1

Greene, Alicia M.

From: Veronese, Gina

Sent: Thursday, February 17, 2011 9:31 PM

To: Greene, Alicia M.

Subject: FW: water transfers

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Thursday, February 17, 2011 8:27 PM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: Fw: water transfers 

For record.

From: Bruce Meyer <btmeyer@chico.com> 

To: Hubbard, Bradley C 

Sent: Thu Feb 17 20:54:59 2011 

Subject: water transfers 

HelloMr. Hubbard,

 I appreciate the opportunity to respond to the Bureau's proposal of water transfers from Butte Co. I have three points 

to make:

 1) This is just a bad idea. Removing water from Butte Co. will jeopardize the quality of life in the area. The local 

population relies on the availability of water for its livelihood and survival. Replacing marketed surface water with 

pumped aquifer water can only lead to diminished supply and further compromise of communities that are already 

defined as "disadvantaged". 

 2) The legality of the proposal is in question. The original contracts with the water supplier (Bureau of Reclamation) 

surely prohibits the sell of water (provided by the Bureau) to a second agency. And if profit is involved, certainly the 

Bureau of Reclamation would not supply surface water to any agency and allow that agency to sell the provided water at a 

profit. 

 3) If this proposeal is allowed to go forward, an EIR would certainly be warranted to protect the residents of Butte Co. 

Determining withdrawl limits, monitoring consequences, and assessing liability are topics that would certainly have to be 

addressed. 

 At the Chico meeting on January 11, 2011, a number of questions went unanswered and in developing further 

conservation concerning this proposal I feel that the following 3 questions are pertinent: 

 1) Who initiated this proposal?

 2) Who are the proposed sellers and buyers?

 3) What guarantees do the residents of Butte Co. have in protecting their water supply?

Thank you for your attention to these concerns and I look forward to your response to my questions. 

 Sincerely, Bruce T. Meyer

 2045 Manzanita Ave. Chico, Ca. 95928
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Wednesday, January 19, 2011 9:54 AM

To: Greene, Alicia M.

Subject: FW: EIS/EIR Development for long term water transfers-public scoping

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Tuesday, January 18, 2011 4:37 PM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: FW: EIS/EIR Development for long term water transfers-public scoping 

Gina,  Here is another comment received.

Thanks,

Brad

From: rmeyers@digitalpath.net [mailto:rmeyers@digitalpath.net] 

Sent: Monday, January 17, 2011 1:29 PM 

To: Hubbard, Bradley C 

Subject: EIS/EIR Development for long term water transfers-public scoping 

Mr. Brad Hubbard 

Bureau of Reclamation 

Sacramento, Ca. 

 

“The mission of the Bureau of Reclamation is to manage, develop, and protect water and related resources 

in an environmentally and economically sound manner in the interest of the American public.” 

 

The “American Public” is a much broader and more important interest than the corporate farming interests 

represented by San Louis and Delta Mendota Water Authority. There are thousands of people in the north 

state that rely on the Tuscan Aquifer for their economic interests, environmental interests and for water for 

their home and farm use. Any proposal to pump groundwater in a sustained way to replace irrigation water 

previously obtained from surface water has been proven to affect the Tuscan Aquifer. In 1994 there was 

sustained pumping to replace water sold south and we had numerous well failures in the Durham area. Until 

long-term studies can prove that there will be no effect, no agency can claim there will be any mitigation 

that will work. I am personally dependant on a spring fed home water system, possibly linked to the Tuscan 

Aquifer. I live in the foothills outside of Oroville. When my spring fails because of sustained pumping of 

water from the Tuscan Aquifer will the Bureau of Reclamation find some way to mitigate that? 

 

The Bureau is involved in a court case right now challenging the EA and FONSI for the NEPA Document 

for the 2010-2011 CVP Water Transfers. For the bureau to start another, longer plan for water transfers with 

no decision on this court case seems like very poor planning. These “scoping meetings” are premature and 

have no actual proposal to comment on. There is no project to develop any EIS on, no concrete figures of 

how much water SLDMWA is looking to buy, and no statement about who is willing to sell water (therefore 

no locale to pinpoint any environmental impacts). The North valley is a huge and diverse area, for the 

bureau to lump it all into an EIS for some undefined amount of water grab will probably soon be found to be 

illegal. 

 
2

I don’t know about NEPA but for CEQA the “Lead Agency” is the agency with authority to accept or deny 

the EIR (EIS for NEPA) and to develop and approve mitigation measures needed. How in the world does 

SLDMWA become a “Lead Agency” in this proposal when they are the “customer” and “end user”? 

SLDMWA benefits from, initiates the need, sets the price, and now, with this proposal, becomes the 

environmental and economic watchdog for these undefined water transfers. Talk about “the fox guarding the 

henhouse!” 

 

Historically the area encompassed by SLDMWA was used mainly for “Truck Farming”. The seasonal 

nature of this allows a farmer to change his crops to allow for the cyclic drought and wet years of 

California’s climate. In Northern California we have a mixture of crops with orchard crops making up a 

large percentage of the plantings. Our average rainfall is large enough that we seldom need to irrigate in the 

winter and spring, and the groundwater table is stable. The central valley uses 3 to 4 times the yearly water 

needs of the same crop grown in the north state. The rice farms that usually make up the “willing sellers” in 

this project have neighbors who have orchard crops and depend on the ground water for their crops viability. 

These “willing sellers” and “willing buyers” are also mostly made up of large corporate farms with their 

short term outlook for profit and loss that drives them to look at water as a commodity rather that an 

environmental and economic resource. 

 

Water is not a “resource” to be mined and sold for profit. Water is a right and an ecological need for us in 

the north state. To make a long term commitment to sell water for marginal farming and to plan to do so in 

“drought years” when north state flora and fauna are at their most vulnerable seems unconscionable to 

me.For the bureau to rush to judgment on this issue because of a manufactured “need” for water by farmers 

who are trying to farm crops ill-suited to the desert they live in, without first addressing the very real 

concerns of the broad cross-section of people at the meeting in Chico, would be completely abrogating the 

duties listed in their “Mission Statement” quoted as the first lines of this letter. 

 

Thank You, 

Richard Meyers 

3503 Dry Creek Road 

Oroville, Ca. 95965 

rmeyers@digitalpath.net 

 

 

 

1

Greene, Alicia M.

From: Veronese, Gina

Sent: Monday, February 28, 2011 8:21 AM

To: Greene, Alicia M.

Subject: FW: Long-Term North to South Water Transfers

‐‐‐‐‐Original Message‐‐‐‐‐ 

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov]  

Sent: Sunday, February 27, 2011 5:55 PM

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly

Subject: Fw: Long‐Term North to South Water Transfers

Comment for record.

‐‐‐‐‐ Original Message ‐‐‐‐‐ 

From: Jan Mountjoy <janmhayfork@gmail.com>

To: Hubbard, Bradley C

Sent: Sat Feb 26 19:24:47 2011

Subject: Long‐Term North to South Water Transfers

As a resident of Trinity County in Northern California, I am against the program to grant

long term North‐South Water Transfers.  We already have limitations on our modest growth

projections from existing water transfers and we need the water for our fisheries and

recreational river and lake economy.

Please consider  these comments in your decision.

Thank you,

Jan Mountjoy

Hayfork, CA 96041

This article was printed from the Local Stories

section of the Chico News & Review, originally published 

January 6, 2011.

This article may be read online at:

 http://www.newsreview.com/chico/content?oid=1900955

 Copyright ©2011 Chico Community Publishing, Inc.

 Printed on 2011-01-17.

At long last, water transfers get analyzed 

Upcoming meeting to discuss impacts of pumping from north 

to south 

By Meredith J. Cooper

Next week, a new chapter in North State water history will 

begin with discussion of an environmental review of 

transferring water from the North State down south. For 

water advocates like Barbara Vlamis, it’s about time. 

“This is what we’ve been clamoring for for more than a 

decade and a half,” said the executive director of the 

advocacy group AquAlliance. “I guess there’s an element 

of satisfaction, but it’s really shameful that it’s taken 15 

years of public pressure and follow-through to have public 

agencies follow their own laws.” 

What Vlamis is referring to is the transfer of surface water 

to regions in the south. In the early 1990s, agencies “flirted with the idea,” and often fields would 

remain fallow so that surface water could be sold south. But as the years wore on, despite a 

negative experience early on, it became common practice to pump groundwater from the Tuscan 

aquifer to replace the surface water that was being sold—so those fields that had previously 

remained fallow could instead be operational. 

But until now, projects were short-term and never required an environmental review. Next 

Tuesday’s meeting (Jan. 11) will be the public’s first opportunity to voice concerns about the 

environmental impacts of transferring water out of this region. The federal Bureau of 

Reclamation, which touts itself on its website as “the largest wholesaler of water in the country,” 

and the San Luis Delta Mendota Water Authority want to ink a 10-year plan to transfer water from 

Northern California south and are seeking public input on how to study the project’s 

environmental impacts. 

For Vlamis, this is an opportunity she’s lobbied for since 1994, when she was executive director 

of the Butte Environmental Council (BEC), an environmental organization dedicated to education 

and advocacy. That year, wells actually went dry because of over-pumping of the aquifer. 

Get involved: 

Attend a public meeting at 6 p.m. 

Jan. 11 at the Chico Masonic 

Family Center, 1110 W. East Ave. 

The Bureau of Reclamation is 

seeking suggestions for areas of 

study for a forthcoming 

environmental review of its 

proposal to transfer water from the 

North State south over a 10-year 

period.

