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HomeMy WebLinkAboutMINUTES - 07221997 - C79 Contra :.� TO: BOARD OF SUPERVISORS Costa.•;,,, FROM: WATER COMMITTEE County SUPERVISOR GAYLE B. UILKEMA, CHAIR SUPERVISOR JOE CANCIAMILLA DATE: July 22, 1997 SUBJECT: REPORT FROM WATER COMMITTEE ON DELTA WETLANDS PROJECT SPECIFIC REQUEST(S) OR RECOMMENDATION(S) & BACKGROUND AND JUSTIFICATION RECOMMENDATIONS AUTHORIZE Chair to sign a letter to the State Water Resources Control Board expressing concern with the potential impacts of the proposed Delta Wetlands Project. FINANCIAL IMPACT None. BACKGROUND / REASONS FOR RECOMMENDATIONS The Delta Wetlands Project proposes to convert two Delta islands to full-time reservoirs (Webb Tract, in Contra Costa County,and Bacon Island)and two Delta islands to wetlands/wildlife management areas (Holland Tract, in Contra Costa County,and Bouldin Island). Project proponents propose filling the two reservoir islands during times of above-average outflow in the Delta and discharging during periods of lower outflow. Discharged water would be available for purchase by willing buyers. CONTINUED ON ATTACHMENT: X YES SIGNATURE: _ RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE APPROVE OTHER SIGNATURE(S): S ervisor Gayl . Uilkema, Chair S ervis Joe Canciamilla ACTION OF BOARD ON JuiV 22, 1991 APPROV66 AS RECOMMENDED X OTHER VOTE-OF SUPERVISORS X UNANIMOUS (ABSENT I HEREBY CERTIFY THAT THIS IS A TRUE AYES: NOES: AND CORRECT COPY OF AN ACTION ABSENT: ABSTAIN: TAKEN AND ENTERED ON THE MINUTES OF THE BOARD OF SUPERVISORS ON THE DATE SHOWN. Contact: Roberta Goulart (510) 335-1226 cc: Community Development Department ATTESTED July 22, 1997 County Administrator PHIL BATCHELOR, CLERK OF THE BOARD OF SUPERVISORS AND CO NTY ADMINISTRATOR BY: , DEPUTY RG:jk H:\\cdadpool\jkopc\john-old\dwswrbj7.bo F� C,79 Board Order Water Committee Report on Delta Wetland Project July 22, 1997 - Page 2 - BACKGROUND / REASONS FOR RECOMMENDATIONS (CON'D) The Contra Costa County Water Agency filed a water rights protest against the Delta Wetlands Project in 1988 when the project consisted of four seasonally flooded islands. The project has changed considerably since then,and the protest is no longer active. However,the Contra Costa Water District has studied and modeled the proposed project extensively, and has a raised a number of specific concerns. The Contra Costa County Board of Supervisors has authorized this letter to urge that any decision to grant water rights to the Delta Wetlands Project ensure that the drinking water supply of County residents is fully protected and that the fish and other aquatic resources of the Delta are maintained. Current plans for operating the Delta Wetlands Project provide no assurance that the drinking water supply of County residents will be protected or that fish and other aquatic resources will be maintained. Potential negative impacts include the following: • Delta Wetlands diversions could aggravate the salinity intrusion problem in the Delta at some times of the year, degrading drinking water quality for hundreds of thousands of County residents and harming fish. • The X2 salinity requirement for the Delta Wetlands Project under the federal biological-opinion is less restrictive than the salinity requirement for the Los Vaqueros Reservoir diversions, even though the Los Vaqueros water right would be more senior. As a result, operation of the Delta Wetlands Project could limit or even prevent diversions to Los Vaqueros at times when such diversions would otherwise be allowed. • Releases of water from the Delta Wetlands Project could harm water quality for municipal drinking water and fish by leaching excess amounts of organic carbons from the peat soils, by concentrating salts via evaporation, and by increasing water temperatures. • The timing of Delta Wetlands operations could create problems by diverting water during periods of low water quality and releasing this stored water when water quality in the Delta is relatively better. The Water Committee recommends that the Board of Supervisors send a letter to the State Water Resources Control Board expressing concern overthese potential impacts and urging protection for County interests. The State Water Resources Control Board should address these negative impacts by including protections for drinking water and fish in any water rights permit that is issued for this project. Specifically,the County could recommend that any permit be linked to: 1) an X2 requirement for diversions that is more stringent than that for the Los Vaqueros Project; 2) a prohibition on Delta Wetlands discharges when water quality in the project is lower than that in the Delta; and 3) a general condition that the Delta Wetlands Project will not harm Contra Costa Water District or any other water diverter in the County with more senior