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D. 10
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Adopted this Order on December 12, 1995 by the following vote:
AYES: Supervisors Rogers, Smith, DeSaulnier, Torlakson and Bishop
NOES: None
ABSENT: None
ABSTAIN: None
SUBJECT: San Luis Drain Grassland Bypass Project
On this date, the Board of Supervisors considered further
the San Luis Drain Grassland Bypass Project and comments from the
Community Development Director and County Counsel .
Victor Westman, County Counsel, advised the Board that he
had presented a written report to the Clerk of the Board relative
to the progress on this issue to date.
Supervisor Torlakson moved the report from County Counsel
and the authorization of up to $30, 000 from the Water Agency
budget for the County Counsel' s office and the Water Agency to
pursue retaining consultants and/or legal strategy and
authorization for the Chair to send letters to neighboring
counties urging them to join Contra Costa County and outlining
the urgency of the issue with the Grasslands Bypass and selenium
pollution problem.
The following person presented comments on the issue :
Al McNabney, 1161 Leisure Lane #7, Walnut Creek,
representing Mt . Diablo Audubon Society, in opposition to the San
Luis Drain.
IT IS BY THE BOARD ORDERED that the report from County
Counsel on the San Luis Drain Grasslands Bypass- Project is
ACCEPTED; up to $30, 000 is AUTHORIZED from the Water Agency
budget, for County Counsel and the Water Agency to pursue
retaining consultants and/or legal strategy; and the Chair, Board
of Supervisors, is AUTHORIZED to send letters to Alameda, Solano,
Sacramento and Yolo Counties urging them to join Contra Costa
County and outlining the urgency of the issue with the Grasslands
Bypass and selenium pollution problem.
I hereby certify that this Is a true and correct copy of
an action taken and entered on the minutes of the
Board of SIsors on t date shown.
ATTESTED:
CC : County Counsel PHIL BATCHELOR,Clerk of ofe Board
Community Development Department .Perviso and coup d Inistrator
Roberta Goulart
By Deouty
N
COUNTY COUNSEL'S OFFICE
CONTRA COSTA COUNTY
MARTINEZ, CALIFORNIA
Dace: December 12 , 1995
To: Board of Supervisors
From: Victor J . Westman, County Counsel
By: Diana J. Silver, Deputy County unsel
Re: Grasslands Bypass Project
We are attaching our December 11 , 1995 memo to the Board, a
letter from John Herrick on behalf of South Delta Water Agency
received December 8 , 1995 and a memo from county water agency staff
received December 11 , 1995 .
Under the county' s better government ordinance, staff material is
to be made available to the public 96 hours before it is considered
by the Board unless the time limits are waived by the Board by a
three-fourths vote (C .C .C . Ord . Code § 25-2 . 206 ) . As you will note
from our memo, we were in the process of obtaining this material
until December 11 , 1995 . For this reason, we . ask the Board to waive.
the time requirements under the better government ordinance by a w
four-fifths vote so that this material may be considered by the Board
and made available to interested members of the public at the
December 12 , 1995 Board meeting .
DJS : fjb
Attachments
ib10 a:\grassl.nd.mem
COUNTY COUNSEL'S OFFICE
CONTRA COSTA COUNTY
MARTINEZ, CALIFORNIA
Date: December 11 , 1995
To: Board of Supervisors
From: Victor J. Westman, County Counsel
By: Diana J. Silver, Deputy County 5sel
Re: Grassland Bypass Project (Short term drain use, San Luis Drain)
On November 28 , 1995 , the Board of Supervisors directed staff to
further identify legal and administrative options and to develop
estimates of costs for initiating a legal or other action concerning
the implementation of the use agreement for the above-referenced
project . In addition, the Board asked staff to identify potential
legal counsel who might be available as experts in the water
litigation area .
Accordingly, we have taken the following steps :
1 . Other Water Agencies . At the suggestion of Supervisor
Torlakson, we contacted John Herrick, legal counsel for the South
Delta Water Agency. As indicated in his attached letter, he and the
Central Delta Water Agency (counsel, Dante Nomellini ) are currently
meeting with the Bureau of Reclamation ( "Bureau" ) in an attempt to
resolve their concerns regarding the anticipated increased salinity
in a portion of the San Luis Drain which may result from
implementation of the use agreement . If they are not successful in
resolving their concerns with the Bureau, they may file an action in
federal court in mid-January, 1996 . They anticipate that if a law
suit were filed, the Central Delta Water Agency and possibly, San
Joaquin County may join as parties . Contra Costa County could also
join in this litigation if this county shares the same concerns over
salinity levels . Mr. Herrick indicated that they are not record
gathering now because the South Delta Water Agency has been attending
hearings and compiling materials with regard to the salinity issue
for several years and believes it has enough documentation and
technical analyses in its files to allow it to formulate adequate
legal pleadings without first having the official administrative
record completed.
