CSPA's Bill Jennings

However, Jennings, commenting for CSPA, found numerous and fatal flaws in the plan as it is now proposed. Among those are the inconsistencies of protecting and restoring listed species and a conveyance plan involving a massive public works project that will change the hydrology of the estuary and tributary waterways. Further, the plan guarantees water delivery to the south state, a basic inconsistency with habitat preservation. The plan does not consider recent court rulings regarding the Endangered Species Act and does not conform to the governor's Delta Vision statement. Numerous other faults were found which lead Jennings to conclude, "The plan is little more than a Bay-Delta Conveyance Plan masquerading as an HCP."

A list of recommendations for revision were submitted which include that the plan, "Incorporate a comprehensive ecological analysis," to identify targeted species, identify and evaluate alternative water supplies and delivery systems, analyze and quantify the Delta needs, and propose full mitigation for "take" of species protected pursuant to the California Endangered Species Act. A number of additional recommendations were made regarding water sources, flow and their effect on the delta and the habitat of the creatures living there.

Summing up, Mr. Jennings stated, "The enormous and unprecedented scope of the proposed scheme will require the most ambitious and detailed environmental document ever assembled."

The complete document may be found at: Scoping Comments for the EIR/EIS for the Sacramento-San Joaquin Bay Delta Conservation Plan