Summary Position Statement of the Delta Coalition On the Bay Delta Conservation Plan and the Delta Plan

by coalitionadmin on March 15, 2012

Agriculture is the life-blood of the Delta with nearly 80% of all farmland classified as prime agricultural land.  Preserving and enhancing the Delta’s agricultural industry is vital to the region, the state, and the nation.  In calculating value-added manufacturing, the statewide impact of Delta agriculture is about 25,000 jobs, nearly $5.4 billion in economic output and over $2 billion in economic value.  The leading BDCP proposal is a direct threat to Delta’s agricultural based economy.

The Delta Coalition opposes the Bay Delta Conservation Plan (BDCP) and the Delta Stewardship Council’s (DSC) implementation of the enabling legislation (2009 Delta Water Package) regarding the Delta Plan for the following fundamental reasons:

COVERED ACTIONS

The regulation of land-use consistent with Federal and California law has always been, and should remain, within the control and responsibility of local government.  In making determinations whether covered actions are consistent with the Delta Plan, the DSC should only consider approved and funded flood control, water conveyance, and habitat projects identified in the Plan.  The review authority of the Delta Stewardship Council (“covered actions”) should be strictly limited to the specific appellate authority granted in the enabling legislation.

“Covered Actions” should exclude:

1)     Any plan, program, project or activity within the Secondary Zone of the Delta, which is consistent with an adopted General Plan, Sphere of Influence, Specific or Master Plan, Development Agreement, Subdivision Map, and/or other land use entitlement or permit, having received environmental certification under the California Environmental Quality Act, and/or which otherwise has “vested rights” in effect as of the effective date of the Delta Plan; and

2)     Non-conventional land use decisions, including, but not limited to, leases entered into by public agencies, dredging activities by the federal government or special districts to facilitate interstate or international commerce on navigable waterways of the United States, and resolutions of necessity adopted as a precursor to filing an eminent domain action.

WATER QUALITY, QUANTITY, AND ECOSYSTEM RESTORATION & PROTECTION

Existing water rights and laws must be continued and protected, including the “area of origin” laws and non-degradation policy of the State Water Resources Control Board, such that there is no deprivation of the water needed for present and future reasonable beneficial use in the areas where the water originates, including the Delta.  Improvements must be made in water quality for agriculture, and the restoration of fisheries and the ecosystem.

BDCP, DELTA PLAN/COST BENEFIT AND SCIENTIFIC ANALYSIS:

Delta Conveyance should continue to be based upon “common pool” and a through-Delta system.  Change to existing export project diversion points for conveyance methodology must include:

a)     Rigorous independent analysis of the costs and benefits of proposed action and a reasonable range of alternatives, including out-of-Delta “regional self-sufficiency” opportunities; and

b)     Rigorous independent scientific review and analysis of proposed actions and a reasonable range of alternatives, including out-of-Delta “regional self-sufficiency” opportunities.

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