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HomeMy WebLinkAboutMINUTES - 06231998 - C145 TO: BOARD OF SUPERVISORSO costal FROM: WATER COMMITTEECounty ---''� Supervisor Joe Canciamilla, Chair Supervisor Gayle B. Uilkema DATE: June 23, 1998 SUBJECT: COMMENTS ON THE DRAFT EIRIEIS FOR THE CALFED BAY-DELTA PROGRAM SPECIFIC REQUEST(S) OR RECOMMENDATION(S) & BACKGROUND &JUSTIFICATION RECOMMENDATIONS AUTHORIZE the Chair of the Board of Supervisors to sign a letter to Lester Snow, Executive Director of the CALFED Bay-Delta Program, conveying County comments on CALFED's Draft Programmatic Environmental Impact Report/Environmental Impact Statement, including opposition to construction of an isolated facility i to convey water around the Delta. FISCAL IMPACT None. BACKGROUND/REASONS FOR RECOMMENDATIONS The CALFED Bay-Delta Program is a state/federal joint planning effort intended to restore the Sacramento-San Joaquin Delta system and address problems with its use, such as water quality and water supply reliability. The Board of Supervisors Water Committee has examined the CALFED Bay-Delta Program and the Draft CALFED Programmatic EIR/EIS at a number of meetings over the past several years. Water Committee activities on this matter have included presentations from the Executive Director of CALFED and County Water Agency staff as well as a number of written staff reports providing background and analysis. As a result of thesediscussions, the Water Committee recommends that the Chair of the Board of Supervisors sign the attached letter which outlines primary County concerns and comments regarding the draft CALFED plan for the Delta. Specific, detailed comments on the draft environmental document will be submitted separately by Water Agency staff. CONTINUED ON ATTACHMENT: X YES SIGNATURE: RECOMMENDATION OF COUNTY ADMINISTRATOR — RECOMMENDATION OF BOARD COMMITTEE APPROVE OTHER 2' 4 -� SIGNATURES?: of : S r\' or Joe Canciamilla Chair Sur)er4isor Gayle B. ill erna ACTION OF OAR O APPROVED AS RECOMMENDED — OTHER VOTE OF SUPERVISORS 1 HEREBY CERTIFY THAT THIS IS A X UNANIMOUS (ABSENT TRUE AND CORRECT COPY OF AN AYES: NOES: ACTION TAKEN AND ENTERED ON THE ABSENT: ABSTAIN: MINUTES OF THE BOARD OF SUPERVISORS ON THE DATE SHOWN. Contact: John Kopchik, CDD (335-1227) ATTESTED ` Orig: Community Development Department pHae BATCHELOR, CLERK OF cc: CAO THE BOARD OF SUPERVISORS County Counsel AND UNTY ADMINISTRATOR Public Works , Department of AgricultureBY - pEPUTY h Ajkopc\john-o{d\cfedcom8.bo COMMENTS ON THE DRAFT CALFED EIR/EIS June 23, 1998 Page 2 OVERVIEW 4F THE CALFED BAY-DELTA PROGRAM The CALFED Bay-Delta Program is one outcome of the December 1994 Delta Accord (the first evidence of consensus in the state's historic battles over water) and is a joint planning process sponsored by an array of state and federal agencies. It is intended to resolve, at least partially, problems which are manifest in the Delta and portions of the Bay. CALFED has identified four primary types of problems on which to focus: 1) water quality; 2) ecosystem quality; 3) reliability of water supply; and 4) integrity of Delta levees. CALFED has also identified six so-called "solution principles" which are the criteria by which proposed programs will be judged. According to these principles, the preferred alternative in the final EIS/EER must be: 1) affordable; 2) equitable; 3) durable; 4) implementable; 5) must reduce conflict among competing interests; and 6) must not have significant redirected impacts. CALFED seeks to be loosely consensus- based, and sponsors a variety of "stakeholder" forums to help achieve this goad. CALFED is a three phase program. Phase 1, which was completed late last year, included scoping and the development of three alternatives for further environmental review. Phase 11 is currently underway and involves the development of a draft program level EIS/EIR (now available for comment), the preparation of a revised draft program level EIS/EIR including a draft preferred alternative by the end of 1998, and the completion of a final program-level EIS/EIR selection of a final preferred alternative by the summer of 1999. Phase III involves site-specific project analysis and will begin in 1999. The first Draft Programmatic FIR/EIS for the CALFED Bay-Delta program was released on March 16, 1998. Comments on this document are due by duly 1 , 1998. Public hearings were held throughout the state during the month of May, including one public hearing held on May 13 in Pittsburg. The Draft EIR/EIS consists; of one primary document, an executive summary, and eleven appendices devoted to specific subjects such as the Water Quality Program, Implementation Strategy, etc. The Draft EIR/FIS does not identify a preferred storage and conveyance alternative though it does compare performance over a variety of criteria described by CALFED as "distinguishing characteristics". Copies of the CALFED documents, past staff reports, and past County comments are available upon request. CALFED is considering a wide range of actions to address the four primary Delta problems listed previously. Most of these proposed actions are contained within a core of "Common Program Elements" which will be included in any CALFED plan regardless of which alternative is selected. The six Common Program Elements are: the Long- Term Levee Protection Plan, the Water Quality Program, the Ecosystem Restoration Program, the Water Use Efficiency Program, the Water Transfer Policy, and Watershed Management Coordination. The three alternatives to be analyzed in the EIS/EIR are distinguished by differences in how water is stored and how it is transported through the Delta. Alternative 1 relies on the existing system of natural channels to transport water. Alternative 2 would modify natural channels to make water' transport more efficient. Alternative 3 would include both through-Delta water conveyance and construction of an isolated conveyance (i.e., a pipeline or canal or some kind) to transport water around the natural channels to the