Zachary Simmons, Project Manager
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Zachary Simmons, Project Manager US Army Corps of Engineers, Sacramento District 1325 J Street, Room 1350 Sacramento, California 95814-2922 Email: [email protected] 916-557-6746 Comments: Reference Public Notice SPK-2008-00861 Mailed and submitted online on November 9, 2015 Re: Draft Bay Delta Conservation Plan and associated Draft Environmental Impact Report/Environmental Impact Statement renamed as “WaterFix” and “EcoFix”, (i.e. the Tunnel of Lies) with background data and studies filed under CalFED and various CA Dept or Resources proposals. Specific chapters or topics: Water flow and exports through the Delta; baseline data used for computer modeling; current impacts; flood flow risk; negative impacts to native aquatic fish species; hindrance or blockage of navigation on listed navigable waterways of the Delta Specific focus chapter link: http://baydeltaconservationplan.com/Libraries/Dynamic_Document_Library/Public_Draft_BDCP_EIR- EIS_Chapter_5_-_Water_Supply.sflb.ashx Re: Request for public hearings conducted by and for USACE decision makers to hear the concerns of the most affected persons from the plan, with multiple public meeting to be held in the Legal Delta Region at or near proposed construction sites if at all possible. Submitted by Nicole S. Suard, Esq. Managing Member, Snug Harbor Resorts, LLC located on historic Steamboat Slough a tributary of the Sacramento River in the North Delta region. [email protected] http://www.snugharbor.net A copy of this letter, the referenced attachments, screen prints and timeline will be uploaded for online viewing to http://www.snugharbor.net/bdcpcomments.htm Dear Mr. Simmons, Project Manager, USACE, and the Decision Makers of USACE: These comments are submitted by an in-Delta land and business owner who has lived through the “on the ground” environmental combat zone that is the current California Delta Region. I do not need to guess probable impacts on the affected aquatic environment and the secondary or cumulative effects because I can describe the real life impacts already happening based on the flow changes and “restoration” test sites along Steamboat Slough and other North Delta waterways. Some of the proposed actions of the BDCP/WaterFix/EcoFix will create new hazards to navigation, could create greater risk of flooding in some areas of the North Delta, would accelerate further degradation of native aquatic species, and would put freshwater wells of residents and businesses in the Delta and San Francisco Bay area at risk of permanent destruction. What BDCP/DWR computer modeling says and what are real life experiences are two very different matters. I am also concerned that USACE Decision Makers may not be utilizing correct baseline data when making decisions, because so much of the data used by BDCP/WaterFix/EcoFix proponents is verifiably incorrect baseline data. USACE comments on BDCP/WaterFix/EcoFix Public Notice SPK-2008-00861 Page 1 I would hope USACE prefers to make decisions based on reality and not incorrect assumptions based on false baseline data. Given the very substantial negative impact to humans, aquatic species, agriculture, transportation, air quality, navigation and flood control for millions of us in the Bay and Delta, I am requesting that USACE hold numerous open mike public comment meetings in each and every major city in the state of California, as well as public comment meetings, with open mike, within the primary Delta region, the area likely to be most negatively impacted by the proposed plans of BDCP/WaterFix/EcoFix. Please do not approve any more plans affecting California water diversions and changes to flood flow management until you have truly listened to those most affected, and reviewed the documents to check for accuracy, particularly the computer modeling for flow, exports, flood, salmon migration and salinity impacts. There simply is not enough water flow on the Sacramento River to allow for the volume of export water required to validate the cost of construction of the tunnels, and also protect the Delta and Bay and Northern California surrounding agricultural land uses. If unbiased scientists and water engineers reviewed the baseline data used for the computer modeling to validate the proposed plan, I believe your scientists and water engineers would find the current proposal to be a Tunnel of Lies. Who am I, a non-scientist who is challenging the veracity of DWR/MWD baseline data? I am a 4th generation Californian with home, land and business in the Bay/Delta, and I have been collecting old California maps for years. I am a California attorney as well. My Delta business is located on Steamboat Slough, a natural navigable waterway in the North Delta, which was often noted in books and maps from the 1850s to current publications. I have found it quite offensive to watch as MWD, DWR, Delta Vision, DSC and USBR document drafters have repeatedly erased Delta waterways from planning