water rights. Attachments: • Background on the project provided by Delta Wetlands • Delta Wetlands materials provided by Dr. Richard Denton, Contra Costa Water District • Draft of letter from Chair to the State Water Resources Control Board RG:jk H:\\cdadpool\jkopc\john-old\dwswrbj7.bo 5102834028 DELTA WETLANDS 644 P03 JUN 30 197 11:53 D b; L 7' A W i; I' !. A N L) 5 i i i BACKGROUND INFORMATION THE DELTA WETLANDS RESERVOIR AND WILDLIFE HABITAT Despite the record rains of last winter, California still faces a water crisis that refuses to go away. Unless we find some hard aruivers to this crisis in the next few years, both our population and our � economy will suffer. The problem, however, is the delculty of finding water supply solutions that are sensitive to environmental considerations and have the flexibility to dovetail with other water projects,present and future. The Delta TYetlands Project, described in this background paper; is such a solution. It is already 10 years in the planningphase and is nearing the end q an exhaustive environmental study that has found most of its environmental impacts 'less than significant" and many of them actually "beneficial." Very few impacts were without suitable mitigation measures. Beyond that, this is a major water project that can actually be brought online within two years after final approval, an unprecedented short turnaround. In the following pages, the Delta rYetlands Project is described in its scope and details, !f you have any questions,please feel free to contact us. Thank you for your interest. I Background Delta Wetlands (DW) is a private joint venture formed to create a unique water supply and environmental enhancement project in the Bay-Delta estuary. The project involves the diversion and storage of water on two Delta islands, Bacon Island and Webb Tract (reservoir islands), and the seasonal diversion and use of water for wetlands and wildlife habitat management on two other Delta islands, Bouldin Island and Holland Tract(habitat islands), Currently, the islands are used almost exclusively for agriculture. To operate its proposed project,DW will improve and strengthen levees on all four islands, install additional siphons and water pumps on the reservoir islands, and convert nearly 9,000 acres on the habitat islands to a mosaic of wetland and wildlife habitat types. The DW Project,therefore, serves two important public policy objectives. First, it expands water supply capacity in California in an environmentally sound manner. Second, it enhances wildlife habitat for numerous species and promotes an ecosystem-based approach for creating wetlands and conserving wildlife in the Bay- Delta estuary region. The project is now undergoing rigorous environmental review at state and federal levels to obtain the necessary authorizations to complete construction and begin operation. 31,97 Mt.Diablo Blvd. Stile 1011 ImAlyetla,CA A11540 tel 5 10 283.4216 fax 510.WAOUS 5102834028 DELTA WETLANDS 644 PO4 JUN 30 197 11:54 Background Information The Delta Wetlands Project Page 2 Reservoir Island Design and Operations The reservoir island design requires the conversion of Bacon Island and Webb Tract,approximately 11,000 acres,into water storage facilities. These islands will be operated as extremely flexible in- Delta reservoirs. The ability of the reservoir islands to fill or drain in less than a month allows the project the flexibility to capture a short-term freshet passing through the Delta or to discharge stored water for short-term water demand opportunities. The existing reservoir levees will be reinforced and the interior levee surfaces will be armored with rock revetixnent to prevent wave erosion when the reservoirs are full, Each reservoir island will have two separate siphon stations with sixteen 36-inch siphons at each location. There will be a single discharge pumping station on each island, employing 32 pumps on Webb Tract and 40 pumps on Bacon Island. The total combined storage capacity of the project is 238,000 acre-feet. The project is generally filled during wetter periods and emptied during drier periods. However,during more moderate water years,the Delta is often subject to multiple periods of high and low flow conditions and the reservoir islands are able to fill and drain more than once. During extremely wet years,the project will clearly be in a position to fill,but bccausc export demand is lower and supplies are plentiful,there may be little opportunity to discharge DW water for export. Water remaining on a reservoir island at the end of a water year will be carried over as storage for the next year. During extremely dry years,the Delta might remain in a "balanced" condition for all of the year and the project will have no opportunity to collect water for storage. DW reservoirs are unlike conventional reservoirs in that they are designed to