large export pumps. COUNTY AND V1 ATS AGENCY INYOLVEMENT The County and its water agency have participated in the CALFED Program since its inception. Staff from the Water Agency regularly attend CALFED workshops and meetings, as well as meetings of the Bay Delta Advisory Council and the meetings of the various BDAC work groups (BDAC is an panel of stakeholders and;agencies which is intended to provide guidance to the CALFED program; it is not the only vehicle for public involvement). The County and the Water Agency have submitted several letters to CALFED as the program has progressed, including letters from the Board on the CALFED scoping process (May 14, 1998), on the scope of the proposed CALFED Habitat Conservation Plan (October 14, 1997), on the Draft Ecosystem Restoration COMMENTS ON THE DRAFT CAVED EIRIEIS June 23, 1998 Page 3 Program Plan (October 14, 1997) and on selecting interim restoration projects (December 2, 1997). These letters have stressed two primary issues; 1) the importance of maintaining a common Delta pool for uses and users in order to meet the "durability" solution principle; and 2) the need to throughly consider the impacts to water quality caused by agricultural drainage. At its meeting in December of 1997, the Water Committee approved the following mission statement to guide its process of reviewing and commenting on the CALFED Ray-Delta Program: Contra Costa County supports the intent of the CALFED Bay-Delta Program to restore the natural resources of the Bay-Delta system and resolve the longstanding conflicts associated with utilizing these natural resources. Contra Costa County will actively participate in and comment on the actions of the CALFED Bay- Delta Program to ensure the protection, preservation, and enhancement of water quality, freshwater flows, fisheries, wetlands, and educational/recreational opportunities of the San Francisco Bay-Delta estuary system. KEY ISSUES The CALFED program is addressing many issues of concern to Contra Costa County. A summary and brief analysis of some of the major CALFED components with significant bearing on the interests of the County are presented below. Storage and conveyance alternatives, probably the most crucial issue from a County perspective, are discussed last. Ecosystem restoration actions are not discussed extensively because the Board commented on that specific issue in October of last year. Selected figures from the CALFED documents are referenced by number in the text below and are included at the end of this report. CALFED IMELEMENTATION STRATEGY The Implementation Strategy released by CALFED discusses two important issues Assurances and Financing. The document outlines, in a very genera) way, the range of tools which could be used as well as the policy questions that must be answered to select from among these tools. No specific Assurances or Financing plan is provided, at least partially because CALFED contends that a decision on which actions will betaken is needed first. However, it is very difficult to evaluate certain proposed actions, such as an isolated facility, without knowing how its "proper" use will be assured or who will pay for it. Some examples of Assurances and Financing issues of interest to the County that are raised but not resolved in the Implementation Strategy are the following: • Who will operate any isolated conveyance facility? What criteria will be used to determine how much water will flow through the facility and how much will flow through the Delta (i.e. criteria to guide a balancing or prioritizing of the competing goals of fisheries protection, export water quality, and Delta water quality)? How can we be assured that these criteria will not be changed? • How can diverters of Delta water be protected from further mitigation requirements by a "no surprises" policy through a Habitat Conservation Plan while extending the same level of protection to the biological resources of the Delta? This problem is magnified because we may not be able to identify or effectively address the causes of their decline. • Who will pay for an isolated facility, for major new darns north of the Delta, and for ecosystem restoration activities? The Implementation Strategy suggests that the general public may be asked to fund a share of these efforts because the isolated facility may be built (in part) to improve fisheries, new reservoirs may be used (in part) to increase Delta flows, and restoration activities may be viewed as the responsibility of society rather than as measures to mitigate for damage caused by Delta exports or other specific actions. The draft comment letter briefly addresses these implementation issues. COMMENTS ON THE DRAFT CALFED E#R/EiS June 28, 1998 Page 4 WATER OL)ALITY PROGRAM Like the Implementation Strategy discussed above, the CALFED document which describes the Water Quality Program is extremely general. With respect to agricultural drainage, a primary cause of poor water quality in the San Joaquin River and parts of the Delta, CALFED identifies some very broad and appropriate goals, such as meeting all water quality standards for selenium and salinity, but fails to identify specific actions needed to achieve these goals. The document mentions land retirement and more efficient irrigation, but provides no descriptions of how or where this will occur and sets no quantitative goals for implementation. Formerly, CALFED had set a target of retiring 70,000 acres of the most drainage-impaired lands in the San Joaquin Valley, but this is not mentioned in the current document. (early in the CALFED process, retiring as much as 800,000 acres was considered) The Water Quality Program could also be improved by including specific and enforceable performance criteria for the attainment of water quality standards, a tool which may help to correct the past limited effectiveness of the State and Regional Water Quality Control Boards in making progress in some areas, particularly the San Joaquin River. The Draft comment letter briefly addresses these issues. WATER