United States House of Representatives
Washington DC 20515
July 13, 2015
Dear Members of Congress:
The undersigned conservation and recreation organizations, outdoor businesses, and Native American Tribes urge you to reject Rep. Valadao’s H.R. 2898. Under the guise of water and food “security,” H.R. 2898 proposes to maximize water exports, and weaken regulations protecting threatened and endangered fish and wildlife in California.
Passage and implementation of this complex legislation will almost certainly result in the extinction of the endangered Delta smelt in its native habitat and accelerate the already precipitous decline of the Central Valley’s wild salmon and steelhead towards extinction. It will also further degrade Delta water quality (the drinking water source for millions of Californians) and harm rural and urban communities throughout the state, while primarily benefitting just a few water districts in the southern Central Valley.
H.R. 2898 fails to provide real water and food security because of its narrow focus on maximizing water exports and expediting costly, ineffective, and environmentally destructive new dam projects. These water options cannot produce new water supplies in this unprecedented fourth year of drought (no matter how quickly they may be
implemented) and they may never be able to produce new supplies with our changing (and likely to be drier) climate.
Just a few of the most egregious provisions of H.R. 2898 include:
- Complex technical direction for Delta water flows, upstream dam project operations, and Delta smelt incidental take calculations for which Congress has neither the expertise or authority to undertake (Sec. 102-103, 302-307).
- Selective use of alleged “new” science to mandate a non-federal fish predator control program that fails to address the many significant habitat and water quality issues – including blocked habitat, lack of spawning gravel, modified flows, high water temperatures, low dissolved oxygen levels, and high concentrations of pesticides – that have largely contributed to the decline of salmon in the Stanislaus River (Sec. 203).
- Mandate impossibly short deadlines for endangered species consultation, emergency environmental review and permitting, and expedited water transfers that will likely result in poor decisions, unacceptable environmental impacts, and increased litigation (Sec. 302, 305, 308, 309).
- Allow all the fresh water inflow from the San Joaquin River to be exported in April-May, which will further degrade Delta water quality, and expand water transfers well into the spring and fall, when threatened and endangered salmon and steelhead are most sensitive to modified flows (Sec. 302).
- Overturn a significant public investment in the legally and legislatively mandated goal of restoring salmon in the San Joaquin River in favor of an undefined “warm water fishery” (Sec. 313).
- Establish impossibly short deadlines for the completion of feasibility and environmental studies for CALFED dam projects and penalizes the Bureau of Reclamation if the deadlines are not met, which all but ensures that the studies will be incomplete or inadequate (Sec. 401, 403).
- Prohibit the Interior Secretary from discharging her duties under the National Wild & Scenic Rivers Act to protect the San Joaquin River Gorge, a river segment recommended by the Bureau of Land Management for National Wild & Scenic River protection (Sec. 402).
- Ignore the coordinated operation of state and federal water projects and weaken state protection for endangered species by promising additional water yield from federal sources to make up for state water delivery reductions that may be required by the California Endangered Species Act (Sec. 501).
- Make it nearly impossible to keep promise of no redirected adverse impacts on water rights in regard to Endangered Species Act compliance and other legal obligations (Sec. 503).
- Generally infringe on state water rights authority by guaranteeing full delivery of federal north of Delta water contracts in most water years (Sec. 505).
- Establish an oversight board for the expenditure of CVPIA restoration funds with nearly exclusive representation from water contractors and no representation from the U.S. Fish and Wildlife Service or the general public (Sec. 602).
- Penalize the Bureau of Reclamation for failing to complete and implement a CVPIA water replacement plan that is simply infeasible and fails to recognize that the state has likely reached its limit in regard to new water development (Sec. 604).
- Ordain that federal agencies not “distinguish” between naturally and hatchery spawned anadromous fish species when making endangered species determinations, despite substantial biological opinions to the contrary (Sec. 605).
- Transfer ownership and operational control of the federal New Melones Dam, in which million in public funds have been invested, to local water and power providers, apparently at no cost (Sec. 606).
- Prohibit water releases into the Trinity River that may be needed to prevent a repeat of the massive salmon die-off in the Klamath River that occurred in 2002 (Sec. 608).
- Establish unreasonable deadlines for the completion of environmental studies and for federal cooperating agencies to fulfill their legal duties in regard to reviewing and commenting on new dam projects (Sec. 705).