Page 1 of 2

http://www.newsreview.com/chico/PrintFriendly?oid=1900955 1/17/2011
In 1994, the Western Canal and Richvale water districts sold a significant amount of surface water 

to Southern California. To make up for the loss, they pumped groundwater. Unfortunately, 1994 

turned out to be a drought year, and agricultural and residential wells in the Durham area went 

dry. A Durham municipal well even had to be shut down, Vlamis recalled. 

“We saw what happened to the wells, but there was no monitoring of the environment,” she said. 

“If they want to do this for 10 years, the potential to compound the impacts is huge.” 

Robin Huffman, advocacy director at BEC, agrees. 

“A 10-year plan is basically institutionalizing water transfers,” she said recently by phone. 

Both women emphasized that the public should be very concerned about such a project and 

encouraged everyone to get involved. 

“The agencies need to know that the people up here care,” Vlamis said. 

For her part, she hopes to learn what the impact of transfers is on local creeks, ecosystems, wells 

and farms. In addition, she hopes to see a system in place to monitor changes in the local 

environment and a policy that would stop transfers if significant negative impacts are found. 

Huffman’s questions for the Bureau of Reclamation hinge around the details of the project, which 

are as yet unknown. 

“What is the program exactly? How deep are they going to go? How much can they transfer? And 

shouldn’t it depend on how much rainfall we get that year?” she posed. “We need to make sure 

it’s sustainable. We have a relatively healthy system right now, and we want to keep it healthy.” 

An e-mail and phone message left for Brad Hubbard, project manager for the Bureau of 

Reclamation, seeking further information about the plan were not returned by press time. A 

meeting-notice document posted on the AquAlliance website (www.aqualliance.net) says the 

details—such as who can sell water to whom, what the limits will be, and what the impacts will be 

on a variety of resources—will be included in the environmental-review document. 

Page 2 of 2

http://www.newsreview.com/chico/PrintFriendly?oid=1900955 1/17/2011
Water Transfer Meeting Draws Huge Crowd 

Reported by: Alan Marsden 

Email: amarsden@khsltv.com

Last Update: 12:06 am 

Print Story | 

Nearly 200 people, concerned over water transfers to the San Joaquin Valley, crowded an informational 

meeting in Chico Tuesday night. Organizers seemed to even be a little unprepared for the huge turnout. 

At issue, transferring water from the North State to parched farmland in the Central Valley, south of the 

Delta. 

The Bureau of Reclamation explained its 10-year-plan to accommodate the sale of water by those who 

have it in the North to those who need it in the South. They're looking for public input in preparing an 

environmental impact report. 

Farmers and environmentalists are particularly worried that ground water will be depleted and the North 

State will be left high and dry. Barbara Vlamis of the group AquAlliance said the dry desert conditions of 

the Central Valley region is no place for farming. "The people that really don't have water, their 

watersheds are dry, they want water to farm in a desert," said Vlamis. "That is the biggest problem." 

Louis Moore, a Bureau of Reclamation spokesman, said Tuesday night's meeting was important to hear 

these types of concerns. "Water's one of those things everybody needs," said Moore. "Everybody wants it 

and we have to figure out, based on the fact we have a limited resource, how do we get the best out of 

what we have?" 

http://www.khsltv.com/content/localnews/story/Water-Transfer-Meeting-Draws-HugeCrowd/OkbqGeImlUO2Jsac206AOw.cspx 

 

Water transfer meeting comes to boiling 

point

By JEN SIINO -Staff Writer 

Posted: 01/12/2011 01:07:17 AM PST 

CHICO — More than 200 people crowded into a room prepared for 50 to voice opinions about water 

transfers at the Chico Masonic Family Center Tuesday evening. 

The event is the first of three scoping meetings to be held by the Bureau of Reclamation and the San Luis 

& Delta Mendota Water Authority regarding the Long-Term North to South Water Transfer Program. 
Other events are scheduled today in Sacramento and Thursday in Los Banos. 

The meeting aimed to gain comment on what should be included in a joint environmental impact 

statement/environmental impact report. 

The meeting included a PowerPoint presentation and was supposed to be followed by an "open house" 

where citizens could approach designated areas about specific topics, such as transfer types and resources. 

However, not long into the initial presentation by Brad Hubbard, project manager for the Bureau of 

Reclamation, audience members started asking questions. 

Though the questions were supposed to be taken after the presentation, the audience insisted on being 

heard. One man even made a formal motion to change the format, saying they didn't want to do an open 

house and would rather hear each others' questions and have them answered. The idea was met with a 

resounding "aye" from the audience members in favor. 

Audience members requested their questions be answered directly, and Frances Mizuno, assistant 

executive director for San Luis & Delta Mendota Water Authority jumped into the hot seat. 

Mizuno tried to answer questions, but often came up short on specifics. She responded to more than one 

question by saying she didn't know the answer at that time. 

For the remainder of the evening, citizens took two-minute turns at the microphone, sharing concerns 

and posing questions. 

Common concerns were conservation and misuse of water and where it would be going. One main issue 

dealt with water not going to southern California and another with who would take responsibility for 

possibly harmful environmental effects. 

These general concerns seemed to be shared by the majority of the diverse crowd, comprised of 

everyone from a homeless man, to farmers, to local politicians. 

"There are a lot of liberals here and a lot of conservatives here, but on this we are united," said John 

Janinis, a Chico resident of 50 years. "You will see these people come together like you've never seen 

before." 

Janinis and other speakers commented that water doesn't belong to any group of people and its rights 

shouldn't be bought or sold, he said. 

Others expressed concern the EIS/EIR is intended to be issued next year, which some felt is not enough 

time to do sufficient research. 

Butte County resident Terry Faulkner spoke to the audience about fears of negative environmental 

impact. 

"Who's responsible for dealing with the damages?" Faulkner asked the audience and Bureau of 

Reclamation employees. 
Faulkner also expressed concern over things being handled effectively and mentioned she didn't want the 

process to "take years of lawsuits." 

The meeting's tone, at times, became humorous, too. Local politician Mark Herrera got the crowd 

laughing by saying he thought the community wasn't interested — adding that the Bureau of Reclamation 

representatives could still stick around. 

Herrera wasn't the only local politician to make an appearance. Former Chico City Council member Tom 

Nickell was also in attendance. 

Early in the meeting, Nickell said he was concerned about how the bureau intends to notify people about 

what is decided. 

He also requested more meetings be held in areas such as Redding and Tehama County to make sure 

everyone's opinion is heard. 

"I think that this interaction is really good," said Louis Moore, public affairs specialist for mid-pacific 

region of the Bureau of Reclamation. "There was a little bit of angst in the audience, but the people came 

to grips with, 'wait, this is my chance to say something.'" 

Moore added that the purpose of the scoping report was achieved and they got what he considered to be 

"a lot of passionate input." 

http://www.orovillemr.com/news/ci_17073976 
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bhubbard@l)sbr,gov or fran~es.m;z\.lno@sld'mwa,Qr9 wit.h tlte-$lJbl~r Un!;!"Long-Term North,lO'

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received by5:00 p.rn, {PacificStandard Time} on February 28, 20,11.

PLEASE PRINT CLEARLY;PLEASE NOTE THAT ALl COMMENTs BECOME PART OF tHE PUBLIC RECORD.

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1

Greene, Alicia M.

From: Veronese, Gina

Sent: Monday, February 28, 2011 2:29 PM

To: Greene, Alicia M.

Subject: FW: Long Term North to South Water Transfer 

From: Frances Mizuno [mailto:frances.mizuno@sldmwa.org] 

Sent: Monday, February 28, 2011 1:24 PM 

To: Buckman, Carolyn; Veronese, Gina 

Cc: bhubbard@usbr.gov 

Subject: FW: Long Term North to South Water Transfer 

More comments.

From: GordyOh@aol.com [mailto:GordyOh@aol.com] 

Sent: Monday, February 28, 2011 1:15 PM 

To: bhubbard@usbr.gov; Frances Mizuno 

Subject: Long Term North to South Water Transfer 

 

 Long Term North to South Water Transfer ~

 Public Comment Letter

 

 It is imperative that there should be more public input on this subject.

 It is both shocking and disappointing how "quiet" this has been in the media. To have only 

one meeting on a rainy winters night in Chico is not sufficient nor respectful to all of the 

communities and farmers of the effected watershed.

 My sister farms 1000 acres in Colusa County, and was livid that the meeting was so far away. 

As a fifth generation farmer on the same land, she suggested that there should be a public meeting 

every sixty miles from Sacramento to Susanville.

 

 I have lived here all my life and know intimately the panic-feeling of when the well goes dry 

in September. It already happens, and we cannot drain water from this area in a greater degree. 

Each of my neighbors wells are tenuous and 1/3 are currently drilling them deeper.

 To lower the aquifer would kill, stunt, or damage immeasurably the trees and streams 

throughout the landscape, far beyond the immediate riparian flora and fauna. You see, it is all 

connected. The California landscape would change, our world would literally dry-up. Taking 

water from the north-state, thereby killing tress and plants would remove the cleansing action of 

the living vegetation. Live, growing vegetation of all varieties, replenish the oxygen we breath, 

remove carbon-dioxide and cool the air. It is where fresh air comes from.

 This northern part of our state, the Sacramento Valley, is one of the largest wild bird flyways 

in the world. A major route of the whole world. As they fly from the southern part of the globe to 

Alaska, this is where they rest, feed, and procreate.The water wetlands nurture literally millions. 

Please do not tamper with this delicate regional balance.

 
2

 One last point; as a businessman I must point out that the farmers in the southern area show 

signs of being bad farmers/bad businessmen. They are overextending themselves beyond their 

resources. Because these men have made bad choices beyond the ability of the land to sustain and 

produce, or are possibly simply driven by greed, that is no justification to take from another 

community leaving it worse off. These actions of insensitive selfish desire should not be 

rewarded.

 We live here. It is not right to steal from another.