STORAGE Storage is emerging as a key issue in the CALFED debate, and the County may want to consider adopting a position. Water users are urging CALFED to develop new water supplies for a growing population by creating additional storage, beyond the storage needed for operational flexibility and improved reliability. Storage proponents argue that the new diversions needed to fill this storage could be timed just after peak flows to minimize impacts (when diversions would be very small relative to total flows; peaks would be maintained as these have important ecological functions) and that the new storage could be used to provide increased flows for fish during critical periods. Environmental and fishing interests argue that new diversions and reservoirs run counter to the goal of restoring the Delta and its freshwater flows, though conjunctive use of groundwater as a storage technique is generally supported. The Draft comment letter supports storage as necessary to support growth and provide for freshwater flows for the environment, but urges that storage be created in the most environmentally benign manner possible. POTENTIALLY SIGNIFICANT LAND CONVERSIONS IN THE COUNTY Within the storage and conveyance alternatives, two specific projects are mentioned which could involve significant land conversions in the County: (1) expansion of Los Vaqueros Reservoir from a capacity of 100,000 acre feet to an approximate capacity of one million acre feet; and (2) levee setbacks and channel enlargement along Old River, which could impact Syron Tract, Orwood Tract, Palm Tract and possibly other areas. Flooding of some Delta islands, similar to what is proposed under the Delta Wetlands project, is another action under consideration. These two actions are mentioned by CALFED primarily as examples of specific projects which could be performed if program level alternatives (i.e. "increase storage south of the Delta") were selected. Project level environmental review of these actions would be required if they were to proceed. Comments on these matters could be provided now or withheld until project-level review, should that ever occur. WATER USE EFFICIENCY Ensuring that water users, particularly agricultural customers of the state and federal water projects who have not agreed to binding efficiency guidelines such as those adopted by urban agencies, make efficient use of existing supplies before new supplies are developed may be an appropriate recommendation consistent with past County policy to protect freshwater flows. R C L URAL IMPACTS QF THE ECOSYSTEM TO ATl N PROGRAM AND OTHER CALFED ACTIONS TO CONVERT AGRICULTURE: COMMENTS ON THE DRAFT CALFED EIR/EIS June 23, 1998 Page 5 The Ecosystem Restoration Program is drawing considerable attention from farmers in the Delta concerned about the loss of agricultural lands to habitat and facilities. The Draft letter urges CALFED to do more to minimize and mitigate impacts to Delta agriculture while making serious efforts to restore the ecosystem. STORAGE AND CONVEYANCE ALTERNATIVES Provided below is a summary of the three alternatives, the common Delta pool concept, and the other long-standing policy arguments regarding the Peripheral Canal or other isolated conveyance facilities. The focus, however, is the information yielded by the CALFED analysis of these alternatives and its implications for County comments on this matter. Summary of the Three Alternatives: All three alternatives now include possible new water storage facilities (reservoirs--probably off-stream reservoirs--and groundwater) north and south of the Delta. As seen in Figures 1 and 2, it is the storage component of these alternatives, rather than the conveyance options, which make possible increased export of Delta water. The water to fill this new storage could be diverted during periods of very high flow when impacts to the ecosystem and to salt water intrusion may be minimized. Increased diversions at other times could have large impacts. Regarding the distinctions in how water is conveyed through the Delta, the chief differences are as follows (see Executive Summary for more information): Alternative 1- Least expensive, involves only small changes to how water flows through the Delta. Alternative 2- Floods some islands and widens some channels to improve conveyance of Sacramento River Wafter to the South Delta while at the same time slowing this southward flow down to reduce fisheries impacts. Alternative 3- Combines portions of Alternative 2 with construction of an isolated facility (probably a canal rather than a pipeline extending from near the town of Hood on the Sacramento River to the South Delta pumps) which is intended to further reduce fisheries impacts and provide a better, more reliable water supply for exporter areas. As shown in Figures 3 & 4, none of the alternatives are predicted to have a significant impact on salinity intrusion, as measured by the indicator known as X2 (X2 is the location at which total salinity reaches 2000 parts per million of total dissolved solids). The reasons for this are the following: (1) the requirements for maintaining specific X2 locations were fixed by the 1994 Bay-Delta Accord, and (2) the only proposed new diversions to new storage are planned for periods of very high flow. The Ecosystem Restoration Program may provide new flows for the environment during critical periods, which might have some small positive impact on X2. However, this assumes that willing sellers of water can be found--not at all a certainty. Summary of Policy Issues: The County and others have for many years advocated the maintenance of a common Delta pool to ensure that all parties which use or have a stake in the Delta have shared need to maintain water quality, flows, and healthy populations of fish and wildlife. The County General Plan addresses this matter, stating "The County shall actively oppose any and all efforts to construct a peripheral canal or any other water diversion system that reduces Delta water flaws unless and until it can be conclusively