drain completely. The reservoir islands will empty in most years,except for carryover storage in extremely wet years. This unused reservoir capacity can be made available to facilitate future water transfers and banking transactions. Water available for transfer during periods of traditional high export, when the state and federal pumps are operating at their maximum capacity,can be"parked"in DW reservoirs until later in the year when export is possible. The DW project is ideally suited to help fine-tune the operations of both the Central Valley Project (CVP) and the State Water Project (SWP) because the reservoir islands are the most downstream freshwater storage facility in the estuary and are still at a location very close to the export pumps. They are able to catch freshwater flows unavailable to other upstream storage facilities. Yet DW water can still be exported from the Delta and made available to two-thirds of California's population. 5102834028 DELTA WETLANDS 644 P05 JUN 30 197 11:54 Background Information The Delta Wetlands Project Page 3 Habitat Island Design and Operations The habitat island design requires the development of a mosaic of wetland and wildlife habitat types on Holland Tract and Bouldin Island, Working in conjunction with state and federal fish and wildlife agencies,as well as environinental organizations, DW developed a comprehensive habitat management plan (HMP) to construct and manage the two habitat islands. The plan creates approximately 9,000 acres (6,000 acres on Bouldin Island and 3,000 acres on Holland Tract) of dedicated habitat for waterfowl and other wetland-dependent wildlife species. The HMP has been designed to suit the needs of certain representative waterfowl species, including tundra swans and white-fronted geese, and specific listed species, such as Swainson's hawks and greater sandhill cranes. In addition,the plan benefits a wide range of wildlife species including 24 species of special concern, such as the federally protected bald eagle and the giant garter snake. The habitat islands will be managed year-round to meet habitat goals and objectives. The habitat areas will include a broad range of habitat types,such as herbaceous uplands,modified agriculture, riparian habitats, emergent marsh and permanent water. The habitat plan has also included flexibility to allow for future modification for unseen problems or opportunities. The existing habitat island levees will be reinforced for additional levee stability and secutity during high water and storm conditions. The levees will be raised and widened to meet,at a minimum,the state recommended levee standards. New land management practices will reduce land subsidence and improve long-term levee stability, Project Benefits • Significant Increase in California's Water Supply At a time when demand for water in California is growing, new water quality regulations and environmental requirements are actually shrinking the state's water supply. The DW Project can produce an average of 170,000 acre-feet of new water each year. The project can be brought online quickly, .DW could produce now water within two years of receiving the necessary permits and approvals. • Compatibility with Other Existing and Planned Water Projects The DW Project is a very compatible new water project. It works well with existing water projects and even new water projects still in the planning stage. Its compatibility is primarily a result of location mid operational flexibility, 5102834028 DELTA WETLANDS 644 P06 JUN 30 197 11:54 Background Information The Delta Wetlands Project Page 4 • Levee Stability The existing levees on both the reservoir and habitat islands will be reinforced by increasing their width and height. The improved levee stability on the four prof ect islands reduces the likelihood of a levee breach during high water and storm conditions or strong seismic events that might threaten the area. These improvements benefit the entire Delta. Long-term levee stability is also increased by reduced land subsidence resulting from new land management practices. * Water Quality Water quality is a key issue to the DW Project bccauwe of its centralized location within the Delta. The primary water quality concerns include saluiity and dissolved organic carbon(DOC)production, a precursor to the disinfectant by-product trliholoix than (THM). The reservoir islands are filled during periods of high inflows and relatively low salinity levels. The water is then discharged for export during periods of lower inflows and generally higher salinity. The result is a slight iYnproveraent in average salinity and bromide conditions at the major export locations of the Delta. Operations on both the reservoir and habitat islands will reduce DOC production. The major source of DOC is the oxidation.of the peat soils. Maintaining the soils in a wet or