 Thank you for registering my comments. In closing, may I urge you to be open to the input of 

others. Please consider that some actions may be clever...but not wise. 

 Thank you~

 

~ Gordy Ohliger 

 Butte County Homeowner 

 530 891-3354 
 Carole S. Oles 

 286 East Sacramento Ave. 

 Chico, CA 95926 

 February 25, 2011 

Mr. Brad Hubbard 

Bureau of Reclamation 

2800 Cottage Way 

Sacramento, CA 95825, MP-410 

Dear Mr. Hubbard: 

I am writing to register strong opposition to the “Long-Term Water Transfers” that 

were the subject of the Bureau of Reclamation meeting on January 11, 2011 at the 

Masonic Lodge in Chico. My opposition is based on the following four major 

reasons: 

the indeterminate nature of these “transfers,” since the presenters at that meeting 

could not provide specific details of the project, as suggested by language such as 

“likely” and “not necessarily” on page 4 of the Bureau’s handout; 

the lack of provision for direct EIS/EIR analysis of all proposed SWP “transfers”; 

the fragility of the aquifer and groundwater system as witnessed personally by 

many well-informed residents and farmers who had experienced dramatic 

negative results of excessive groundwater extraction for the drought water bank in 

1994; 

a recent University of California at Irvine study documenting the crucial depletion 

of groundwater in the Central Valley, stating that “Over-pumping is pulling vast 

and unsustainable amounts of groundwater from the heart of California farming, 

the Central Valley.” (Published 2/5/2011 online, Geophysical Review Letters.) 

I urge the Bureau to suspend further action on the SWP until it has completed a 

comprehensive study and has disseminated all results of that study to citizens in the 

proposed project area and statewide. 

Sincerely, 

Carole S. Oles 

Professor Emerita 

Department of English 

California State University, Chico 
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Friday, February 11, 2011 10:25 AM

To: Greene, Alicia M.

Subject: FW: Comments,for Proposed long-term 'North to South water transfers Envirnmental 

Document Preparation

‐‐‐‐‐Original Message‐‐‐‐‐ 

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov]

Sent: Friday, February 11, 2011 9:24 AM

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly

Subject: FW: Comments,for Proposed long‐term 'North to South water transfers Envirnmental

Document Preparation

Comment for the record.

‐‐‐‐‐Original Message‐‐‐‐‐ 

From: Steve Owen [mailto:sowen278@gmail.com]

Sent: Friday, February 11, 2011 5:38 AM

To: Hubbard, Bradley C

Subject: Comments,for Proposed long‐term 'North to South water transfers Envirnmental

Document Preparation

I am a landowner in the Glenn Colusa Irrigation District and have sold surface water rights

in past water transfer programs, requiring cropland idling.  I am against any program

involing the transfer of groundwater or the use of groundwater to make up for the selling of

surface water.  I am also against Glenn Colusa punping groundwater into their surface water

system.  If water is transfered, the land must be idled and no water used during that season.

If the land is idled and allowed to have seasonal ,non irrigated, vegetation to grow on it,

would have great benefits for wildlife.  A win win for wildlife and southern water users.

Thank You

Steve Owen




1

Greene, Alicia M.

From: Veronese, Gina

Sent: Monday, January 17, 2011 3:59 PM

To: Greene, Alicia M.

Subject: FW: CA North state Water

From: Frances Mizuno [mailto:frances.mizuno@sldmwa.org] 

Sent: Monday, January 17, 2011 2:56 PM 

To: Buckman, Carolyn; Veronese, Gina 

Cc: Hubbard, Bradley C 

Subject: FW: CA North state Water 

FYI.

From: Brenda Rogers [mailto:brogers@soperwheeler.com] 

Sent: Monday, January 17, 2011 2:55 PM 

To: bhubbard@usbr.gov 

Cc: Frances Mizuno; shatleberg@usbr.gov 

Subject: CA North state Water 

To: U.S. Dept of the Interior Bureau of Reclamation,

I’m writing in regards to the long-term water transfer that you are planning in the north 

state from 2012 to 2022. I’m a resident of Butte County and I highly oppose any type of 

water transfers. You have not provided the documentation to show the cumulative effects 

that will be done to our aquifers from your planned water transfers. I believe taking 

100,000 to 150,000 acre feet is highly detrimental to Butte county and all of the north 

state. The environmental as well as the economical impact could be enormous. Farmers, 

consumers, and residents, could easily have their wells dry up and a water shortage. 

Please formally file this letter as a protest to your proposed project. I would also like to be 

update on any new developments on this project.

Sincerely,

Brenda L. Rogers 
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Friday, January 14, 2011 8:41 AM

To: Greene, Alicia M.

Subject: FW: Water transfers

Public comment for file

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Tuesday, January 11, 2011 10:43 PM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: Fw: Water transfers 

First questions from tonight.

From: Angus Saint-Evens <saintevens@sbcglobal.net> 

To: Hubbard, Bradley C 

Sent: Tue Jan 11 23:34:10 2011 

Subject: Water transfers 

I am interested in the proposed water transfers and before deciding whether to be in 

favor or against. A few questions if I may. 

Is there a position paper or executive summary of the proposal that can be reviewed 

preferably on line? 

What is the purpose of the transfer? 

Will the receiving entities be permitted to further transfer the water received? Or sell it. 

Is the transfer designed to supplement current water resources in the district who will 

receive it. 

 

Is the transfer designed to supplant current water resources in the districts who will 

receive it. 

Thank you for your anticipated responses. 

Angus Saint-Evens 

Orland California 

1

Greene, Alicia M.

From: Veronese, Gina

Sent: Wednesday, February 23, 2011 11:50 AM

To: Greene, Alicia M.

Subject: FW: Opinion

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Wednesday, February 23, 2011 10:49 AM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: Fw: Opinion 

Comment for record.

From: Ann Patello <apatello@hotmail.com> 

To: Hubbard, Bradley C 

Sent: Wed Feb 23 11:41:17 2011 

Subject: Opinion 

Dear Sir:

I am from Orland, a town with a 95% agricultural-based economy. I attended the meeting in Chico, and found the atmosphere so toxic 

I left after about an hour. I agreed with the general feeling of frustration, disgust, disillusionment, and the feeling of 'being played'.

The entire reason for the meeting seemed to be to humor the public, when it appeared to many of us that the decisions had already 

been made. 'It will keep them quiet if they think they have a say in the process.' 

In my opinion the most important, and unspoken, issue at the time was not how water transfers should be handled, but if there should 

be any. There was never any question 'do you want to participate and under what circumstances'. Our participation was a foregone 

assumption. That is what ticked everyone off so badly. We were given no reason to want to participate. Our homes, lives and crops, 

the water supply in OUR area, was not taken into consideration; ie: how will our wells be affected. I believe we should be given first 

priority, because this is where the food is grown. No water. No food. No people. Period. 

The very fact that some have chosen to live in a place without adequate water(semi-arid and historically water poor), and then 

steadfastly refused to be proactive in utilizing reservoirs or other cachement is their decision, and their problem to cope with. Their 

problem does not automatically become our responsibility to solve. Because our water is subterranean and not easily quantifiable it is 

assumed to be limitless and therefore not treated with the respect a finite resource deserves. 

Please do not bother to respond with a form letter, automatically generated. It is another sign of the disregard you have for us and our 

opinions.

Ann Schuenemann

Orland CA
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Monday, February 28, 2011 8:22 AM

To: Greene, Alicia M.

Subject: FW: Long-Term North to South Water Transfers

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Sunday, February 27, 2011 6:02 PM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: Fw: Long-Term North to South Water Transfers 

Comment for record.

From: Laurie Schwaller <lschwaller1@wildblue.net> 

To: Hubbard, Bradley C 

Sent: Sun Feb 27 18:43:37 2011 

Subject: Long-Term North to South Water Transfers 

We feel strongly that it is time for the people of California to start living within their means.   

We cannot afford to continue to devastate California’s ecosystems and natural resources at gigantic and unsustainable

expense, both economically and environmentally, by building more and more monumental systems to move huge

volumes of water all over California.  These systems are monstrously costly to build and to maintain, and they invariably

have drastic consequences that in many ways outweigh their benefits.

Our efforts to provide more water to people who choose to live in areas where their demands have already outstripped

the natural water supply should focus on conservation, re‐use, and recycling.  For too long, we’ve been robbing Peter to

pay Paul at the taxpayers’ expense.  Far too often the transferred water is not used wisely or efficiently.  Why should we

destroy more ecosystems at huge expense to try to keep expanding human population in an ecosystem already virtually

destroyed by overpopulation?   

As for agricultural demand, water‐intensive crops should not be grown in areas without adequate water supply, and ag

water should not be wasted.   

Californians should pay the true cost of their water at the point of demand.  Rates must be tiered to promote careful

and efficient use.

Long‐Term North to South Water Transfers are not in the long‐term interest of California and should not be pursued.  

The collapse of the Delta ecosystem will be an unmitigatable disaster.  Let the water stay and do its work where it

belongs.

Thank you for considering our comment.

Greg and Laurie Schwaller

43857 South Fork Dr.

Three Rivers, CA  93271
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Tuesday, March 01, 2011 8:09 AM

To: Greene, Alicia M.

Subject: FW: Long Term Water Transfer EIS/EIR San Luis & Delta Mendota Water Authority

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Monday, February 28, 2011 5:02 PM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: FW: Long Term Water Transfer EIS/EIR San Luis & Delta Mendota Water Authority 

Comment for record.