demonstrated that such a system would, in fact, protect, preserve and enhance water quality and fisheries of the San Francisco Bay-Delta estuary system." (Policy 8-19 on Page 8-29). Proponents of the isolated facility argue that the common Delta pool has not worked well to date and that an isolated facility is needed to ensure a safer (from a health perspective) water supply,!to improve the reliability of this supply, and to protect fisheries from the reverse flow !problems in the COMMENTS ON THE DRAFT CAVED EIRIEIS June 23, 1998 Page 6 Delta caused by heavy pumping in the South Delta. Evaluating the Storage & Conveyance Alternatives: As CALFED has not yet selected a preferred alternative, the County should, in its comments, indicate which alternative or alternatives it favors. Figure 5 presents CALFED's overview of the key advantages and disadvantages of the three storage and conveyance alternatives. Certain alternatives do not benefit the interests of the County, and/or have little chance of being selected, and should be abandoned. For example, some variations of Alternative 3 call for a large isolated facility with a capacity of 15,000 cfs (the 1982 Peripheral Canal and was to be 23,000 cfs, though it was to have been constructed somewhat differently). Such a facility would significantly degrade in-Delta water quality (see Figure B), would provide no physical assurance that any operating criteria designed to protect the Delta would be adhered to, and would essentially eliminate the common Delta pool. Likewise, Alternative 1 slightly degrades water quality for CCWD and other urban suppliers, fails to address some fisheries problems, and has little chance of being implemented. The key questions before the Board are: (1) whether the smaller isolated facilities proposed by CALFED meet the water quality and fishery criteria of the General Plan (the Water Committee can think of no reason for changing the General Plan policy), (2) whether the claimed advantages of an isolated facility are substantive and important from a County perspective; and (3) whether the benefits of a smaller isolated facility outweigh the costs of a diminished common Delta pool. Preliminary analysis of these three points is provided below. Question 1 : There appears to be some agreement among fisheries experts (particularly among U.S. Fish and Wildlife Service fisheries experts) that while all three of the CALFED alternatives would benefit fisheries to some extent, Alterative 3 (isolated facility) would have the most benefit. Biologists predict Alternative 3 would gest reduce the negative effects of South Delta diversions (by reducing the need to transport fish caught in screens and by reducing diversions in important spawning habitats--see Figure 7), best reduce reverse flow problems (Figures 8 & 9), and best restore a Delta circulation that is healthy to fish (Figure 10). In terms of Delta water quality, Alternative 3 has the most disadvantages, mainly because it increases the impact of poor quality agricultural drainage which flows northward in the San .Joaquin River. As seen in Figures 11 , 12 and 13, Alternative 1 causes the least change, Alternative 2 has the most benefits, and Alternative 3 causes the largest change (some positive some negative--the degree of impact depends heavily on how large the isolated facility is and how much it is used), Alternative 2 is predicted to have the most benefits for water quality at Rock Slough (one of CCWD's diversion points) while Alternative 1 is predicted to be slightly deleterious and Alternative 3 is predicted to be slightly advantageous (Figure 14). Conclusion; The question of whether CALFED's proposed isolated facility, as compared with other conveyance alternatives, would meet the criteria outlined in the General Plan cannot be answered definitively. Fisheries might benefit from an isolated facility, but Alternative 3 would seriously degrade water quality in some areas and improve it in others (whereas Alternative''2 would better protect Delta water quality), making it difficult to assess the overall impact. Question 2: The primary advantages of a small isolated facility are the predicted improvements to fisheries, to export water quality, and to the reliability of export water supplies. The predicted advantages to fisheries are discussed in more detail above and do constitute a substantive improvement' from a County perspective, Likewise, if an isolated facility were built, it is possible that County residents that now receive their water from the Delta could instead receive water from the isolated facility. Such a facility would provide',water that not COMMENTS ON THE DRAFT CALFED EIR/EIS June 23, 1998 Page 7 only has better quality than the water provided now, but is also better than what is predicted under Alternative 2 (Figure 15). This is important not only to reduce the saltiness of tap water, but also to reduce the associated levels of bromide which can react with chemical disinfectants to produce trihalomethanes(THMs)--known carcinogens which are suspected to increase the risk of miscarriage and which we continue to learn more about (more stringent THM standards are expected in the near future). Regarding reliability of exports, to the extent that an isolated facility would provide water to County residents and would reduce the impact of Delta levee failures (in terms of short term increased salinity intrusion), the County does have some interest in this outcome, though it is difficult to determine how much. CALFED also predicts that an isolated facility would benefit export reliability by excluding these diversions from regulations on Delta exports (such as criteria for maintaining certain Export-inflow ratios), but this asserted benefit applies more to non- County exporters, as Los Vaqueros Reservoir should effectively boost the reliability of CCWD supplies. Conclusion: At least some of asserted benefits of an isolated facility are substantive and important to the County. Question 3: Weighing the advantages of a smaller isolated