Digest Version of my Delta Tunnels Comments

Comments on the Delta Tunnels environmental documents are due today.  Here is a summary of my comments, which focus on two issues that severely bias the analysis in favor of the tunnels.

• The analysis is based on a project description that is widely known to be economically unviable due to its minimal water yields.  Because of the tunnels extreme cost, the intention to pay for the tunnels through steep increases to water rates, and the fact that the tunnels design capacity allows for much higher water exports; a complete project description must include a financial analysis that shows the proposed water yields are economically viable (especially for agricultural users).  The lack of such a financial analysis and plan in the face of well-known questions about economic viability mean that the project description is at best incomplete, and at worst making false statements about intended levels of water exports in order to gain environmental approval.  

• Obvious alternative actions to building the tunnels are ignored in both the No Action scenario and the Alternative Scenarios.  Many of these actions have been repeatedly recognized by both the state and water agencies as either viable alternatives or their planned actions if the tunnels are not built.  The result is a No Action scenario that is unreasonably pessimistic about water supply reliability and environmental conditions, and an unreasonably weak and narrow set of alternatives.  The four most obvious alternatives ignored in the RDEIR/SDEIS are:
• Investment in Delta Levees: Multiple assessments sponsored by the California Resources Agency have identified this as a viable, and in many aspects preferable, alternative to the Tunnels.  Its total exclusion from RDEIR/SDEIS alternatives is unjustified.
• Increased Delta Flows and Reduced Exports for Environmental Benefits: This is the No Action Scenario DWR uses in previous economic analysis, and continues to argue is their expected outcome without the tunnels use when questioned on costs.  But the RDEIR/SDEIS invalidly and inconsistently ignores higher flows in either the No Action scenario or alternative scenarios.  
• Increased Investment in Alternative Water Supplies such as recycling, conservation, storm water capture, and desalination:  Many water agencies have stated that they will increase investment in alternative water supplies in the absence of the tunnels.  In fact this strategy is in the official resource management plan of some of the agencies, and water agencies have put forward economic analysis that describes much of the benefit of the tunnels as avoiding these obvious alternatives.  Thus, it is inexcusable to exclude increased investment inalternative water supplies from the No Action and alternative scenarios.
• Move the Intakes Downstream to the West Delta:  This is another obvious alternative that is ignored in the analysis.  It would reduce environmental and socio-economic impacts in the Delta and potentially reduce costs to the water agencies by greatly shortening the lengths of the tunnels.  While there are advantages to water exporters of being further upstream, there is no valid reason to completely exclude a full analysis of moving the intakes downstream.