- “Streamline” and accelerate feasibility studies, environmental review, and permitting for new dam projects in a manner that will likely fail to identify financially and environmentally feasible alternatives and result in inadequate reports and poor decisions (Sec. 803-805).
- Fail to explicitly protect Sacramento Valley groundwater aquifers, which will likely increase pumping and export of north state groundwater south of the Delta.
Instead of passing this one-sided and environmentally destructive bill, we urge you instead to introduce and pass true drought relief legislation for California that protects water quality, aquatic ecosystems, and native fish and wildlife in our rivers and estuaries, while providing effective and timely relief to California communities, industry, and farms.
Effective drought relief legislation should focus on those immediate actions that will extend our existing supplies, reverse the near total loss of wild salmon runs, boost water conservation and efficiency, provide immediate relief for economically disadvantaged communities and neighborhoods that have run out of water, help mitigate the economic impacts of reduced water deliveries to farms, and encourage the permanent establishment of fundamental and long term changes in how water is managed and used in California.
We believe that this goal is achievable only if the drought relief bill is drafted in public with the full participation of and input from all of California’s water stakeholders.
California does need federal assistance and relief from this devastating drought. But Congress should not make this situation worse by passing drought relief legislation that overrides environmental laws, weakens state water rights authority, pits different regions of the state and different water users against each other, and focuses on the most costly and environmentally destructive water supply option (surface storage) that will provide little immediate drought relief.
Thank you for your consideration.
Sincerely,
Eric Wesselman
Executive Director ~ Friends of the River
1418 20th Street, Suite 100
Sacramento, CA 95811
eric@friendsoftheriver.org
S. Craig Tucker
Natural Resources Policy Advocate ~
Karuk Tribe
P.O. Box 1016, Happy Camp, CA 96039
ctucker@karuk.us
Caleen Sisk
Spiritual Leader and Tribal Chief ~
Winnemem Wintu Tribe
14840 Bear Mountain Road, Redding, CA 96003
caleenwintu@gmail.com
Kyle Jones
Sierra Club California
12th Street, Suite 202, Sacramento, CA 95814
kyle.jones@sierraclub.org
Sage Sweetwood, Excutive Director ~
Planning and Conservation League
1107 9th Street, Suite 901
Sacramento, CA 95814
sage@pcl.org
Cindy Charles
Golden Gate Women Flyfishers
1940 Sacramento Street #6
San Francisco, CA 94109
cindy@ccharles.net
Barbara Barrigan-Parilla
Executive Director ~ Restore the Delta
10100 Trinity Parkway, Suite 120
Stockton, CA 95219
Barbara@restorethedelta.org
Conner Everts
Facilitator ~ Environmental Water Caucus
Director ~ Southern California Watersheds
Alliance
Co-Chair ~ Desal Response Group
120 Broadway, Suite 105
Santa Monica, CA 90401
connere@gmail.com
Carolee Krieger
President ~ California Water Impact Network
808 Romero Canyon Road
Santa Barbara, CA 93108
caroleekrieger7@gmail.com
Tim Sloane, Executive Director ~ Pacific Coast
Federation of Fishermen’s Associations
P.O. Box 29370, San Francisco, CA 94129
tsloane@ifrfish.org
Bill Jennings, Executive Director ~
California Sportfishing Protection Alliance
3536 Rainier Avenue, Stockton, CA 95204
deltakeep@me.com
Dave Steindorf
California Stewardship Director ~
American Whitewater
4 Baroni Drive, Chico, CA 95928
dave@americanwhitewater.org
Peter Drekmeier
Policy Director ~ Tuolumne River Trust
312 Sutter Street, Suite 402
San Francisco, CA 94108
peter@tuolumne.org
Cecily Smith
Executive Director ~ Foothill Conservancy