facility against the disadvantages of diminishing the common Delta pool and against the advantages of Alternative 2 is difficult because: (1) we lack important information on assurances and financing; and (2) we are required to choose among some important, long-held County interests. To be specific, the County would have to choose between the potential improvements to fisheries and tap water quality offered by Alternative 3 on one hand, and the much better in-Delta water quality and the long-term assurance of a maintained common Delta pool offered by Alternative 2 on the other. Conclusion: The Water Committee's view is that the uncertainties associated with the Assurances, Financing, and the Water Quality Programs (all discussed above), make accurate comparison of the predicted advantages and disadvantage of Alternatives 2 and 3 (small facility only) close to impossible. The physical assurance of Alternative 2, which would maintain the common Delta pool and better protect in-Delta water quality, are more concrete and important to the interests of the County than the predicted but far from certain advantages of a small isolated facility. PRIMARY ISS E FOR INCLUSION IN THE BOARDS COMMENT LETTER The Water Committee recommends that the Board of Supervisors authorize the Chair to transmit comments on the Draft Programmatic EIRIEIS for the CALFED Bay-delta Program which: • explain the County's strong concern with the construction of any isolated facility because the uncertainties and disadvantages far ` outweigh any advantages, 0 recommend the selection of Alternative 2 as the preferred alternative, • urge Strengthening and significantly expanding the Water Quality Program, the Water Use Efficiency Program, the financing strategy, and the assurances package, • urge the maintenance or enhancement of freshwater flows to and through the Delta to benefit fisheries and Delta water quality, * recommend inclusion of some new water storage to provide for growth, operational flexibility, emergency reserves, and increased freshwater flows through the Delta, but urge that such storage be developed and operated in the most 'environmentally benign manner possible, • recommend that the Ecosystem Restoration Plan be refined to minimize and mitigate impacts to Delta agriculture while maintaining restoration goals, • urge support for actions to improve educational and recreational opportunities COMMENTS ON THE DRAFT CALFED EIR/EIS June 23, 1998 Page 8 in the Delta, and • support and reinforce the principles outlined Water Committee's mission statement with respect to CALFED (see page 3). Attachments: • Figures 1-14, reproduced from the CALFED Draft EIR/EIS • Recommended Board of Supervisor comment letter on the Draft CALFED EIR/EIS H:\jkopc\John-otd\cfedcom8.bo _ __ ___ Figure 1 South of Delta SWP and CVP Water Supply Average Annual Critical Period Deliveries Alternative 1 Altemative 2 Altemative 3 SIMO ............................ ..................-----..._. ......................... Legend 8Ao0 ............................ ................................. ........_..........�...... ons Smd on __ wsong ftndsrds 4,76o ................................ ................................ ................................. ... 4.250 ................................ ................................ ................................ NoAcdbn 4,1X10 3,750 ................................ ............................». -------.................. ...... 3MO �.. a-is irrrrr�wrrr�.�a�w- F1 re 2 South of Delta SWP and CVP Water supply Average Annual Lon Term Deliveries Long 6,750 Altemative 7 Altemative 2 Altemative 3 8Le end .500 .............................. ............................. .... ...._._..._._......_ 9 61000 ........................ ............................. - . . Fids tng con&wOm 5,750 ................................ ............... ...........:.. ....... No Aeon 5,500 ....r_r.y..r_,r..�.-.a, �_r_.r.-..-.....r......r. .r ...�.�_.r.s.aw_:.�.._ 8,250 C Ml � Figures I and 2 compare the predicted Delta exports made possible by the three alternatives (storage has more impact than conveyance). ......... ...._.... ......... ......... ......... ......... ......... ......... ._..... .. _.... ...... ......... Figure 3 Average X2 Position under Program Alternatives Water Years 9975-99 (All Years) . i 100 ► 95 ..............•......... .................................................................... 90 ----------•---------•----------•-•----•-••-----•----------------------------------------- 85 ..................................... ............................................... .....-.No Action i so .. .. .. ........................................................... x:::. ...,..Alternative I +SIG75 ................. ::.` ........- ...--•--............... . .................. Alternative 2 ! sic 70 ----•---------------------':. ................... ' ................................. J..x ' Alternative 3 65 •................................ .4 .... .....---------- ..__......................... J 68 .......................................: "__--__------__--._____---------_--_-_--------._- 55 ..................................................... ..................................... 50 Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep 1vilre CA "' a X2 Position under Program Alternatives Average g Water Years 9975-91 (dry and Critical Years Only) 100 95 .................................................. ....................... ....... 90 ................................_.._....-•-----.._._._.._........._........._.-........ ... -..No Action 85 .., =a,•--r K ....................................... rr 80 `;�•; - d«�' ................ ..,,..Alternative k T5 ............................ .....-.........,x.' ,:.................................. a � .•. __ Alternative 2 yTit ....................................... :. .. . � -.�•-Alternative 3 65 .................•--._..........._...--•---------••---•............_...................... 60 .......................................--------............