on than I have. So, I'm gonna get back to fishing and let the NGO's do the heavy lifting....
I've taken some time to review the Implementing Agreement (IA) and find it vague in parts and worrisome in others. One example of concern is issuance of "take Permits" to SWP/CVP water contractors. These permits will have a duration of 50 years, same as the length of the project. Try as I might, I can't see a reason to take that action. The only purpose I can imagine is that the permits will somehow provide the contractors with some immunity from being held accountable for their actions.... :confused: At any rate, following are some summarized observations:
In order to make the project more acceptable and more easily managed, the BDCP should be divided into two distinct and separate projects. One would be construction of conveyance facilities and the other completion of large scale eco-system restoration.
The two goals are at conflicting purposes with competing, differing priorities. In my opinion, combining the co-equal goals in the BDCP made a complex project even more difficult to understand and administer.
The list of alternatives analyzed in the BDCP EIR/EIS doesn’t include any alternatives other than those suggested by the state and/or the SWP/CVP water contractors. listing several alternatives that represent variations of the same alternative for evaluation does not amount to consideration of real alternatives.
Real property for this project is to be acquired by the state (overall footprint 67,000 plus acres). Thus, reducing or eliminating agricultural/ranching activities that occur within the project footprint now.
An agreement to reimburse county governments in the project area for revenues lost due to real property converted for BDCP activities for 50 years is un-acceptable and may be a violation of provisions of Prop 13(1979).
Funding for BDCP activities is not yet secured.
In accord with the principle of beneficiary pays, repayment costs for bonded indebtedness should be evidenced by a written promise to pay secured with the assets of SWP/CVP water contractors since they will be the major beneficiaries of the increased water diversions.
There is no guarantee that planned environmental restoration activities will be completed.
Uncertainty involving funding of Delta restoration and other project activities is due mainly to the need for approval of three or more proposed issuances of bonds, each requiring approval by a vote of the public.
Operations of SWP/CVP conveyance facilities in addition to other upstream diversions will contribute to reducing the amount of fresh water flowing through the Delta.
Releases for diversion under BDCP, eco-system health and/or controlling saltwater intrusion tends to reduce the amount of water stored in reservoirs upstream of the Delta, annually. All of this amounts to conveniently providing justification to construct additional storage (reservoirs).
Although there's a provision for funding collection/treatment of urban storm water run-off, there is no mention of providing support for collection and treatment of run-off from agricultural and/or industrial activities.
Of course, all of this is just my opinion. There's a lot more to comment on than I have. So, I'm gonna get back to fishing and let the NGO's do the heavy lifting....