moist condition reduces oxidation,and,consequently,DOC production. A second source of DOC is from the decornpos;tion of vogetative material (biomass). Reservoirs and wetland habitats combined will produce less biomass than traditional agricultural activities. Adaptive management procedures will be implemented to ensure that negative impacts will be avoided. • Wetland and Wildlife Benefits The DW Project will create significant wetland and wildlife benefits for a wide variety of terrestrial species. The development of 9,000 acres of wotlands and wildlife habitat also advances at least tWo goals of the Administration's ESA. program. first, by providing quality habitat for numerous sens4tive species protected under state law, the DW Project promotes wildlife conservation and f serves as atproactive plan that will help ensure thamany of these species may not require future ESA protection. Second, the DW Project's HMP adopts an ecosystem'-based approach, incorporating key aspects of the state and federal wildlife habitat goals for the entire Bay-Delta region. The DW Project also promotes the state and federal goals of"no net loss of wetlands." i tqu�}tic Species B@nefits The DW project,will provide the potential for aquatic species benefits and will avoids gni4ean! impacts to all tJueatened and endangered species. State-a the-art fish screens will be in on all diversi+�ns, including both reservoir end habitat islands. The current diversions onto the four i �I • 5102834028 DELTA WETLANDS 644 P07 JUN 30 197 11:55 Background Information The Delta Wetlands Project Page 5 project islands are all unscreened. DW is also working closely with the U.S. Fish and Wildlife Service (FWS), California Department of Fish and Game (DFG) and National Marine Fisheries Service (NMFS) to develop a comprehensive adaptive management program to schedule the reservoir operations with the needs of the fish species using the project area, including real-time monitoring procedures. • Research Funds The DW Project includes the commitment to set aside two dollars per acre-foot of exported water for research in areas affected directly or indirectly by in-Delta water storage projects. This fund will average about$340,000 per year and will be administered by committee including state,federal and private sector representation. Examples of typical research projects might include fish monitoring methodology and waterfowl nesting investigations. For additional ii-Oormation,contact John Winther at the project office,3697 Mt. Diablo Boulevard, Suite 100,Lafayette, California 94549. Telephone(510)283-4216. Fax(510) 283-4028. December 9, 1996 This Page Left Intentionally Blank Delta Wetlands Material for Contra Costa County Dr. Richard Denton, Contra Costa Water District On June 6, Contra Costa Water District (CCWD or District) submitted exhibits for the State Board's hearing on the water rights applications for the Delta Wetlands Project, scheduled for July 8 through July 24, 1997. The proposed Delta Wetlands Project would involve converting two Delta islands, Webb Tract and Bacon Island, into reservoir storage islands. Up to 238,000 acre-feet of water would be stored on the islands during times of surplus in the Delta and then be released back into the Delta channels when Delta outflow is reduced. When the water is released, the water would become available for purchase by a willing buyer. No buyer has been identified by Delta Wetlands,but the State Board Notice of Hearing states that the water from the islands would be rediverted at the.State Water Project, the Central Valley Project, the Contra Costa Canal intake, or be used to meet Delta outflow objectives. Along with the two storage islands, two other Delta islands, Bouldin Island and Holland Tract, would be converted to wildlife habitat islands. (See Exhibit A attached for map of Delta Wetlands' Islands.) CCWD has been following the Delta Wetlands project since Delta Wetlands originally proposed a four-island water storage project on July 9, 1987 and sought water rights applications from the State Board. The District protested those applications in 1988 on the grounds that the project would injure the District's ability to divert its water at Mallard Slough and at Rock Slough. A draft EIR/EIS was prepared in December 1990 and released for public comment. After receiving substantial comments on the draft EIR/EIS and evaluation of potential fishery, wildlife, and other impacts, Delta Wetlands redesigned the proposed project and in 1993 additional water rights applications were sought by Delta Wetlands. CC"protested those applications. On September 11, 1995, Delta Wetlands issued the new draft EIR/EIS for the project. The District and many other agencies submitted extensive comments on the draft EIR/EIS,but have yet to receive any response to comments. The State Board has indicated that it