_.............-_....._._.... 55 ------------------------------------------------------ ................................... 50 Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Figures 3 and 4 compare the predicted effects of the three alternatives (and the no action alternative) on salinity intrusion. ..................................................................................I...................................... ............................. .................................................................................................... .......................... ... ... ... ........ Figure 5 Summary Evaluation of Most Significant Technical Distinguishing Characteristics 9 e J� Aherr ative I M L L L L L L L Alternative 2 M+ M M+ L M L M M Alternative 3 L H L M+ M+ M H H ............................................................................................. .............-....................... ............ Figure 6 Alternative 3 09tegOry 3E Q 3H 31 me to River at Flow, 0 Less flow down Sacra; !ng:tat e simiiarto=with 0 Similar to 2C with Velocity, Rio Vista and through Deb toward reduced flows through reduced flows and Stage pumps Delta through Delta * Reduces reverse flows in San Joaquin River * Decreased velocity in channels with setback levees * Changes in stage and velocity in am near flow control structures Mass Fate 0 Reduces mass reaching exports from • Similar to 2E except • Similar to 2C all locations except Freeport isolated facility reduces except isolated 0 For low flow conditions,increases mass reaching exports facility reduces travel time through Delta for mass from all locations except in=reaching injected in south and central Deb Freeport exports frown an locations except Fmepmt Net Delts, 0 Similar to 3B Similar to 2D • Similar to 3B Outflow Central * Reverse flows are not observed. * Similar to 3E 0 unknown Deb outflow X2 Position 0 Similar to 3B 0 Similar to 2D * Similar to 3B Salinity 0 Increases Salinity at Jersey Point in the * Similar to 3E 0 unknown. winter and spring about W1.of the time.Reduces salinity at Jersey Point during the remaining times of year. * Substantially increases salinity at Emniaton throughout the year about SO*/*of the time,mom so in summer and fall. * Substantially increases salinity at 4<WAOWAW� 0-0 Rack Slough throughout the year. Rock Slough salinities increase in winter and spring about W1.of the time. * Substantially reduces salinity at Clifton Court Favlay. Table 6.L2-2. Summary of Changes in Dela Hydrodynamic Variables Baud on DWRDSM1 and DWRSIM Model Simulation(page 5 of 5) Predicted Salinity Impacts of a Large (15,000 cfs) of a Isolated Facility. ................ ...... .................................... .................... ................I............ Figure 7 Dlvtrslon Efftets on Fisltarles (Qustitstivs Assesament) Rest Better Good Evisting No Action Aft. f Alt.2 All,8 Conditions 1 ;i. re OS .San Joaquin River at Antioch_ Average Monthly Flow Water Years 1975-91 (Dry and Critical Years Only) 6,000 4,000 No Action .. Alternative 1 2,000 ------`--`x: ................... ......,,tS_...._...... ... � +s V,�,. Alternative 2 10 -,,-Alternative 3 -2,000 ......y4..• ........ ...;:........................._._......................_..._._._.. -4,000 , Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep • F1eure 9 Old River at Bacon Island Average Monthly Flow Water Years 1975-91 (Dry and Critical Years Only) 1,000 Q ............................... _� ----- ...................................... _.__No Action -1,000 .............•--...............--• ...... ......... ..............W..........•--- r....,., .......Alternative 1 -2,000 + :...............: ........................ � -�.Alternative 2 rot -3,000 ---•-•. •••. .... .;`. ` 1�r.......................... s:::"" _Alterrrativ$ 3 -4,000 '................. ........... ,: . -5,000 Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Comparisons of predicted impacts of 3 alternatives on flows and reverse flows (negative numbers) at selected points in the Delta. Figure 10 Flow Circulation -. for Fisheries (Onalttative Assessment) Seat i Setter J i Good i No grange ~ .dW AMW i Existing No Action Alt. t Y Alt. 2 Alt. 3 Conditions ......... ......... ......_.. _ Fivre �. Alternative 1- Changes in Salinity from No Action Alternative �R j yr � Ji r�� s �� w«se water owd ty �,.T..>$etterwater Quatity Note:In these figures"+" means better water quality and reduced salinity measured by electrical conductivity(EQ; "='means worse water quality. Figure 12 Alternative 2- Changes in Salinity from No Action Alternative •j r t WorseWater Qoelity Hetltr Water L7"Ry Fi re 1,3 ,Alternative 3 - Changes in Salinity from No Action Alternative sc � s s t ` T Worse Wats Ckw ty t BMW Water Model Output Locations for Monthly Average Electrical Conductivity n Legend +' 3 Sar R Riumteen 21 MWdk River 4Str R �CoRkmViDe 'i racy Road ....7 N*rtk Say Aelnede d 23 Middk S Terminans Alxneienilk Is @�'�+e ti 'i3ylaa! ti, t !! SQL,g Rindge Tpad 25 Glom#Line c �v 12 ."e TR PPrs„eattere Pot xsC We A Ead , 15 SJR C Antioch 28 comb ec C+aft `. I4 oW iL a Middle River 1nt�ks 19 old River heck.S! •DMC intake at existing be ubm tar Alteruativ'e 1A K-ey for Ficmires 11 - 13 Figure 14 Average EC-- Contra Costa Intake water Years 1075-81 Sao 60o . wary end CrNicaf Yeah ,Aft Years �, 10tT w soft 0 No Action Aft. 1 Alt.2 Aft. 3 .......................... ........................ .....................