35 Court St, Ste 1, Jackson, CA 95642
Cecily@foothillconservancy.org
Spreck Rosekrans
Executive Director ~ Restore Hetch Hetchy
P.O. Box 71502, Oakland, CA 94612
spreck@hetchhetchy.org
Scott Greacen
Executive Director ~ Friends of the Eel River
P.O. Box 4945, Arcata, CA 95518
scott@eelriver.org
Dan Ehresman
Executive Director ~
Northcoast Environmental Center
1385 8th Street, Suite 226, Arcata, CA 95521
dan@yournec.org
Ryan Henson, Senior Conservation Director ~
California Wilderness Coalition
3313 Nathan Drive, Anderson, CA 96007
rhenson@calwild.org
Tim Woodall
President ~ Protect American River Canyons
148 Court Street, Auburn, CA 95603
twoodall@leuppwoodall.com
Dr. Michael Martin, Chairman ~
Merced River Conservation Committee
P.O. Box 2216, Mariposa, CA 95338
mmartin@sti.net
Lowell Ashbaugh
Conservation Vice-President ~ Northern California
Council Federation of Fly Fishers
677 Equador Place, Davis, CA 95616
ashbaugh.lowell@gmail ~ NCCFFF.org
Stephen Green
President ~ Save the American River Association
4441 Auburn Boulevard, Suite H,
Sacramento, CA 95841
gsg444@sbcglobal.net
Don Rivenes
Executive Director ~ Forest Issues Group
108 Bridger Court, Grass Valley, CA 95945
rivenes@sbcglobal.net
Dr. Mark Rockwell
California State Representative ~ Endangered
Species Coalition
19737 Wildwood West Drive
Penn Valley, CA 95946
mrockwell@endangered.org
Larry Hanson
Manager ~ California River Watch
P.O. Box 816, Sebastopol, CA 95472
larryjhanson@comcast.net
Robyn DiFalco
Executive Director ~ Butte Environmental Council
116 W. Second Street, Suite 3, Chico, CA 95928
robynd@becnet.org
Richard Pool
President ~ Water4Fish
P.O. Box 5788, Concord, CA 94524
rbpool@protroll.com
Roger Thomas
President ~ Golden Gate Fishermen’s Association
50 Briarwood, San Rafael, CA 94901
suedupuis@aol.com
Frank Egger
President ~ North Coast Rivers Alliance
13 Meadow Way, Fairfax, CA 94930
fjegger@gmail.com
Alan Levine
Director ~ Coast Action Group
126 Steiner Court, Santa Rosa, CA 95404
alevine@mcn.org
Barbara Vlamis
Executive Director ~ AquAlliance
P.O. Box 4024, Chico, CA 95928
barbarav@aqualliance.net
Nate Rangel, President ~ California Outdoors
Adventure Connection
P.O. Box 476, Coloma, CA 95613
Nate@raftcalifornia.org
Dan Buckley
Owner ~ Tributary Whitewater Tours
P.O. Box 728, Weimar, CA 95736
rafting@whitewatertours.com
John Buckley, Executive director ~ Central Sierra
Environmental Resource Center
P.O. Box 396 Twain Harte, CA 95383
johnb@cserc.org
George Wendt
President ~ The O.A.R.S. Family of Companies
P.O. Box 67, Angels Camp, CA 95222
georgew@oars.com
Stephen Liles
President ~ W.E.T. River Trips, LLC
P.O. Box 160024, Sacramento, CA 95816
Liles.stephen@gmail.com
Marty McDonnell
Owner ~ Sierra Mac River Trips
P.O. Box 264, Goverland, CA 95321
marty@sierramac.com
Steve Welch
General Manager ~ A.R.T.A. River Trips
2400 Casa Loma Road, Groveland, CA 95321
steve@arta.org
Keith Miller
President ~ California Canoe & Kayak
409 Water Street, Oakland, CA 94607
keith@calkayak.com
Caleb Dardick, Executive Director ~
South Yuba River Citizens League
216 Main Street, Nevada City, California 95959
caleb@syrcl.org
Steve Schramm, Conservation Chair ~
Mission Peak Fly Anglers
reelsafari@yahoo.com
John McManus, Executive Director ~
Golden Gate Salmon Association
1370 Auto Center Drive, Petaluma, CA 94952
john@goldengatesalmon.org
Bob Ferguson, President ~
Zephyr River Expeditions, Inc
P.O. Box 510, Columbia, Ca. 95310
raft@zrafting
Lloyd Carter
California Save Our Streams Council
2863 Everglade Avenue, Clovis, CA 93619
lcarter0i@comcast.net
Lucas Merz, Executive Director ~
Sacramento River Preservation Trust
631 Flume St., Chico, CA, 95928
lucas@sacrivertrust.org
Jim Walker, President ~
San Joaquin River Gorge Trailriders
34385 Tollhouse Rd Auberry CA 93602
56jmwalker@gmail.com