Despite these ambiguities, the draft BDCP has concluded that an “isolated conveyance facility” should be constructed consisting of a 45-mile tunnel or pipeline, capable of conveying 15,000 cubic feet per second (cfs) of Sacramento River water around the Delta to the south Delta’s existing water export pumping plants, to allow for“dual operation” with the existing south Delta diversion facilities (draft BDCP, Chapter 4.2.2.1.1 and Table 4-1). (Again, the “note to reviewers” on p. 4-14 of the draft BDCP suggests that the conveyance system might be a canal, but there is no analysis of a canal in the draft BDCP or even a statement as to whether the findings from the analysis of a canal would differ from the analysis of a tunnel system.)

Alternative Actions

To support the issuance of an ESA § 10 take permit, the BDCP must specify “what alternative actions to such taking the applicants considered and the reasons why such alternatives are not being utilized” (ESA § 10, 16 U.S.C. § 1539(a)(2)(A)). Even if the proposed action has been decided on, an analysis of alternatives is still required. This analysis does not appear prominently in the draft BDCP. Not only is the analysis a legal requirement, but it also is important scientifically, because to the degree that the reasons for not utilizing the alternatives are scientific reasons, the absence of the analysis hinders the ability to evaluate the BDCP’s use of science. If the BDCP also seeks incorporation into the Delta Plan (and thereby qualifying for state funding of public benefits), then it should also include an analysis of “conveyance” alternatives. As a prerequisite to incorporation, the BDCP must undertake “a comprehensive review and analysis of . . . [a] reasonable range of Delta conveyance alternatives, including through-Delta, dual conveyance, and isolated conveyance alternatives and including further capacity and design options of a lined canal, an unlined canal, and pipelines” (Cal. Water Code, § 85320). Finally, the federal approval process also will require an environmental impact statement that considers alternatives to the “proposed action,” which includes construction of the alternative conveyance (National Environmental Policy Act, 42 U.S.C. § 4332(2)(C)(iii)). Once again, this legally required analysis of alternatives is scientifically important. Therefore, to permit a complete scientific evaluation of the BDCP, it should include an analysis of such alternatives to “take”and to the construction and design of the contemplated isolated conveyance.



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