From: John Scott [mailto:john_lewis_scott@msn.com] 

Sent: Monday, February 28, 2011 5:01 PM 

To: San Luis & Delta Mendota Water Authority; Hubbard, Bradley C 

Cc: Richard Harriman; Robin Huffman; Carol Perkins; Gary & Linda Cole 

Subject: Long Term Water Transfer EIS/EIR San Luis & Delta Mendota Water Authority 

Dear Frances Mizuno & US Bureau of Reclamation; February 28 ,2011 

 

Subject: Long Term Water Transfer EIS/EIR (for the San Luis & Delta Mendota Water Authority, and the U. S. Burea of 

Reclamation) 

 

Please include my comments in the official draft document, and keep me informed of this potential project and EIR. 

 John Scott, 4370 Tao Way, Butte Valley, CA 95965-8345 and via my e-mail. 

 

Comments: 

1). Water transfers can not be extended beyond one year, because of the potential devastating economic and 

environmental consequences to our Tuscan Aquifer. 

 

2). Conjunctive Water management is no way to treat our aquifer, because there is a great potential that our entire 

aquifer could be contaminated, and because many aquifers have been stolen away from the local people by those running

the conjunctive water program. 

 

3). Any farmer that sell their water will be shunned by the community, because of the disgrace they are bringing on to 

the entire farming community. 

 

4). Any monetary proceeds that a farmer is to receive from attempting to sell their water must be taken away from them 

and given to their county of Origin. The water is ours and they do not have the moral right to sell our water. 

 

5). Local water must stay local!! 

 

6). The area of origin of water must have primary right to that water, forever. 

 

7). The San Joaquin valley destroyed their Aquifer, by over pumping it until it collapsed and it can no longer be 

recharged. 

We will not allow anyone to destroy our Aquifer. 

 

very sincerely, 

 
2

John Scott 

Butte Environmental Council, Butte Valley Coalition, Cherokee Watershed Alliance 
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Monday, February 28, 2011 1:13 PM

To: Greene, Alicia M.

Subject: FW: Long-Term North to South Water Transfers

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Monday, February 28, 2011 12:12 PM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: FW: Long-Term North to South Water Transfers 

Comment for record.

From: g-marvin@comcast.net [mailto:g-marvin@comcast.net] 

Sent: Monday, February 28, 2011 12:05 PM 

To: Hubbard, Bradley C 

Subject: Long-Term North to South Water Transfers 

Brad Hubbard

bhubbard@usbr.gov

Bureau of Reclamation

2800 Cottage Way MP-410

Sacramento, CA 95825

Subject: Long-Term North to South Water Transfers

As Conservation Chair of the Sierra Club, Yahi Group (covering five north state counties) I have attended 

meetings and discussed various aspects of the North to South Water Transfer program. I am hereby submitting 

EIS/EIR comments. We have a number of concerns about the program which I shall summarize:

1- At the recent meeting in Chico, the spokespeople for the Delta Plan spoke proudly of their "'Coequal goals'” 

which were providing a more reliable water supply for California and protecting, restoring, and enhancing the 

Delta ecosystem. But I heard nothing about the goal of protecting tecological systems in the north state that 

are a source of most of the Delta's water. We want a rigorous scientific study of our water supplies, including 

ecosystems, ground and surface water, relationships between aquifers, and recharging. We have strong 

evidence of subsidence, and lowered groundwater in numerous wells, aquifers and streams, suggesting that 

excessive movement of water southwards would continue to damage our ecosystems and water related 

economies. As audience members expressed: what is seen as a “safe yields” by water agencies are not safe 

from our perspectives. Give us the studies to allow for a) proper analyses of conjunctive management and for 

b) environmental impact reports.

2- Insufficient attention is given in the plans for water conservation efforts. For example, some widely grown 

crops are poorly chosen given water availability, and it is agricultural conservation that seems to receive the 

least attention in the plan. We agree with Sierra Club California which states that the plan should also : a) 

Promote statewide water conservation and efficiency, including enacting into law AB 19 (Fong)..., to require water metering or 

sub-metering of new multi-family residences like apartment buildings and condominium towers. b) Build best management 

practices for urban water agencies.

3- We agree with many other groups and individuals who maintain that we need to have more solid data 

regarding how much flow should take place through the Delta and during which times of year more flows are 
2

needed. Furthermore, the plan should incorporate projections related to climate change, since water levels 

have already changed and will continue to do so – even more in coming years

4- It is truly unfair that we have to raise money for legal costs in order to challenge water transfers that have no 

good scientific or ecological justification as well as coming up with money for drilling new, deeper wells to 

replace those that have gone dry. We have much history that provides us with skepticism about assurances 

that our water needs will be met in the north state.

Please address these comments. The Yahi Group Executive Committee has voted to approve this letter

Thank you.

Sincerely,

Grace M. Marvin, 

Conservation Chair

Sierra Club, Yahi Group
801 K Street, Suite 2700 , Sacramento, CA 95814 • (916) 557-1100 

FAX (916) 557-9669 • www.sierraclubcalifornia.org

February 28, 2011 

Mr. Brad Hubbard , Project Manager 

United States Bureau of Reclamation 

2800 Cottage Way, MP-410 

Sacramento, CA 95825 

bhubbard@usbr.gov 

Mr. Dean Messer, Chief 

DWR Office of Water Transfers 

1416 9th Street Sacramento, CA 95814 

dmesser@water.ca.gov 

Ms. Frances Mizuno 

Assistant Executive Director 

San Luis & Delta-Mendota Water Authority (SLDMWA) 

frances.mizuno@sldmwa.org 

Re: Comments on Scope of Environmental Review of Proposed North to South Water 

Transfer Program 

Dear Mr. Brad Hubbard, Ms. Frances Mizuno & Mr. Dean Messer: 

Sierra Club California thanks you for the opportunity to comment on the proposed long term transfer 

program. The unprecedented duration and scale of these transfers raise serious environmental and 

economic issues, which we believe will be difficult to predict or evaluate. 

We have the following comments on the scope and lead agency for the proposed environmental 

review:

1. Conflict of interest with lead agency 

 Since the San Luis and Delta Mendota Water District has many member agencies which are 

proposed recipients and financial beneficiaries of transferred water, they are not an appropriate 

agency to be a lead agency on this Environmental Review. The lead agencies should be the 

Department of Water Resources and the US Bureau of Reclamation, as the only statewide water 

agencies. The courts have held that the Department of Water Resources has the statutory duty to 

serve as lead agency in assessing the environmental consequences of projects involving the State 

Water Project. 
2. New scoping notice announcing water agencies in the program. 

 Water agencies known to be in the project were not named in the notice, new ones may 

be added, and there may be others are known to be considering it. For example, it was learned 

at a scoping meeting (or write instead: at the Sacramento scoping meeting) that the Placer 

County Water Agency is in the project. A new notice and scoping comment period should be 

opened with a list of these agencies. Regarding the project sending and receiving areas, all of 

the agencies in these areas should be listed in the notice. The notice for the scoping that has 

occurred should have named the known agency participants including description of the 

mechanisms for participating and the status of their program participation. The participation 

documents should be made available online as soon as they are in effect. 

3. Seller water rights and sources, and buying and selling history 

 For each agency in the project, at minimum, all water rights held or contracted for by the 

agency and all of its other water sources of any kind need to be identified and quantified. This 

includes any kind of water rights or other water use authority including agency including FERC 

water-related permits, riparian rights, wells, contracts and so forth. Maps of seller water right permit 

and other source locations and. A table and narrative description of these water rights and all other 

sources of water need to identify all aspects of the status of these authorities and uses. This needs to 

include, but not be limited to, quantity of beneficial use, permit/source expiration, renewal 

applications. The history of all of each agency's water transfer and sales and buys needs to be 

included. 

4. Buyer water rights, sources and water buying and selling history 

 Buyer information, analysis and documentation needs to be the same as for sellers. 

5. Seller and buyer area and entire watershed water transfer analysis 

 Buyer and seller areas including the watershed-wide and sub-watershed issues in the 

watershed where they are located need to be the basis for environmental, energy, water rights 

and land use impact and documentation and analysis. Specific factors to address include but 

are not limited to public trust doctrine water, instream uses, federal and tribal water rights, 

federal reserved water rights, all public lands water rights or other state and federal public land 

water use permissions, all other water rights, surface waters including lakes and groundwater, 

local general plans, local, state and national land use and resource management plans, 

downstream uses and environmental issues, development water supply, recycled water projects 

and plans, public health including drinking water, basin plans. Current and historical water 

sales and purchase throughout both seller and receiver watersheds need be detailed in table and 

narrative form. 
6. Proof of beneficial use, lack of injury to other legal users of water 

 The mechanisms for participation in the Long-Term North to South Transfer program 

should be in agreement with SB 7X 1, and in particular the new office of the Delta 

Watermaster and instream flow determinations by the State Water Resources Control Board. 

The Delta Watermaster has proposed to enforce state law requiring beneficial use of water. 

Therefore all water transfers under this program should be required to show reasonable and 

beneficial use. The Environmental Review should address procedures for buyers to show that 

the end use of the proposed transfer is for a reasonable and beneficial and that it will not injure 

other legal users of water. 

Comments on specific issues in the Environmental Review:

The transfer program is occurring at a time when the Sacramento Delta and anadromous fish 

populations are in a fragile state of recovery. Other essential ecosystem management policies, 

such as designated critical habitat for the Giant Garter Snake, Thamnophis Gigas, have not 

been completed. Therefore we have the following requests on specific issues: 

1. Effects on listed Delta species 

 With the implementation of the Biological Opinion governing the joint operation of the CVP 

and SWP pumps in flux, it is impossible to determine in advance what the effect of the proposed 

transfer program will be on Delta smelt and other listed fish species. Therefore, we request that the 

time period for this evaluation be reduced to no more than three years. If the ten year term is kept, 

procedures for evaluating impacts on listed species should be specified, and criteria for reducing or 

discontinuing the transfers should be determined. 