will distribute the response to comments along with the final EIR/EIS at the completion of the water rights hearing. On March 11, 1997 the State Water Resources Control Board("State Board") issued a Notice of Public Hearing for the Delta Wetlands Project. The Notice outlined the procedures for the water rights hearing, scheduled to begin on July 8, 1997. CC" submitted a Notice of Intent to Appear to the State Board listing the expert witnesses that are expected to testify on behalf of the District. The District has the same concerns with the Delta Wetlands project that it has since its inception, and the testimony of the District encompasses all the comments CCWD has raised previously. Since the issuance of the Notice of Hearing by the State Board, the U.S. Fish and Wildlife Service and the Department of Fish and Game have issued biological opinions for the proposed Delta Wetlands Project. These opinions change the way the Project can be operated from what was proposed in the draft EIR/EIS. Because these biological opinions were not issued until May 1997, their impacts were not analyzed in the draft EIR/EIS. CCWD has the following concerns about the Delta Wetlands project: • Delta Wetlands operations would cause injury to CCWD, by interfering or preventing the filling of the District's Los Vaqueros reservoir. Under the Delta Wetland Project operating rules, as governed by its biological opinions, the District's Los Vaqueros Water Rights could be impacted when Delta Wetlands' islands fill. Delta Wetlands water rights applications are for a diversion of up to 9,000 cfs onto the Delta islands, compared to 200 cfs for Los Vaqueros water. Both Delta Wetlands and Los Vaqueros.water rights are limited by the X2 location in a number of months,but in certain months the Delta Wetlands Biological Opinion allows for diversion when X2 is at Collinsville, when at the same time X2 must be past Chipps Island for the District to divert Los Vaqueros water. Because the requirement for X2 to be at Collinsville is less restrictive than at Chipps, Delta Wetlands would be able to divert water when the District is prohibited from filling Los Vaqueros reservoir. Once Delta Wetlands begins diversions, it is unlikely that X2 would move to Chipps Island because of their ability to divert large quantities of water, and the District would remain prohibited from diverting water to fill Los Vaqueros reservoir under the USBR and LV water right permits. If the Delta Wetlands water rights applications were approved without additional permit term restrictions, then the District might lose some of the ability to use its more senior water right and negatively impact the performance of the Los Vaqueros Project. • Delta Wetlands would degrade District water quality when filling reservoir islands by drawing seawater into the Delta. If approved, the Delta Wetlands Project could divert up to 9,000 cfs of water that would otherwise be available to repel seawater from the interior Delta. As Delta Wetlands reduces the Delta outflow by up to 9,000 cfs, seawater is drawn farther into the Delta, and the salinity would increase at the District's intakes. Recent modeling by Delta Wetlands' consultant suggests that the chlorides at Rock Slough could increase by as much as 20 mg/1. • Delta Wetlands would degrade District water quality when discharging stored water because of high levels of TOC and increased salinity. When water is stored on Delta islands with peat soils, the total organic carbons ("TOC") dissolved in the water increases. The water discharged back into the Delta by Delta Wetlands will have a higher concentration of TOC. TOC levels in the Delta are a concern for urban water users,because higher TOC levels would make it more difficult for the District and others to meet the disinfection by-products rule when treated by District water treatment plants. In addition to increasing the TOC of the water diverted onto islands by Delta Wetlands, the salinity of the water on the islands also increases, because some of the water evaporates, leaving the salt concentration higher in the remaining water. It is also possible that water will be diverted onto the islands during periods of higher salinity and discharged during periods of lower salinity. • Delta Wetlands may be incompatible with the CALFED process, and eliminate certain options currently available for fixing the Delta. • Delta Wetlands would harm fisheries by diverting large quantities of water (9,000 cfs) and by releases of warm water from islands. CCWD has requested a general permit term prohibiting Delta Wetlands from causing any direct or indirect injury to the District or its raw water customers. The District has asked for a specific permit term limiting Delta Wetlands diversions to periods of high Delta outflow (i.e. Delta Wetlands cannot divert unless X2 remains west of X2 = 71 