- .............. Figure 15 - Comparison of Bromide Impacts at Rock Slough (CCWD's current intake) with those at Clifton Court (location of Delta pumps and proposed terminus of isolated facility (Alternative 3)) Predicted Bromide of Rock Slough SDD f3UPP&r 95% Confidence 400., Limit WAverage CL Lower 95% 200.,-' Confidence Limit 100. No Action Alt. I Aft.2 Alf. 3 Predicted Bromide at Clifton Court W W toper 96% Confidence Limit 400. EAverege Soo-,,, Lower 95% a 20O Confidence Limit 100." No melon W. I T.3 Alt. 3 ........... The Board of Supervisors Contra county ft*ni*nat w Buil "' "+' 651 piney Str"t,Room 106 Costa +� (510)396.1900 Mardrwz,callomia 04553-1Z* County J6n �,iat ClisLitx 01ryM!1.iJlgcstrrr,2rx1 DtKrid D Wma i�lrbrrr,Std E7kUict �r 'T Yiwit Dom,b16 OtsttW� RAr J"lbs,&h Owtft .x» June 23, 1998 Mr.Lester Snow, Executive Director CALFED Bay-Delta Program 1416 Ninth Street, Suite 1155 Sacramento, CA 95814 Ile: Comments on the Draft EIWS for the CALFED Bay-Delta Program Bear Mr. Snow: The Contra Costa County Board of Supervisors supports the efforts of the CALFED Bay-Delta Program to identify and implement comprehensive solutions to the various problems associated with the Bay-Delta system, and believe that the plan contained in the Draft EIRIS is properly ambitious and contains elements which are of significant value. However,we are concerned that the CALFED program will propose drastic and probably damaging changes to the delivery of water through the Delta and only modest changes to other aspects of the Delta system that are more important to its long terra health. To be more explicit,the Board of Sppemisora does not a=W construction of an igQlated fWW gl Ri2di=to gm=water Dom,and urges the CALFED program to focus instead on maintaining the common Delta pool,on increasing fresh water flows to and through the Delta,on,comprehensively addressing the causes of Delta pollution,on restoring the once-great fisheries of our region,and on improving the recreational and educational opportunities available to study and enjoy this important state'-wide resource. As CALFED revises the Draft EIR/S to develop a draft preferred alternative and a revised environmental document,we strongly recommend the following: • Select Conveyance Alternative 2, Improved Through-Delta Conveyance, as the preferred conveyance alternative:Modifying Delta channels to improve the flow of water through the Delta will improve water quality both in the Delta and at the state and federal pumps. We see no justification for constructing an isolated canal to move the state and federal water project diversion points out of the Delta, and assert that any solution which endorses such a concept will only aggravate the very problems it purports to solve. Maintaining the Delta as a common pool for agricultural, environmental, and urban uses ensures a balanced distribution of resources which is far more binding and dependable than any agreement which calls for an isolated transfer facility. Mr.Lester Snow DRAFT June 23, 1998 Page 2 of 3 • Strengthen the Water Quality Program by establishing enforceable performance criteria: As currently written, CALFED's Water Quality Program includes broad, commendable goals for improving water quality in the Delta, but lacks any description of how this will occur. In particular, the Water Quality Program does not contain a specific plan for reducing the serious water quality problems caused by the discharge of agricultural drainage from San Joaquin Valley to the Delta. This component must be strengthened to assure that such goals, many of which are already stated within state regulations, will be achieved in the near future. • Define a specific financing strategy which fairly assigns costs based on benefits: The financing package now only analyzes options, and a specific financing plan will be needed before much of the program can be supported. This more detailed plan must ensure that storage and conveyance facilities are primarily funded by those parties which would most benefit from them,namely those areas which export water from the Delta. • Define a package of assurances which specifically states how facilities will be operated and how water quality, freshwater flows, and fisheries will be protected: Creating an acceptable solution will require strong assurances to all partiesthat plans will be implemented as described. A crucial part of this will be assuring that new storage and new conveyance facilities will be operated in a responsible manner and will protect water quality, flows, and fisheries. As another example, CALFED should also provide assurances that water entitlements purchased from farmers in the Delta will be used to maintain freshwater flows to the Delta and not used to increase exports to the south. • Improve the Water Use Efficiency Program to ensure that existing water supplies are used as efficiently as possible before additional water supplies are developed: Water use efficiency guidelines for agriculture must be enforceable to be consistent with the enforceable guidelines established for urban users. • Select a storage alternative which maximizes freshwater flows for fish and minimizes environmental impacts:New storage is needed to provide for expected population growth, operational flexibility, emergency reserves, and increased opportunities for boosting freshwater flows through the Delta during critical periods. However, such storage should be as environmentally benign as possible. Storage plans should include conjunctive use of groundwater and should restrict new diversions to periods of extremely high flows. • Refine the Ecosystem Restoration Plan to maintain ambitious restoration goals while minimizing and mitigating impacts to Delta agriculture. • Identify means for improving public recreation and public education opportunities in the Delta. e15/ /y Mr. Lester Snow June 23, 1998 Page 3 of 3 Thank you in advance for your thorough consideration of these recommendations. We believe it is vitally important that CALFED succeed in its difficult mission to solve the long-standing problems with Bay-Delta, and we hope that the substantial progress you have made to date can continue through this crucial period in the process. County staff will be sending more detailed comments on specific aspects of the Draft EMEIS under separate cover. Please feel free to contact John Kopchik in our Community Development Department at (925) 335-1227 if you should have any questions on this or other correspondence from the County. Sincerely, DRAFT Jim Rogers, Chair Contra Costa County Board of Supervisors .R..rx H:\jkopc\cWeirs.com BOWhSW The Bard of