The Hon. Ken Salazar
U.S. Department of the Interior
The Hon. Rebecca Blank
U.S. Department of Commerce
Dear Secretary Salazar and Acting Secretary Blank:
As you know, we were recently briefed on a proposal to retool the Bay Delta Conservation Plan (BDCP). It is our understanding that this revised proposal is designed to respond to the warnings from state and federal agencies that earlier versions of the plan would not meet statutory requirements.
However, the new proposal raises far more questions than it answers, and appears to turn the maxim of "policy before plumbing" on its head. We ask that you not finalize or formally announce this framework until a far more detailed description is made available for review.
Since the BDCP process began in 2006, we have warned that a poorly designed plan would cause significant disruptions to northern California and could increase water exports from the Bay-Delta estuary -- while failing to restore the Bay-Delta ecosystem and rebuild salmon and other California fisheries as required by law. Our concerns have been echoed by northern California water agencies, flood control districts, cities, counties, the commercial and recreational fishing industries, and conservation groups.
We agree that the BDCP requires a significant overhaul if it is to succeed, and we genuinely appreciate the efforts that your departments and agencies have dedicated to the recent revisions. However, we do not believe it is wise to commit to massive new water pumping stations and conveyance tunnels while sustainable solutions to the problems of water quality, fish and ecosystem restoration, local impacts, and water flows are made to wait. Furthermore, we have not yet seen an explanation of how this "plumbing before policy" approach would be made consistent with applicable state or federal law.
There is too much at stake in the BDCP for the federal government to announce a plan that defers important decisions while an expensive and potentially damaging water diversion project is allowed to proceed.
Thank you for your attention to our concerns. We look forward to reviewing a detailed proposal and hope to work with you to improve this process further.