maps or changed the names of Delta islands or waterways either out of carelessness or ignorance or by calculated intention to misinform the persons reviewing the particular report. I started collecting examples of the “Wrong Maps of the Delta” which began to emerge in the public forum of the internet in 2005, and can show very specific examples of how the incorrect location of a specific island or waterway was used to create false impressions or reports that are still referred to by DWR/BDCP/DSC, which has a negative impact on the persons and environment of those specific areas.1 I am therefore requesting that each Decision Maker from USACE start with a correct map of the Delta, including the waterway names2, the island names, and the actual roads used in the Delta, so that you will better understand the realities of impacts here in the Delta. I suggest that the Decision Makers take the time to get on a boat and explore the different areas of the Delta, as you will find the North Delta is very different from the Central and South Delta naturally, due to climate and natural freshwater quality differences. One very obvious difference is historically the existence of tall or mature oak and sycamore trees along levee banks in the North Delta, as pictured in a sketch from and 1860s book by A. Hutchings, one of the first California newspaper publishers.3 Note that historically a section of the Sacramento River in the North Delta was referred to as “Old River” so when you read pre-1930s reports about impacts to “Old River” please use a map to determine if the reference is related to “Old River” Sacramento or “Old River” off the San Joaquin River in the Central Delta area. 1 http://deltarevision.com/wrong-maps-of-the-delta.html and http://deltarevision.com/Issues/wrong_maps_data/wrongmaps/waterways/03-Waterways.pdf 2 http://snugharbor.net/images-2013/deltastuff/wrongdeltanames.pdf 3 http://www.yosemite.ca.us/library/scenes_of_wonder_and_curiosity/alabaster_cave.htmlAnd http://deltarevision.com/1840-1879_docs/00894049.jpg USACE comments on BDCP/WaterFix/EcoFix Public Notice SPK-2008-00861 Page 2 I first learned of the plans to revise California’s plumbing system, Delta included, in August 2008, at a meeting at the Ryde Hotel were Delta citizens were introduced to the “Delta Vision” Plan. Delta Vision documents contained several important false statements regarding Delta history, Delta flows and Delta use. Data for the Delta Vision incorrect data came from another previously unknown (to me) document series, the DRMS Phase 1 Report4, and also the Flooded Islands Feasibilities reports5. Upon review of the technical data for DRMS Phase 1, by myself and many other concerned Delta and California citizens, it was established the baseline data used for DRMS Phase 1, and therefore Delta Vision, the “Pulse of the Bay-Delta”, and other publications also all were based on the false baseline data6. The BDCP thereafter utilized and built upon the false data with the result that in several important areas or topics the BDCP starts with incorrect baselines and then compounds the mistake by continuing to build on the false data. DWR representatives were advised of some of the false data in use; however Delta Vision and DWR spokespersons continued to intentionally spread the false data for media purposes, and intentionally distributed the false data to other “scientists” and organizations such that there is an expanding library of evidence showing how the false data has been used, and its impact on the decisions leading up to the issuance of the draft BDCP. The BDCP is or may be a component of the overall new California Water plan7. Both document series start with the false baseline data regarding Delta history and some Delta current status, and utilized computer modeling to validate to desired or proposed outcomes. However, when you start with false data entered into a computer program, the outcome is logically based on false data. This comment paper will focus on specific data that was published by DWR and its consultant URS, and how the false or incorrect data has been incorporated into BDCP document and decisions which impact the Delta. In addition to starting with false baselines, the BDCP drafters have failed to recognize and address substantial impacts to the Delta; impacts include the recent past 4 http://www.water.ca.gov/floodsafe/fessro/levees/drms/phase1_information.cfm# 2007 data tab and 2009 data tab 5 http://www.water.ca.gov/frankstract/docs/%284%29Flooded%20Islands%20Baseline%20Report.pdf page 24 6 http://ryerisland.com/DRMS_wrong_on_ryer_island.htm 7 http://www.water.ca.gov search 2013 Water Plan Update USACE comments on BDCP/WaterFix/EcoFix Public Notice SPK-2008-00861 Page 3 impacts during the BDCP and CALFED site test studies, the near future impacts during proposed end-stage construction, and the long term impacts on the Delta, San Francisco Bay and Northern California especially focused on recharge of drinking water aquifers and long range water rights.