km, which is 3 kilometers west of Chipps Island). This limit would be greatly reduce the chance of seawater intrusion, help ensure DW does not interfere with the operations of the CVP and SWP when the state and federal projects are trying to meet Delta water quality standards, help avoid any conflict between DW and the Los Vaqueros Project which has filling limits tied to X2 being west of Chipps Island, and is consistent with the fisheries testimony of the State Water Contractors. DW's own mitigation measures commit them to stop diverting if they are interfering with other senior appropriators. CCWD also supports the California Urban Water Agencies' (CUWA) request for permit terms only permitting Delta Wetlands to divert good water quality on to the islands and limiting Delta Wetlands discharges to periods when the water quality on the islands is better than in the Delta channels. Delta Wetlands will tend to fill October through February when the water in the Delta is often saltier and contain more organics than average (due to agricultural drainage) and discharge in July and August when the water quality is often the better than average (even though this is a low Delta outflow period). Even if one ignores the fact that storing water on peat soils may cause a build up in TOC (which DW acknowledges but says is only slightly less than the organics produced by existing agricultural practices), and one ignores the concentration of TDS and TOC caused by the high evaporation, DW will create water quality problems just by taking water when it is poor quality and returning it to the Delta when the water quality is better than the stored water. CCWD may be filling Los Vaqueros Reservoir filling at the time during July and August when DW will be discharging stored water for export. The California Urban Water Agencies has submitted detailed testimony that shows there could be significantly more TOC build up than acknowledged by DW and criticizing the experiments and laboratory methods used by DW in the draft EIR/EIS. Urban agencies are very concerned about the impacts of this project on drinking water quality and oppose issuing a water rights permit until these impacts can be properly analyzed and shown not to cause degradation of our water supply. CCWD also supports a proposal by the SWT and CVP that Delta Wetlands be part of a new Coordinated Operations Agreement and that DWR and USBR should decide when excess water is available for Delta Wetlands to divert. CCWD's testimony points out the uncertainties over the magnitude of the salinity reductions that would occur if existing agricultural drainage were eliminated from the four Delta Wetlands islands. Delta Wetlands is claiming that this reduced degradation by eliminating the existing drains offsets any degradation caused by operating the proposed project. The assumptions of the timing and magnitude of the existing agricultural drainage from Webb Tract, Bacon Island and the two habitat islands (Bouldin and part of Holland Tract) used in DW's model studies do not appear be consistent with actual Delta water quality measurements. CCWD also recommends that the Delta Wetlands project should be fully coordinated with CALFED's Bay-Delta solution. If permits for the project are issued, the following terms and conditions should be applied: no diversion should be allowed if CCWD operations are impacted; diversion should only be allowed when water is of sufficient quality; and discharges should be allowed only if stored water is better in quality than that of the Delta. H:\\jkopc\john-old\dwccwd.doc The Board of Supervisors Contra �r'�� and County Administration Building Costa c sto�is�oo� 651 Pine Street,Room 106 Martinez,Cal'tfomia 94553-1293 County Jim Rogers,tat District s e t- Gayle B.Ulikems,2nd District -, �;.-_•,,. Donne Gerber,3rd District Mark DeSsuinisr,4th District J Joe Cenelemills,5th District x�i �• �� T.. hUN July 22, 1997 Mr. Walt Pettit, Executive Director State Water Resources Control Board Paul R. Bonderson Building 901 P Street Sacramento, CA 95814 Re: Water Rights Decision on the Delta Wetlands Project Dear Mr. Pettit: The Contra Costa County Board of Supervisors has authorized this letter to urge that any decision to grant water rights to the Delta Wetlands Project ensure that the drinking water supply of County residents is fully protected and that the fish and other aquatic resources of the Delta are maintained. Current plans for operating the Delta Wetlands Project provide no such assurance. Potential negative impacts include the following: • Delta Wetlands diversions could aggravate the salinity intrusion problem in the Delta at some times of the year, degrading drinking water quality for hundreds of thousands of County residents and harming fish. • The X2 salinity requirement for the Delta Wetlands Project under the federal biological opinion