2. Effects on fisheries 

 The proposed transfers could affect the recovery of anadromous fish species both through the 

drawdown of upstream reservoirs and through increased pumping and entrainment at the Project 

pumps in the South Delta. Timing of transfers and potential impacts on the listed Winter and 

Spring Run Chinook salmon, as well migrating Fall Run salmon smolts should be examined. 

Procedures for evaluating the impact on the recovery of the fall salmon run and the economic effects 

of a continuing depressed fishing industry should be specified, as well as mitigation. 

3. Ground and surface water impacts 

 The proposed water transfers are almost half of the amount of water used by the entire 

Sacramento Valley Rice industry. It is difficult to determine in advance what the effects of such 

large-scale, long-term transfers would be on the aquifers. Again, we request that the time period for 

this review be reduced. If the ten year term is kept, procedures for evaluating cumulative impacts 

on aquifers and river flow should be specified, and criteria for reducing the total transfers should be 

determined. 
4. Effects on Sacramento Valley wetlands, riparian species, and migratory birds 

 

 The effects of widespread fallowing on populations of both listed and non-listed species 

should be estimated, and criteria for determining if populations are falling more severely than 

predicted. Baseline population data and mitigation measures for all threatened or endangered species 

should be determined, as well as criteria for mitigation of impacts and reduction of total transfers. 

In particular, critical habitat for the Giant Garter Snake, Thamnophis Gigas should be designated, 

and essential baseline data and mitigation measures s, should be determined. 

5. Socioeconomic effects 

 Both direct and indirect job loss in the areas transferring water should be determined. 

Analysis of impacts should include both agricultural jobs and hunting and recreational fishing jobs. 

Mitigation of adverse impacts should be determined. 

. 

6. Water quality 

 Impacts of transferred water on ground and surface water quality in the San Joaquin Valley 

and the Sacramento-San Joaquin Delta should be addressed, including the potential for the transfers 

to increase nitrate loading in the San Joaquin River, and nourish toxic algal blooms in the lower San 

Joaquin River. Increased costs for water treatment for agencies drawing water from the Delta 

should be considered, and mitigation measures should be identified. 

7. Effects on water supply to other agricultural users (with appropriative rights) 

 Potential transfers of water from Central Valley Project water users to urban users should be 

evaluated for an increase in demand under the Central Valley Project Water Shortage Policy, which 

preferentially allocates water to urban water districts. Mitigation for impacts on agricultural water 

supplies should be determined. 

Background: 

The Central Valley Project water shortage policy includes specific provisions for irrigation 

water transferred or converted to urban or “Municipal & Industrial” use. According to Section 3, 

irrigation water transferred or converted to M&I use is subject to the same shortage allocation as 

irrigation water. However, the agency receiving the water may request that the water obtained by 

transfer or conversion be eligible for M&I reliability. Then the policy states only that: 

 “Before Reclamation may approve such a request, the transferee or assignee must fully 

mitigate any adverse impacts to agricultural water supplies. Further, for CVP water converted, 

an M&I contractor may request a permanent conversion from agricultural shortage criteria to M&I 

shortage.” 
8. Energy impacts 

 The Environmental Review should evaluate the effect of the proposed transfers on energy 

consumption and greenhouse gas emissions in the state. The expected change in the energy 

consumption of the respective projects should be calculated, and mitigation for the expected increase 

in greenhouse gas emissions should be identified. 

Background: 

 A 2010 Study or the California Public Utilities Commission found that the total energy use 

for water supply, conveyance, and treatment in the state was about18,098 GWh.1

 The study found that conveyance of project water was about half of this total. In 2001, the 

State Water Project used 6,352 GWh of electricity, and produced 1,933 GWh of electricity from 

hydropower. The net energy consumption of the State Water Project was 4,420 GWh of electricity. 

The Central Valley Project used 833 GWh of electricity, and the Colorado River 

Aqueduct used 2,483 GWh of electricity. The total energy used for conveyance was 9,718 

GWh, or 7,401 GWh net of hydropower generation. 

 These numbers mean that long-distance conveyance alone is a significant percentage of total 

electricity used in the state – about 4% in 2001. In particular, the State Water Project has been a net 

consumer of electricity for many years, and has needed to supplement hydro power with 

electricity from fossil fuel-based power plants. 

 Increasing North-South exports by an additional million acre feet would use an additional 1.4 

MWh – 3.9 MWh per acre foot – or an extra 840 GWh to 2,340 GWh for 600,000 acre feet. 

 The CPUC report also estimated that in 2001, groundwater pumping used 

about 6,068 GWh of electricity, only slightly less than the net use of the State 

Water Project, Central Valley Project, and Colorado River Aqueduct combined. The total 

energy use may have increased significantly in the past decade with increased reliance on active 

management strategies, including groundwater substitution transfers, and groundwater bank 

infiltration and extraction. 

: 

9. Finances: Effects of proposed transfers on CVP and SWP finances should be evaluated. 

 Given the fluctuations in the cost of fossil-fuel based electricity, and the fixed energy 

payments in the State Water Project Contracts, it should be determined if Project income will be 

sufficient to pay for the increased energy costs of the transfers in any given year. Also, the U.S. 

Bureau of reclamation is going to start implementing the preferred alternative for San Luis Drain 

Feature Re-evaluation, which will significantly increase the cost to the Central Valley Project of 

irrigating lands on the West side of the San Joaquin Valley. 

 

1

  . Embedded Energy in Water Studies. Study 1: Statewide and Regional Water-Energy Relationship, 

 Prepared by GEI Consultants/Navigant Consulting, Inc. for the 

 California Public Utilities Commission Energy Division, August 31, 2010 

 http://www.calmac.org/publications/CALMAC_CA_Statewide_Regional_Water- 

 Energy_Vol_15_of_15_-_Appendix_N.pdf 
 These financial effects will be difficult to forecast for the proposed time horizon, and it will 

be necessary to either reduce the time horizon for the proposed review, or to include provisions for 

recalculation and revaluation of impacts of the transfers on finances of the Projects.. 

10. Alternatives 

 The proposed transfers should be compared with less energy-intensive alternatives, including 

changing cropping patterns and crop irrigation methods for on-farm uses, and accelerated 

implementation of the “20 by 2020” conservation program, and local water recycling for urban users. 

Thank you for the opportunity to comment. Please include Sierra Club California on the 

mailing list for this or similar projects. 

Sincerely, 

Jim Metropulos 

Senior Advocate 

Sierra Club California 

jim.metropulos@sierraclub.org
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Monday, January 24, 2011 9:26 AM

To: Greene, Alicia M.

Subject: FW: Water transfer's

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Monday, January 24, 2011 9:08 AM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: FW: Water transfer's 

Here is a comment that came in over the weekend.  Thanks, Brad

From: robert stanley [mailto:robertestanley@att.net] 

Sent: Saturday, January 22, 2011 1:50 PM 

To: Hubbard, Bradley C 

Cc: frances.mizuno@sldmwa.org 

Subject: Water transfer's 

 The first and foremost rule is THE ECONOMY IS NEVER MORE IMPORTANT 

THAN THE ENVIRONMENT !!! AND THERE IS ONLY ONE ENVIRONMENT AND 

ONCE IT"S GONE IT'S GONE!!! AND WE GO WITH IT!!! This water transfer is bad science, 

but since some one high up in the GOV wants it , they will hire scientist's who are willing to sell 

their soul for money in order to write a false EIS/EIR reports to make it all happen. There is only 

so much water, but there are far better way's to manage water movement and storage in a seasonal 

desert. A great info source is the NATIONAL GEOGRAPHIC SPECIAL EDITION ON 

WATER!!! In it they describe water use and consumption for certain crops and other uses. It 

makes it obvious that high water consumption crop's like cotton should not be allowed in this 

state, and because they also use the most pesticides that kill the fish. LIMITING other high water 

user's like dairy's and cattle ranches may be needed because of the methane they produce, or 

require them to capture most of it. DRIP irrigation could save thousands. Your bad science means 

the person with the deepest well gets to deprive their neighbor's of their water rights's I have the 

answers you need. 

 Sincerly ROBERT STANLEY 
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Monday, January 31, 2011 1:40 PM

To: Greene, Alicia M.

Subject: FW: 

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Monday, January 31, 2011 11:52 AM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: FW: 

For the comment record.

From: robert stanley [mailto:robertestanley@att.net] 

Sent: Thursday, January 27, 2011 10:27 PM 

To: Hubbard, Bradley C 

Cc: frances.mizuno@sldmwa.org 

Subject: 

The place to get water from is way north, Oregon , Washington , Canada all you need to do is pipe 

it to the northern Sacramento tributary's. The time to build is now. I'm completely against your 

flawed plan. Do it right, and get a 500 year supply now. I have brilliant new designs to save 

millions in pumping costs, you really should hire me as a consultant. I know how to fix the delta, 

which means you can pump more water! I have new storage and flood control system's that you 

need. The Sacramento sewage treatment plant needs to be fixed in one year not ten!!! This needs 

federal money NOW!!! I have the best solutions for scores problems. YOU have the money, I have 

the answers. Sincerely ROBERT STANLEY. 
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Tuesday, February 15, 2011 9:27 AM

To: Greene, Alicia M.

Subject: FW: Water transfer's

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Tuesday, February 15, 2011 8:26 AM 

To: Buckman, Carolyn; Veronese, Gina 

Cc: Hatleberg, Shelly 

Subject: FW: Water transfer's 

Comment for record.  

From: robert stanley [mailto:robertestanley@att.net] 

Sent: Monday, February 14, 2011 10:08 AM 

To: Hubbard, Bradley C 

Subject: Re: Water transfer's 

When I said to limit dairy's and cattle ranches I meant south of the delta, 

And other high water consumption user's. 