2 . Special Expert Legal Counsel . We have contacted Kressy
Nakagawa, who has represented the county water agency in. the past.
We have asked him to estimate costs for obtaining the record,
Board of Supervisors 2 December 11 , 1995
obtaining declarations from technical experts and filing a complaint
and motion for a preliminary injunction to stop the implementation of
the use agreement . We have made a similar request of Larry Silver,
the attorney for the California Environmental Law Project,
(C . E.L.P. ) , which has been retained to represent the county and the
county water agency in litigation concerning long term use of the San
Luis Drain. We have also asked him for a status report of that
litigation and for his comments on the cost and possibility and
likelihood of success if a second action were filed to stop
implementation of the use agreement for the Grasslands Bypass
Project . As of this date, we have not received those estimates . If
we receive any written reports from these attorneys, we would propose
to submit them to the Board on the December 12 , 1995 .
3 . Contra Costa County Water Agency Staff . This office is
informed by county water agency staff that they have made an informal
request to the Bureau for a copy of the administrative record of the
relevant proceedings concerning this project . When the record will
be provided has not been indicated. We note that, unlike the South
Delta Water Agency, our county water agency apparently has no
materials and documentation other than the environmental assessment,
FONSI and their comments on the use agreement, submitted in October,
1995 .
4 . One Record Preparation Cost Estimate. On November 28 , 1995,
a representative for Patrick J . Porgans addressed the Board
concerning this issue and represented to the Board that his
organization was prepared to assemble and review data relative to the
record, to perform an evaluation of possible legal courses of action,
to identify and assess impacts of the Grassland Bypass Project and to
perform other record gathering and evaluation services for costs not
to exceed $30 , 000 . This $30, 000 does not include the additional
expense for required attorney time, fees or costs .
Possible Actions . The Board may wish to consider directing that
county water agency staff contact the Bureau to attempt to informally
resolve whatever specified concerns the Board may have concerning
chemical discharges expected to result from implementation of the use
agreement . It is not clear that such concerns may be addressed
adequately at an administrative level but such action should be
considered . If , however, any Board-directed attempts to negotiate
with the Bureau are not successful, the water agency and the county
would still have the option of filing an action, either on its own or
with the South Delta Water Agency. By January, if not received by
the Board' s December 12 consideration of this matter, the estimates
noted in 2 above should be available .
DJS/bmw
djs-6\a:\Grass1an.doc
SOUTH DELTA WATER AGENCY
2509 WEST MARCH LANE, SUITE 200
POST OFFICE BOX 70383
STOCKTON, CALIFORNIA 95267
TELEPHONE(209)474-2509
FAX(209) 474-9701
Directors: Counsel:
Jerry Robinson, Chairman Brewer, Patridge,
Peter Alvarez,Vice-Chairman Genomes&Herrick
Alex Hildebrand, Secretary Engineer:
Robert K Ferguson Gerald T. Orlob
Natalino Bacchetti
December 6, 1995
Via Fax (510) 646-1078 and Regular MaLl
Diana Silver, Esq.
County Counsel
Administration Building
P.O. Box 69
651 Pine Street, 9th Floor
Martinez, CA 94553
Re: Grassland Bypass Proiect
Dear Ms. Silver:
This letter is in response to our telephone conversation
today. Our Agency has previously raised with the USBR various
issues regarding the Grassland's Bypass Project, prior to that
Agency issuing its FONSI. Our major concern was that the Project
as contemplated will result in less drainage of a higher
concentration of salinity entering the San Joaquin River.
Consequently, the Bureau will be less likely to meet the Vernalis
salinity standard of 0.7/1.0 EC. Previously, the Bureau
consistently failed to meet the 500 TDS standard. Higher salinity
seriously affects agricultural diverters in our area especially
during summer.
Notwithstanding our efforts, a final Supplemental
Environmental Assessment and FONSI were issued on the Project on
November 3, 1995. Neither of these documents addresses the
salinity issue we raised. However, the Bureau requested we meet
with them on November 20, 1995 to discuss our concerns. This
meeting was scheduled as a result of a letter by me in which I
again pointed out the failings of the environmental documents. At
this meeting Mr. Michael Delamore of the Bureau and
Mr. Joe Karkoski of the Central Valley Regional . Board quickly
understood the point we were making and agreed the Project could
cause the effects we were predicting. The first Supplemental
Environmental Assessment clearly shows this impact and the
subsequent changes in the Project and those caused by the CVPIA
further exacerbate these delineated effects.
