As the State prepares to release the public draft of the Bay Delta Conservation Plan (BDCP) and draft EIS/EIR next month, the public deserves to get accurate information on the potential benefits, costs, and impacts of BDCP and alternatives. This is one of the essential purposes of NEPA and CEQA, to ensure that decision-makers and the public can make informed decisions on the costs and benefits of a project and compare it to other alternatives. The NEPA/CEQA process is aimed at improving projects by reducing their environmental and social impacts.
At the beginning of 2013, NRDC released an alternative to the State’s dual tunnel proposal. Known as the Portfolio Alternative, our proposal combines a single, new water intake and single tunnel under the Delta, with investments in local water supply development, levee improvements, and South of Delta storage. Numerous water districts, newspaper editorials, and elected officials have requested that the Portfolio Alternative be given a fair shot by analyzing it seriously in the BDCP EIS/EIR. But last month the Secretary for Natural Resources wrote a letter to the San Diego County Water Authority rejecting the request to analyze the Portfolio Alternative, claiming that “the fundamental premise that cost savings from building a smaller facility could generate funding for substantial and adequate investments in other regional and local water supply to meet California’s future water needs does not bear out.” The Secretary based this claim on the State’s assertion that a 3,000 cfs facility with a single tunnel only saved $3 billion compared to the state’s proposed 9,000 cfs, dual tunnel facility.
However, after NRDC reviewed documents provided by the State to justify the cost estimates in the Secretary’s letter, we discovered that the State had substituted the cost of a 3,000 cfs dual tunnel facility for the cost of a 3,000 cfs single tunnel project, providing misleading information about the cost of the Portfolio Alternative (overstating the cost of a single tunnel project by approximately $3 billion). Two days ago, the State admitted to the error in a blog post, and we appreciate them acknowledging the error and providing the following corrected cost estimates:
- 3,000 cfs single tunnel: $8.6 billion
- 9,000 cfs dual tunnel: $14.5 billion
The State made a similar error in the administrative draft BDCP documents, where they used the cost figures for a 3,000 cfs dual tunnel project to estimate the cost of a 3,000 cfs “tunnel” alternative in Chapter 9.B (Page 9.B-4). While consultants for the State have repeatedly said that the Portfolio Alternative was analyzed in Chapter 9, it’s clear that they were looking at a more expensive, dual tunnel project, and equally important, none of the alternatives in Chapter 9 of the BDCP documents or in the EIS/EIR include the benefits of investments in local water supplies, storage, and levees, as called for in the Portfolio Alternative.
Staff has told us that in the forthcoming public draft plan and DEIS/DEIR they will make clear that they are analyzing a dual tunnel project, not a single tunnel project like that described in the Portfolio Alternative. However, this isn’t the only example of the State providing biased analysis in BDCP; for instance, numerous state and federal agencies have publicly commented that the administrative draft of the draft plan and EIS/EIR provided misleading analysis that overstated the environmental benefits and understated the negative impacts of BDCP (see here, here, and here), conclusions that have been echoed by independent scientific reviews.
And unfortunately, the State still refuses to analyze the Portfolio Alternative in the BDCP DEIS/DEIR even though their basic rationale for rejecting it is now shown to be false. We will continue to press for further corrections to the letter to the San Diego County Water Authority regarding the Portfolio Alternative (some of our concerns were outlined here) and we will continue to press for a full evaluation of the Portfolio Alternative in the BDCP EIS/EIR, as numerous conservation groups, water districts, editorial boards, and state and federal elected officials have requested.
The public deserves honest information about the costs and benefits of BDCP and alternatives. That starts with honest information about the costs (including how much each water contractor will pay, so that the public can determine how much it will affect their water rates and property taxes), and honest information about the environmental effects. Ultimately, only with accurate information about the costs, benefits, and impacts of BDCP and alternatives can the public and decision-makers make an informed decision. We appreciate the State admitting to and correcting this error, and we’re going to make sure they correct the rest of them too. Let’s get the numbers right – this issue is too important not to.