From: robert stanley <robertestanley@att.net> 

To: bhubbard@usbr.gov 

Cc: frances.mizuno@sldmwa.org 

Sent: Sat, January 22, 2011 1:50:23 PM 

Subject: Water transfers

 The first and foremost rule is THE ECONOMY IS NEVER MORE IMPORTANT 

THAN THE ENVIRONMENT !!! AND THERE IS ONLY ONE ENVIRONMENT AND 

ONCE IT"S GONE IT'S GONE!!! AND WE GO WITH IT!!! This water transfer is bad science, 

but since some one high up in the GOV wants it , they will hire scientist's who are willing to sell 

their soul for money in order to write a false EIS/EIR reports to make it all happen. There is only 

so much water, but there are far better way's to manage water movement and storage in a seasonal 

desert. A great info source is the NATIONAL GEOGRAPHIC SPECIAL EDITION ON 

WATER!!! In it they describe water use and consumption for certain crops and other uses. It 

makes it obvious that high water consumption crop's like cotton should not be allowed in this 

state, and because they also use the most pesticides that kill the fish. LIMITING other high water 

user's like dairy's and cattle ranches may be needed because of the methane they produce, or 

require them to capture most of it. DRIP irrigation could save thousands. Your bad science means 

the person with the deepest well gets to deprive their neighbor's of their water rights's I have the 

answers you need. 

 Sincerly ROBERT STANLEY 
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Friday, February 25, 2011 11:18 AM

To: Greene, Alicia M.

Subject: FW: Fw:

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Friday, February 25, 2011 9:54 AM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: Fw: 

Comment for record.

From: robert stanley <robertestanley@att.net> 

To: Hubbard, Bradley C 

Sent: Fri Feb 25 00:42:37 2011

 When you think in short time frames like 10 , 20 years , the only result can be an ignorant environmentally 

destructive result.!!! I have plenty of time to contemplate in 200 ,500, 1000 year time frames and my conclusions is it 

is extremely selfish and ignorant for one generation to cause severe environmental destruction just to boast the 

profit of a few farmers. There farming in a seasonal desert and should not be guaranteed water during droughts. 

Maybe they should be paid not to plant some years. You should have learned from your giant Klamath river 

mistake. Even though I'm against this flawed plan , I have figured out how to vastly improve the Delta's health so 

you can send more water through it. RS. 
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Friday, February 25, 2011 4:22 PM

To: Greene, Alicia M.

Subject: FW: Fw:

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Friday, February 25, 2011 3:21 PM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: Fw: 

Comment for record.

From: robert stanley <robertestanley@att.net> 

To: Hubbard, Bradley C 

Sent: Fri Feb 25 14:27:31 2011

 Idling crops in the water rich north and sending water to the water poor farmers south of the Delta makes 

no sense at all. Especially because of the environmental destruction involved. One of the problems is they are 

planting more orchard's there that are not sustainable. Re injecting ground water is a ponzi scheme. It sounds good 

but in the end we all lose. Try fixing Owens valley.Evan though I have given you lots of important information I'm 

withholding vital info you desperately need and I don't put it on my computer because I know you guy's can break 

in. RS 
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Monday, February 28, 2011 8:20 AM

To: Greene, Alicia M.

Subject: FW: Fw:

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Sunday, February 27, 2011 5:53 PM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: Fw: 

From: robert stanley <robertestanley@att.net> 

To: Hubbard, Bradley C 

Sent: Fri Feb 25 21:55:22 2011

Someone has been breaking into my computor I apologize for accuseing you guys. RS 
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Tuesday, February 08, 2011 2:51 PM

To: Greene, Alicia M.

Subject: FW: Fw:

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Tuesday, February 08, 2011 8:42 AM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: Fw: 

Another comment from Mr Stanley. 

From: robert stanley <robertestanley@att.net> 

To: Hubbard, Bradley C 

Sent: Mon Feb 07 23:40:40 2011

 One way to provide more flood protection for Sacramento would be to divert water from 

folsom dam over to the Cosumnes River. It would be pretty easy actually straight south from 

folsom lake . Another free million dollar Idea. You really should hire me as a consultant! But I 

have several other ones also. I know how to fix the Delta to make it hold more water , provide 

flood protection ,store more water , and save the fish. ROBERT STANLEY 




1

Greene, Alicia M.

From: Veronese, Gina

Sent: Monday, February 28, 2011 4:27 PM

To: Greene, Alicia M.

Subject: FW: San Luis and Delta-Mendota Water Authority plan create an illegal Moral Hazard

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Monday, February 28, 2011 3:24 PM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: FW: San Luis and Delta-Mendota Water Authority plan create an illegal Moral Hazard 

Comment for record.

From: r switzer [mailto:prswitz@gmail.com] 

Sent: Monday, February 28, 2011 3:15 PM 

To: Hubbard, Bradley C 

Subject: San Luis and Delta-Mendota Water Authority plan create an illegal Moral Hazard 

Dear Mr. Hubbard, 

 I wish to register my opinion concerning the proposal to establish an agency by which water rights would be 

sold to the San Luis and Delta-Mendota Water Authority. 

I believe it is illegal to establish an agency by which "willing sellers" can assign their water rights to 

Sacramento River water flows, for up to 10 years per contract. 

To do so would be to create a Moral Hazard, illegal under the law. A Moral Hazard increases the likelihood 

that one person will take steps that will adversely affect one or more other parties. 

"Willing Sellers", having sold their Riparian rights, would have strong economic incentive (and financing, with 

profits from water sales) to continue to farm their properties with subterranean water. 

This economic incentive increases the risk of the water table in the local area being greatly affected, with the 

risk of attendant harm assigned to a large number of innocent parties who had no part in the original water 

transfer or subsequent replacement, and did not profit from the original deal. 

In our local area, it is a well established fact that towns and individuals can have their water tables ruined by 

excessive draw-downs. 

Tocal water tables are already drastically reduced*without* the presence of an agency that will more strongly 

incentivize the further depletion of those water tables. 

In this case it is not at all difficult to discern the obvious Moral Hazard attendant to a proposed creation of an 

agency such as proposed by the Bureau of Reclamation. 

The proposal should be rejected. 

Yours truly, 
2

Paul R. Switzer 

1197 Honey Run Road 

Chico, CA 95928 
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Monday, February 28, 2011 4:24 PM

To: Greene, Alicia M.

Subject: FW: Northern California Groundwater

‐‐‐‐‐Original Message‐‐‐‐‐ 

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov]

Sent: Monday, February 28, 2011 3:23 PM

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly

Subject: FW: Northern California Groundwater

Comment for record.

‐‐‐‐‐Original Message‐‐‐‐‐ 

From: Nora Todenhagen [mailto:n_todenhagen@yahoo.com]

Sent: Monday, February 28, 2011 3:12 PM

To: Hubbard, Bradley C

Subject: Northern California Groundwater

The proposed transfers of Sacramento Valley groundwater constitute a common right "taking" in

every moral sense.  Urban and agricultural interests in this hydrological region have used

their groundwater as a good in common.  They have not paid for the water itself only for its

delivery.  The rule was they were to put this water to productive use. With this groundwater

has come a thriving agriculture and a vibrant urban economy dependent on this agriculture.

This common groundwater is delicate.  It is declining; certainly the ground water users

themselves should be imposing limits on its use.  When an outside interest in 1994 siphoned

water from a common aquifer, the results were disastrous.  Wells ran dry.

Now the Bureau of Reclamation is proposing a massive "taking" of this common good.  The

excuse is the sellers of the water are "willing."  There can be no "willing" sellers of a

common good.  There can only be massive disruption of the livelihood of many and the

destruction of the flora and fauna which are dependent on groundwater and on a healthy stream

‐ groundwater relationship.

Please reconsider your groundwater transfer proposal and look for other solutions to

California's water problems.  

Nora Todenhagen

2298 East 8th St.

Chico, Ca 95928

1

Greene, Alicia M.

From: Veronese, Gina

Sent: Monday, February 28, 2011 5:35 PM

To: Greene, Alicia M.

Subject: FW: Scoping Comments: Long-Term Transfers ( 2012-2022 )

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Monday, February 28, 2011 4:24 PM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: FW: Scoping Comments: Long-Term Transfers ( 2012-2022 ) 

Comment for record.   

From: John Merz [mailto:jmerz@sacrivertrust.org] 

Sent: Monday, February 28, 2011 4:22 PM 

To: Hubbard, Bradley C 

Subject: Scoping Comments: Long-Term Transfers ( 2012-2022 ) 

Dear Mr. Hubbard:

 

The Sacramento River Preservation Trust ( Trust ) has serious concerns about the cumulative and third party impacts ( 

among other things ) of the proposed Long-Term Water Transfer Program ( Program ). We trust that these issues will be 

addressed in depth during the EIS/EIR process and hereby request to be kept informed of ANY and ALL meetings and 

related developments regarding the Program.

 

Sincerely, 

 

John Merz 

President 

Sacramento River Preservation Trust 

P.O. Box 5366 

Chico, CA 95927 

(530) 345-1865 

jmerz@sacrivertrust.org

www.sacrivertrust.org
February 28, 2011

Mr. Brad Hubbard

Bureau of Reclamation

2800 Cottage Way, MP–410

Sacramento, CA 95825

Subject: Scoping Comments and Questions regarding the Ten-Year, 600,000 Acre-Feet,

North-to-South Water Transfer Program

Dear Mr. Hubbard:

AquAlliance, the California Sportfishing Protection Alliance, and the California Water 

Impact Network (―the Coalition‖) submit the following scoping comments and questions for 

the Ten-Year, 600,000 Acre-Foot, North-to-South Water Transfer Program (―Project‖) 

Environmental Impact Statement and Environmental Impact Report (―EIS/EIR‖). The 

EIS/EIR will address transfers of 600,000 acre-feet (―af‖) of Central Valley Project (CVP) 

and non-CVP water. The Bureau of Reclamation (Bureau) and the San Luis/Delta Mendota 

Water Authority (SLDMWA), the lead agencies (agencies) as defined by the National 

Environmental Policy Act (NEPA) and the California Environmental Quality Act (CEQA),

must provide the public with a clear project description, properly define and quantify the 

impacts, provide enforceable mitigation measures, consider adequate alternatives, and 

propose a detailed monitoring plan.