is less restrictive than the salinity requirement for the Los Vaqueros Reservoir diversions, even though the Los Vaqueros water right would be more senior. As a result, operation of the Delta Wetlands Project could limit or even prevent diversions to Los Vaqueros at times when such diversions would otherwise be allowed. • Releases of water from the Delta Wetlands Project could harm water quality for municipal drinking water and fish by leaching excess amounts of organic carbons from the peat soils, by concentrating salts via evaporation, and by increasing water temperatures. • The timing of Delta Wetlands operations could create problems by diverting water during periods of low water quality and releasing this stored water when water quality in the Delta is relatively better. The State Water Resources Control Board should address these negative impacts by including protections for drinking water and fish in any water rights permit that is issued for this project. Mr. Walt Pettit July 22, 1997 Page Two Specifically, the County recommends that any permit be linked to: 1) an X2 requirement for diversions that is more stringent than that for the Los Vaqueros Project; 2) a prohibition on Delta Wetlands discharges when water quality in the project is lower than that in the Delta; and 3) a general condition that the Delta Wetlands Project will not harm Contra Costa Water District or any other water diverter in the County with more senior water rights. Thank you for accepting the comments of Contra Costa County on this issue. If you have any questions about this letter, please feel free to call John Kopchik at (510) 335-1227. Sincerely, Mark DeSaulnier Chair, Contra Costa County Board of Supervisors Ex-officio Chair, Contra Costa County Water Agency MD Jk H:\\jkopc-old\dwswrbj 7.let * n The Board of Supervisors Contra �r'�� County Administration BuildingCosta Cou ty Administrator 651 Pine Street, Room 106 Martinez,California 94553-1293 County Jim Ropers,1st District Gayle S.Uilksma,2nd DiaWo Donna Garber,3rd District -= Blest DaSauiniar,4th District Joe Candam01a,5th District ST'9 COLi"'r July 22, 1997 Mr. Walt Pettit, Executive Director State Water Resources Control Board Paul R. Bonderson Building 901 P Street Sacramento, CA 95814 Re: Water Rights Decision on the Delta Wetlands Project Dear Mr. Pettit: The Contra Costa County Board of Supervisors has authorized this letter to urge that any decision to grant water rights to the Delta Wetlands Project ensure that the drinking water supply of County residents is fully protected and that the fish and other aquatic resources of the Delta are maintained. Current plans for operating the Delta Wetlands Project provide no such assurance. Potential negative impacts include the following: • Delta Wetlands diversions could aggravate the salinity intrusion problem in the Delta at some times of the year, degrading drinking water quality for hundreds of thousands of County residents and harming fish. • The X2 salinity requirement for the Delta Wetlands Project under the federal biological opinion is less restrictive than the salinity requirement for the Los Vaqueros Reservoir diversions, even though the Los Vaqueros water right would be more senior. As a result, operation of the Delta Wetlands Project could limit or even prevent diversions to Los Vaqueros at times when such diversions would otherwise be allowed. • Releases of water from the Delta Wetlands Project could harm water quality for municipal drinking water and fish by leaching excess amounts of organic carbons from the peat soils, by concentrating salts via evaporation, and by increasing water temperatures. • The timing of Delta Wetlands'operations could create problems by diverting water during periods of low water quality and releasing this stored water when water quality in the Delta is relatively better. The State Water Resources Control Board should address these negative impacts by including protections for drinking water and fish in any water rights permit that is issued for this project. Mr. Walt Pettit July 22, 1997 Page Two Specifically, the County recommends that any permit be linked to: 1) an X2 requirement for diversions that is more stringent than that for the Los Vaqueros Project; 2) a prohibition on Delta Wetlands discharges when water quality in the project is lower than that in the Delta; and 3) a general condition that the Delta Wetlands Project will not harm Contra Costa Water District or any other water diverter in the County with more senior water rights. Thank you for accepting the comments of Contra Costa County on this issue. If you have any questions about this letter, please feel free to call John Kopchik at (510) 335-1227. Sincerely, Mark DeSaulnier Chair, Contra Costa County Board of Supervisors Ex-officio Chair, Contra Costa County Water Agency MD:jk H:\\jkopc-old\dwswrbj 7.let