Diana Silver, Esq.
December 6, 1995
Page two
Mr. Delamore agreed he would try to get back to us within a
month with some sort of proposals that would hopefully address our
concerns. We look forward to his proposal but cautioned him that
if our concerns were not adequately addressed, we expected to be
forced to file a NEPA action on this matter. At this time we do
not expect to file any such action before January. As of today,
I have not heard back from Mr. Delamore.
From discussions with other counsel of interested parties, I
would anticipate at least two other San Joaquin County Agencies or
Entities would want to join in any such action. Once a suit is
filed, the Bureau would then prepare the Record which would consist
of all document studies, correspondence, etc. , developed and
submitted on the matter. This Record would then be the factual
basis for legal arguments under NEPA.
Prior to bringing such an action, I will discuss the matter
further with you and other parties who may wish to join in. As I
have stated, the salinity levels are our main concern. Other
issues would probably be involved and it could be anticipated that
some of the plaintiffs may have conflicting goals and interests in
this matter. However, if such were the case we could still jointly
participate in bringing the action and share costs of such things
as the preparation of the Record.
Please feel free to contact me if you have any questions.
Very truly yours,
BREWER, PATRIDGE, GERLOMES & HERRICK
Attorneys At Law
By yr
HN ERRICK
JH/ce
cc: Dante Nomellini
Karna Harrigfeld
Jeanne Zolezzi
Virginia Cahill
Alex Hildebrand
DEC-]1-95 MON 05;39 PM CCWD WATER RESOURCES FAX N0, 510 674 8142 P. 02
CONTRA COSTA
WATER DISTRICT
1331 Concord Avenue
P.O.Box H2O
Concord,CA 94524
(510)688-8000 FAX(510)688-8122
Directors December 11, 1995
Joseph L.Campbeii
President
Elizabeth R.Anew
:Vice President
Bette Boatmun supervisor Gayle Bishop, Chair
Donald P.Freitas Contra Costa County Board of Supervisors
James Pretti County Administration Building
Walter J.Bishop 651 Pine Street, Room 106
General Manager
Martinez, CA 94553-1293
Subject: Grasslands Project, Letter of December S, 1995
Dear Supervisor Bishop:
Thank you for your letter of December 5 on the San Luis Drain-Grasslands Project.
As you know, the Contra Costa Water District ("District") has long been concerned
about water quality in the San Joaquin River and the Bay-Delta, and has fought, and
continues to fight, vigorously for improved water quality conditions in the Bay-Delta
and its tributaries. The District has joined with Contra Costa County and others to
intervene in a lawsuit which could result in a consideration, once again, of an extension
of the San_Luis Drain to the Delta. The District and the County are working together
to prevent any consideration of that project, and to ensure that the outcome of the
lawsuit is a swift improvement in water quality through a reduction in the discharge of
pollutants, including salts, to the San Joaquin River,
The District has closely followed the Grasslands Project since last summer and has
provided written comments to the United States Bureau of Reclamation and the Central
Valley Regional Water Quality Control Board (RWQCB) on a number of occasions.
Copies of our correspondence are attached. The District shares your view that it is
preferable to have a plan that guarantees improvements to downstream water quality
through a reduction in pollutant discharges with meaningful enforcement mechanisms.
The drainage in question has for a long time been discharged to the San Joaquin River,
via the wetlands, without controls or adequate enforcement standards, a situation that
is and has been unacceptable. One of regulatory proposals before the RWQCB would,
if successfully implemented, result in a reduction in pollutant discharges to the San
Joaquin River and would put current agricultural drainers under the supervision of the
Regional Board for the first time.
DEC-11-95 MON 05:40 PM COWD WATER RESOURCES FAX NO, 510 674 8142 P103
Supervisor Gayle Bishop
Grasslands Project, Letter of December 5, 1995
December 11, 1995
The District would be happy to discuss with the County ways in which we can achieve our
common goal of improving water quality in the Bay-Delta by ensuring our efforts result in real
pollutant reductions. The District remains strongly opposed to the San Luis Drain and will
continue to find legal means to stop it.
Dr. Richard Denton of our staff is available to discuss actions that we might take. He can be
contacted at (510) 688-8187.
Sincerely,
Walter J. ishop
General Manager
WJB/GG/ce
Attachments
CC*. Board of Directors
Richard Denton