For the majority of the twentieth century, the Sacramento Hydrologic Region supported 

family farming, healthy salmon runs, and a diverse environmental heritage. We hope that the 

agencies will seek to not only remember the heritage, but actively participate in efforts to 

defend what remains and restore what has been degraded for the health of California and 

future generations. That legacy and culture are now in the crosshairs of water policies that 

have repeatedly failed in the San Fernando, Owens, and San Joaquin valleys of California.
AquAlliance, CSPA, CWIN scoping comments on the Ten-Year, 600,000 af, North to South Water Transfer Program.

Page 2

Lead Agencies

Please explain why the California Department of Water Resources is not the lead agency for 

the Project review under the California Environmental Quality Act. Clearly, DWR facilities

are instrumental pieces of the Project as stated in the Federal Register: ―Reclamation and 

DWR would facilitate water transfers involving CVP contract water supplies and CVP and 

SWP facilities.‖ Moreover, how will SLDMWA enforce the state‘s role as trustee of the 

public‘s resources in California? DWR has the statutory duty to serve as lead agency in 

assessing the environmental consequences of projects involving the SWP.1

Project Description

The draft EIS/EIR must provide an accurate description of the proposed Project and its 

relationship to myriad other water transfer and groundwater extraction projects. An accurate 

and complete project description is necessary to evaluate the potential environmental impacts 

of the agencies‘ actions.  ̳Only through an accurate view of the project may affected outsiders 

and public decision-makers balance the proposal's benefit against its environmental cost, 

consider mitigation measures, assess the advantage of terminating the proposal . . . and weigh 

other alternatives in the balance.'" (City of Redlands v. County of San Bernardino (2002) 96 

Cal.App.4th 398, 406-407, quoting County of Inyo v. City of Los Angeles (1977) 71 

Cal.App.3d at pages 192-193.

A) The public‘s ability to comment in this scoping process has been severely hampered by

the lack of a definable project. The Federal Register notice dated December 28, 2010

provides very limited information:

The EIS/EIR will address transfers of Central Valley Project (CVP) and 

non-CVP water supplies that require use of CVP or State Water Project 

(SWP) facilities to convey the transferred water. Water transfers would 

occur through various methods, including, but not limited to, groundwater 

substitution and cropland idling, and would include individual and 

multiyear transfers from 2012 through 

2022................................................................................. Current 

operational parameters applicable to the transfer water include:

• Conveyance of a maximum of 600,000 acre feet per year; and

• Use of the SWP’s Harvey O. Banks Pumping Plant and CVP’s C.W. 

‘‘Bill’’ Jones Pumping Plant during July through September only.

As we await a project description, many questions come to mind such as, who are the 

potential sellers and buyers? Under what conditions will the Project be implemented and at

what scale? What is the baseline? Repeated water transfer projects in the last decade have all 

occurred without the benefit of comprehensive federal or state environmental analysis, which

prompts us to suggest that the baseline should precede all this activity – approximately the 

year 2000 (see chart below).

 

1

http://ceres.ca.gov/ceqa/cases/2000/PCLvDWR-2000.html

84 Cal.App.4th 315A, 100 Cal.Rptr.2d 173, 00 Cal. Daily Op. Serv. 7782, 2000 Daily Journal D.A.R. 10,331
AquAlliance, CSPA, CWIN scoping comments on the Ten-Year, 600,000 af, North to South Water Transfer Program.

Page 3

Source: Western Canal Irrigation District’s Negative Declaration, 2010 Water Transfer Program

B) The use of ground water substitution is very controversial (see Impacts). The Coalition 

brought this to your attention in our comments for the 2010-2011 Water Transfer Program. 

Members of the Coalition have also raised alarm over ground water substitution through 

comments submitted on numerous individual CVP and SWP contractor‘s water transfer and 

ground water extraction projects over many years. The controversy must be addressed in the 

EIS/EIR.

C) It is crucial that the EIS/EIR disclose the current over subscription of our natural water 

supply as well as the over subscription of legally designated surface water rights in the state, 

i.e. ―paper water.‖

D) The Federal Register does not mention directly the use of State Water Project water. 

Please specify what is considered ―non-CVP‖ water that may be used in the Project.

Impacts

The proposed Project will have significant effects on the environment—both standing alone 

and when reviewed in conjunction with the multitude of other plans, projects, and programs 

that incorporate and are dependent on Sacramento Valley water. 

A) The Bureau understands the seriousness of the potential impacts as presented in the 

Environmental Assessment (―EA‖) for the 2010-2011 Water Transfer Program cumulative 

impacts section. The EA disclosed that there could be a devastating impact to groundwater: 

―The reduction in recharge due to the decrease in precipitation and runoff in the past years in 

addition to the increase in groundwater transfers would lower groundwater levels. Multi-year 

groundwater acquisition under cumulative programs operating in similar areas of the 

Sacramento Valley could further reduce groundwater levels. Ground water levels may not 

fully recover following a transfer and may experience a substantial net decline in 

groundwater levels over several years. This would be a substantial cumulative effect,‖ (EA p. 

3-108).

It is unacceptable and would be irresponsible for the agencies to move forward with the 

ground water substitution component in light of the potential impacts. However, if the 

agencies decide to move forward with ground water substitution as a part of the Project, an 

exhaustive and detailed description of the probable and possible impacts must be included in 

the EIS/EIR and the mitigation and monitoring plan, with all the component parts, must be 

presented for public review with the EIS/EIR.
AquAlliance, CSPA, CWIN scoping comments on the Ten-Year, 600,000 af, North to South Water Transfer Program.

Page 4

B) The EIS/EIR must also provide, but isn‘t limited to, data and peer reviewed analysis for 

the following:

 The draft EIS/EIR must thoroughly analyze the potentially significant adverse effects 

on listed species, species of concern, critical habitat, and species recovery plans in the 

area of origin, areas of conveyance, and area(s) of delivery.

 Air quality impacts in the area of origin, areas of conveyance, and area(s) of delivery 

could be severe with the increased pumping that may be necessary to implement the 

Project. These probable impacts must be thoroughly analyzed.

 Significant projects of this size have the potential to create serious growth inducing 

impacts in the area of origin, areas of conveyance, and area(s) of delivery. These 

probable impacts must be thoroughly analyzed.

 Discussion and analysis of the legal and practical implications of artificial recharge, 

in lieu recharge, and replenishment districts must be presented in the EIS/EIR.

 Recharge data for all aquifers in the area of origin.

 Aquifer levels and trends in the area of origin and the area(s) of delivery for the past 

40 years.

 Impacts to native hardwood trees (terrestrial habitat) that may result from alluvial 

aquifer leakage into dewatered aquifer layers.

 Detailed understanding of the interaction between surface and ground waters in the 

area of origin and the area(s) of delivery.

 Isotopic ground water data available for the area of origin.

 Ground and surface water quality in the area of origin, areas of conveyance, and the 

area(s) of delivery for the past 40 years and how the Project may improve or degrade 

water quality. Examples include hazardous waste plumes in ground water basins and 

selenium laden runoff.

 Detailed descriptions of local regulations and management plans and explicitly state 

how they might or might not protect the public trust and private property resources in 

the area of origin from 600,000 af per year water transfers.

Cumulative Impacts

Cumulative impacts analyses are required by both CEQA and NEPA and require the 

cumulative effects analysis to include past, present, and foreseeable future actions and 

projects that can be reasonably predicted to occur within the term of the proposed project.

The cumulative effects analyses in this EIS/EIR must evaluate the combined effects of the 

Project and other water acquisition programs that could engage in water transfers similar to 

those of the Project as well as all ground water stress tests (see Monitoring for examples). 

The cumulative effects analyses must also consider projects proposing physical changes to 

water quality, storage, export, or conveyance facilities in the areas of origin, areas of 

conveyance, and the receiving area(s). The existence of these numerous related projects 

makes an adequate analysis of cumulative impacts especially important.
AquAlliance, CSPA, CWIN scoping comments on the Ten-Year, 600,000 af, North to South Water Transfer Program.

Page 5

The Project‘s surface water transfers and ground water substitution program do not exist in a 

vacuum, as the agencies well know, and instead are actually integrated, important parts of a 

broader scheme to develop regional surface and ground water resources into a conjunctive 

use system. For example, "GCID shall define three hypothetical water delivery systems from 

the State Water Project (Oroville), the Central Valley Project (Shasta) and the Orland Project 

reservoirs sufficient to provide full and reliable surface water delivery to parties now 

pumping from the Lower Tuscan Formation. The purpose of this activity is to describe and 

compare the performance of three alternative ways of furnishing a substitute surface water 

supply to the current Lower Tuscan Formation groundwater users to eliminate the risks to 

them of more aggressive pumping from the Formation and to optimize conjunctive 

management of the Sacramento Valley water resources." (U.S. Bureau of Reclamation, 

September 2006. Grant Assistance Agreement) This example is only one many projects and 

programs that must be evaluated cumulatively in the EIS/EIR.

Alternatives

The agencies should consider direct alternatives and reduced-demand alternatives to the tenyear, 600,000 acre-feet per year water transfer program.

Direct Alternatives to the Proposed Project

 Thoroughly scrutinize the no project alternative.