Supervisors Contra PM Of Ow&Am County Administration Sodding Ca y A**ft t W 651 Pins,fit,Rwm 106 Costa (310)385-19M Maftfnez,Ceii#omia 94553-1 County , „tom*,fst 0 fiiRyM�.tt .Ott ,..i. '�,. '•. Domm O el W*d D*t Ct Us*006ft Ar,401 Dist A g Jw�,tiih Dirbict c A C � June 23, 1998 Mr.Lester Snow, Executive Director CALFED Bay-Delta Program 1416 Ninth Street, Suite 1155 Sacramento,CA 95814 Re: Comments on the Draft EIR/S for the CALFED Bay-Delta program Dear Mr. Snow: The Contra Costa County Board of Supervisors supports the efforts of the CALFED Bay-Delta Program to identify and implement comprehensive solutions to the various problems associated with the Say-Delta system,and believe that the plan contained in the Draft EIWS is properly ambitious and contains elements which are of significant value. However,we are concerned that the CALFED program will propose drastic and probably damaging changes to the delivery of water through the Delta and only modest changes to other aspects of the Delta system that are more important to its long term health. To be more explicit,the BQXJ of iollated camleo gmygy water frm the Sacramentoe Delt&and urges the CALFED program to focus instead on maintaining the common Delta pool, on increasing fresh water flows to and through the Delta,on comprehensively addressing the causes of Delta pollution,on restoring the once-great fisheries of our region,and on improving the recreational and educational opportunities available to study and enjoy this important state-wide resource. As CALFED revises the Draft EIWS to develop a draft preferred alternative and a revised environmental document,we strongly recommend the following: Select Conveyance Alternative 2, Improved Through-Delta Conveyance, as the preferred conveyance alternative.Modifying Delta channels to improve the flow of water through the Delta will improve water quality both in the Delta and at the state and federal pumps. We see no justification for constructing an isolated canal to move the state and federal water project diversion points out of the Delta, and assert that any solution which endorses such a concept will only aggravate the very problems it purports to solve. Maintaining the Delta as a common pool for agricultural, environmental, and urban uses ensures a balanced distribution of resources which is far more binding and dependable than any agreement which calls for an isolated transfer facility. Mr.Lester Snow June 23, 1998 Page 2 of 3 • Strengthen the Water Quality Program by establishing enforceable performance criteria: As currently written, CALFED's Water Quality Program includes broad, commendable goals for improving water quality in the Delta, but lacks any description of how this will occur. In particular, the Water Quality Program does not contain a specific plan for reducing the serious water quality problems caused by the discharge of agricultural drainage from San Joaquin''Dalley to the Delta. This component must be strengthened to assure that such goals, many of which are already stated within state regulations, will be achieved in the near future. Define a specific financing strategy which fairly assigns casts based on benefits: The financing package now only analyzes options, and a specific financing plan will be needed before much of the program can be supported. This more detailed plan must ensure that storage and conveyance facilities are primarily funded by those parties which would most benefit from them,namely those areas which export water from the Delta. • Define a package of assurances which specifically states how facilitieswill be operated and how water quality, freshwater flows, and fisheries will be protected: Creating an acceptable .solution will require strong assurances to all parties that plans will be implemented as described. A crucial part of this will be assuring that neve storage and new conveyance facilities will be operated in a responsible manner and will protect water quality, flows, and fisheries. As another example, CALFED should also provide assurances that water entitlements purchased from farmers in the Delta will be used to maintain freshwater flows to the Delta and not used to increase exports to the south. • Improve the Water Use Efficiency Program to ensure that existing water supplies are used as efficiently as possible before additional water supplies are developed: Water use efficiency guidelines for agriculture must be enforceable to be consistent with the enforceable guidelines established for urban users. • Select a storage alternative which maximizes freshwater flows for fish and minimizes environmental Impacts:New storage is needed to provide for expected population growth, operational flexibility, emergency reserves, and increased opportunities for boosting freshwater flows through the Delta during critical periods. However, such storage should be as environmentally benignn as possible. Storage plans should include conjunctive use of groundwater and should restrict new diversions to periods of extremely High flows. • Refine the Ecosystem Restoration flan to maintain ambitious restoration goals while minimizing and mitigating impacts to Delta agriculture. • identify means for improving public recreation and public education opportunities in the Delta, e../4S Mr. Lester Snow June 23, 1998 Page 3 of 3 Thank you in advance for your thorough consideration of these recommendations. We believe it is vitally important that CALVED succeed in its difficult mission to solve the long-standing problems with Bay-Delta, and we hope that the substantial progress you have made to date can continue through this crucial period in the process. County staff will be sending more detailed comments on specific aspects of the Draft EER/EIS under separate cover. please feel free to contact John K.opchik in our Community Development Department at (925) 335-1227 if you should have any questions on this or other correspondence from the County. Sincerely, t Jiin Rogers, Chair Contra Costa County Board of Supervisors fR:JK H:\jkopcldedeirs.com