 Thoroughly scrutinize the no project alternative or a delay of the Project alternative

in conjunction with:

o Conservation in the area(s) of delivery.

o Retirement of farmland in the San Joaquin Valley that produces polluted 

runoff.

o Bringing the CVP and SWP contract amounts in line with historic firm yields

and eliminating ―paper water.‖

 Allow 600,000 acre-feet per year over ten years, but exclude ground water 

substitution.

 Consider a smaller amount, such as 300,000 acre-feet per year over ten years and 

exclude ground water transfers.

 Use of water transfers only within the basin(s) of delivery (excluding north of delta to 

south of delta transfers).

Additional Reduced-Demand Alternatives to the Proposed Project

 Change crop patterns in the San Joaquin Valley to less water intensive crops. For 

example, change from perennial tree crops to annual crops that can be left fallow 

during normal to sub-normal precipitation patterns.

 Enforce the existing seniority system to manage deliveries, demand, and expectations.

 Create a policy of no net increase in water availability for urban or agricultural 

expansion.
AquAlliance, CSPA, CWIN scoping comments on the Ten-Year, 600,000 af, North to South Water Transfer Program.

Page 6

Monitoring

Adequate monitoring is particularly important in light of the significant risks posed by the 

Project to the health of the area of origin‘s ground water. Moreover, this Project is occurring 

concurrently with other past, present, and reasonably foreseeable projects like the Drought 

Water Bank, the SCF Stony Creek Fan Aquifer Performance Testing Plan, the Butte County 

aquifer performance testing program, and more. A clear and explicit adaptive management 

strategy must be integrated into the EIS/EIR from the outset and available for public 

comment; its description cannot be left undefined or left as a ―next step.‖

A) If ground water substitution is used in the Project, how will individual well owners be 

protected from impacts and notified of Project pumping? The EIS/EIR must disclose that the 

majority of wells used in the Sacramento Valley are individual wells that pump from varying 

strata in the aquifers and that there are thousands of domestic wells in the target export area 

that are vulnerable to ground water manipulation and lack historic monitoring. 

The Bureau‘s 2009 Drought Water Bank Environmental Assessment elaborated on this point 

regarding Natomas Central MWC (p. 39) stating that, ―Shallow domestic wells would be 

most susceptible to adverse effects. Fifty percent of the domestic wells are 150 feet deep or 

less. Increased groundwater pumping could cause localized declines of groundwater levels, 

or cones of depression, near pumping wells, possibly causing effects to wells within the cone 

of depression. As previously described, the well review data, mitigation and monitoring plans 

that will be required from sellers during the transfer approval process will reduce the 

potential for this effect.‖ There must be a monitoring protocol that is sufficient to draw real 

time conclusions regarding area-wide impacts and a notification process and for all well 

owners in any basin that uses ground water substitution.

B) The Coalition believes that individual selling districts‘ mitigation and monitoring plans,

which have been used previously by the Bureau and DWR, are inadequate. They fail to 

provide the most basic framework for governmental authority to enforce the state‘s role as 

trustee of the public‘s water in California, let alone a comprehensive and coordinated

structure, for a very significant program that could transfer up to 600,000 af of water from 

the Sacramento Valley.

We suggest that an independent third party, such as USGS, oversee the mitigation and 

monitoring program. The Bureau, DWR, SLDMWA, and the selling districts are interested 

parties and should not ―guard the henhouse‖ as it were. After the fiasco in Butte County 

during the 1994 Drought Water Bank and with the flimsy, imprecise proposal for mitigation 

and monitoring in the 2010-2011 Water Transfer Program, the agencies and districts lack 

credibility as oversight agencies.

C) Monitoring of the area of origin‘s hydrology must include measurement and analysis of 

the alluvial (shallow) aquifer layers that contribute to stream-flow and sustain deep-rooted 

native valley oak trees. In addition, interaction between these shallow layers and the 

pressurized underlying semi-confined aquifer layers must be disclosed and analyzed.
AquAlliance, CSPA, CWIN scoping comments on the Ten-Year, 600,000 af, North to South Water Transfer Program.

Page 7

Conclusion

As our alternatives section suggests, we believe that the ―need‖ for this project is driven by 

demand from junior water rights holders south of the Delta. The need for 600,000 af of water 

south of the Delta springs from failed business planning that has been supported with 

political influence. The Bureau, SLDMWA, and DWR, the ―silent partner‖ in this Project, 

must acknowledge this and further disclose that their agencies are willing to socialize the 

risks taken by corporate agribusiness and developers while facilitating private profit. Instead 

of asking northern California water districts and municipal water purveyors to place their 

own water at risk, as well as the water and water quality for neighboring communities, 

thousands of residential well owners, fisheries, recreation, stream flow, terrestrial habitat, and 

geologic stability, the agencies must disclose all the uncertainty in the Project and then 

evaluate the risks with scientific methodology.

Please inform our organizations of any information regarding this Project and send us all 

future environmental review news releases.

Sincerely,

Barbara Vlamis

Executive Director

AquAlliance

P.O. Box 4024, Chico, CA 95927

(530) 895-9420

info@aqualliance.net

Bill Jennings

Chairman

California Sportfishing Protection Alliance

3536 Rainier Avenue, Stockton, CA 95204

(209) 464-5067

deltakeep@aol.com

Carolee Krieger

Executive Director

California Water Impact Network

808 Romero Canyon Road, Santa Barbara, CA 

93108

(805) 969-0824

caroleekrieger@cox.net
1

Greene, Alicia M.

From: Veronese, Gina

Sent: Friday, February 11, 2011 10:23 AM

To: Greene, Alicia M.

Subject: FW: Long-term north to south water transfers: comments

From: Hubbard, Bradley C [mailto:BHubbard@usbr.gov] 

Sent: Friday, February 11, 2011 9:21 AM 

To: Buckman, Carolyn; Veronese, Gina; Hatleberg, Shelly 

Subject: FW: Long-term north to south water transfers: comments 

For the record.

From: Elicia Whittlesey [mailto:elicia.whittlesey@gmail.com] 

Sent: Tuesday, February 08, 2011 1:36 PM 

To: Hubbard, Bradley C 

Subject: Long-term north to south water transfers: comments 

February 8, 2011 

 

Comments on north-south water transfer proposal 

 

To Brad Hubbard 

Bureau of Reclamation 

I attended the “scoping” meeting in Chico (January 11th) on the north-south water transfer proposal. These 

transfers – whether they are a “project” or a “plan” or some other scheme – constitute an ill-conceived, poorly 

disguised and unwarranted subsidy of agribusiness. As someone who grew up here, playing in and protecting 

Butte County’s creeks, I am acutely aware of water’s preciousness – and precarity – in northern California. 

Studying water in college and graduate school, I also know that there are ways to live well and wisely with the 

water that we have, and in ways that support all life. I know that there are wise alternatives to this proposal. And 

so, like many other people in the area around Chico, I am firmly opposed to any north-south water transfers. 

 

But it is not up to me to make the argument against such transfers. It is up to the proponents to make an 

argument for them. And it is the job of government agencies working in service of all people, not just the 

richest, to fairly and fully examine all angles of the possible water transfer. This hopelessly nebulous proposal 
2

was brought to the public prematurely. Without the details of any actual proposal in hand, the public is not able 

to adequately comment on this vague proposition. We can only ask questions. I hope that these and many other 

questions will be addressed in the EIR/S. 

 

Why is this water needed? By whom? For what purpose? What will the environmental effects, positive or 

negative, of this water be on the San Joaquin Valley and River ecosystem? Who will benefit economically from 

this water? Who and what will suffer? What state-wide water policies support or conflict with these proposed 

transfers? 

 

When will this water be transferred? Will the public be notified of these transfers, and have case-by-case 

opportunities to comment? What constitutes a drought? How will global climate change affect the supposed 

need for water transfers? Will these transfers truly alleviate a shortage in supply? If northern California is also 

experiencing drought, why would it be reasonable or justifiable to deprive northern ecosystems of water for the 

sake of southern orchards? Why should junior water rights holders farming in inappropriate locations be given 

precedence over the uses of water by senior water rights holders and for farms, ecosystems, and homes in the 

Sacramento Valley? Please provide a detailed monitoring and mitigation plan concerning ground- and surfacewater impacts in the Sacramento Valley. And please be transparent about the political rationale for transferring 

this water. What role does financial and political power play in deciding how water is allocated? 

 

Who will sell the water? What effect will groundwater replacement for irrigation have on the regional 

hydrology, including the aquifers, creeks, wells, and springs? Who will be liable for any adverse effects to these 

water systems? What effect will groundwater replacement have on groundwater quality – including movement 

of heavy metals into drinking water? What effect will groundwater replacement pumping have on river and 

creek levels, and on the viability of these waterways for aquatic life and salmon migrations? Where is the 

baseline data, and what does it say? What will the cumulative impacts be? How can we predict these effects 

with any accuracy, given the current dearth of knowledge about regional groundwater systems? Be honest about 

scientific uncertainty. 

 

What are the alternatives to these proposed transfers? What are the benefits – social, economic, and 

environmental – of retiring cropland on the west side of the San Joaquin Valley? What are the benefits of water 

conservation, in both agricultural and municipal uses? I want to see a full, fair, and thorough investigation of 

these alternatives. 

 

With many others in northern California, I reject the attempt to take the water we all rely on. It is insulting to 

have the Bureau introduce a proposal utterly lacking in substance, justification, or honesty. Without a project 

description, everyone can only guess at the effects. 

 

I ask that you use the space of the EIR/S to tell us how, and why, we can and should formally say “No” to this 

proposal. 
3

 

 

Sincerely, 

 

Elicia Whittlesey 

Butte Valley, California