-
From: Deirdre Des JardinsTo: Delta Council NOPSubject: Delta
Plan Amendments -- Scoping comments on EIR/EISDate: Monday, April
17, 2017 4:56:15 PMAttachments: CWR scoping comments amendments
2.pdf
Please accept these comments on behalf of California Water
Research. Deirdre Des [email protected] 423-6857 v831
566-6320 c CWR logo email
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-
Deirdre Des Jardins
145 Beel Dr
Santa Cruz, CA 95060
(831) 423-6857
[email protected]
April 17, 2017 VIA electronic mail
Delta Stewardship Council
980 9th Street, Suite 1500
Sacramento, CA 95814
To Whom it May Concern:
California Water Research provides the following scoping
comments on Delta Plan
Amendments. The comments address risks from climate change and
not considering
information on levee condition in the Delta Levees Investment
Strategy.
1. Climate Change
The Scoping notice does not adequately describe the project. The
draft Amendment on
Water Conveyance, System Storage, and the Operation of Both
makes significant changes from
the mandates in the Delta Reform Act for analysis of sea level
rise in the BDCP/WaterFix
Environmental Impact Report.
These are the mandates in the 2009 Delta Reform Act:
85320 (b) The BDCP shall not be incorporated into the Delta Plan
and the public benefits
associated with the BDCP shall not be eligible for state
funding, unless the BDCP does
all of the following:
[]
mailto:[email protected]
-
(2) Complies with Division 13 (commencing with Section 21000) of
the Public
Resources Code, including a comprehensive review and analysis of
all of the following:
[]
(C) The potential effects of climate change, possible sea level
rise up to 55 inches,
and possible changes in total precipitation and runoff patterns
on the conveyance
alternatives and habitat restoration activities considered in
the environmental
impact report.
This is the revised language in the draft amendment:
B. 1. Consistent with Delta Plan policies and recommendations,
new and
improved Delta conveyance infrastructure should be based on
an
evaluation of alternatives for conveyance of CVP and SWP
water
supplies from the Sacramento River to the South Delta that
includes all of
the following analyses:
[]
(c) The potential effects of climate change, including possible
sea
level rise in 2030 and 2070 as projected by the National
Research
Council, or other appropriate projections, and possible changes
in
total precipitation and runoff patterns on the conveyance
alternatives under consideration.
The draft Delta Plan amendment significantly weakens the
statutory language in Water Code
85032(b)(2)(c), deleting the requirement that the climate change
analyses be comprehensive, and
consider possible sea level rise of up to 55 inches. The draft
Delta Plan amendment also does
not define what it means projections of the National Research
Council, or other appropriate
projections.
A. Sea Level Rise
The 2012 report by the National Research Council on Sea-Level
Rise for the Coasts of California,
Oregon, and Washington1 defines both a mean projection and a
range, as well as a range of semi-
empirical projections. The table below, from page 89, shows the
mean projection for 2100 is
82.7 centimeters, or 33 inches, with a range of up to 55 inches.
The semi-empirical projection
has a range of up to 175 centimeters, or 69 inches.
There are no NRC projections for 2070. The mean projection for
2050 is 28 centimeters,
or 11 inches, with a range of up to 48.2 centimeters, or 19
inches. Using a linear interpolation
to get values at 2070 gives a mean of 20 inches, with a range of
up to 33 inches. The NRC
mean projection of 20 inches at 2070 is considerably lower than
55 inches. It is close to the
1 National Research Council, Sea-Level Rise for the Coasts of
California, Oregon, and Washington: Past, Present, and Future.
Washington, DC: The National Academies Press. 2012. Available
at
https://www.nap.edu/catalog/13389/sea-level-rise-for-the-coasts-of-california-oregon-and-washington
https://www.nap.edu/catalog/13389/sea-level-rise-for-the-coasts-of-california-oregon-and-washington
-
value of 18 inches by 2065 used in the BDCP/WaterFix tunnels
engineering and Environmental
Impact Report.
The Delta Independent Science Board (ISB) was harshly critical
of the climate change
assumptions in the BDCP Draft EIR/EIS2, stating:
The potential effects of climate change and sea-level rise are
underestimated. . . . The
potential direct effects of climate change and sea-level rise on
the effectiveness of actions,
including operations involving new water conveyance facilities,
are not adequately
considered. . . . We believe this is dangerously unrealistic.
CEQA requires impacts to be
assessed "in order to provide decision makers enough information
to make a reasoned
choice about the project and its alternatives."
The Department of Water Resources (DWR) responded to the Delta
ISB's review, stating
that "the scope of an EIR/EIS is to consider the effects of the
project on the environment, and not
the environment on the project." However, the plain meaning of
85032(b)(2)(C) required
consideration of the effects of sea level rise of up to 55
inches on the project. In Chapter 9 of
the WaterFix Final EIR/EIS, DWR quietly disclosed that
underestimating sea level rise in the
WaterFix tunnel design could result in saltwater intrusion into
water supplies and damage to
infrastructure3:
Underestimating sea level rise in the project design will result
in harmful realized
impacts such as flooding. Harmful impacts are more likely to
occur if the project design
is based upon a low projection of sea level rise and less likely
if higher estimates of sea
2 Delta Independent Science Board, Review of the Draft EIR/EIS
for the Bay Delta Conservation Plan. 2014. Available at
http://deltacouncil.ca.gov/sites/default/files/documents/files/Attachment-1-Final-BDCP-comments.pdf
3 WaterFix Final EIR/EIS, Volume I, Chapter 9 Geology and
Seismicity. 2016. Available at
http://baydeltaconservationplan.com/Libraries/Dynamic_Document_Library/Final_EIR-EIS_Chapter_9_-
_Geology_and_Seismicity.sflb.ashx
http://deltacouncil.ca.gov/sites/default/files/documents/files/Attachment-1-Final-BDCP-comments.pdf
http://baydeltaconservationplan.com/Libraries/Dynamic_Document_Library/Final_EIR-EIS_Chapter_9_-_Geology_and_Seismicity.sflb.ashx
http://baydeltaconservationplan.com/Libraries/Dynamic_Document_Library/Final_EIR-EIS_Chapter_9_-_Geology_and_Seismicity.sflb.ashx
-
level rise are used. In situations with high consequences (high
impacts and/or low
adaptive capacity), using a low sea level rise value involves a
higher degree of risk.
(Examples of harmful impacts that might result from
underestimating sea level rise
include damage to infrastructure, contamination of water
supplies due to saltwater
intrusion, and inundation of marsh restoration projects located
too low relative to the
tides). (Chapter 9, section 9.2.2.6)
The Delta Plan Amendment Programmatic EIR needs to evaluate the
consequences of not
requiring a comprehensive analysis of the effects of sea level
rise of up to 55 inches on the
WaterFix project, which include the harmful impacts described in
the Final EIR/EIS.
Sea level rise of up to 55 inches by 2100 is no longer an
extreme estimate. It is now a
95% exceedance value, according to recent released risk
estimates of the Ocean Protection
Councils Science Advisory Team (OPC-SAT.)4 The extreme estimate
is now 10 feet of sea
level rise by 2100 at the Golden Gate (estimated by Sweet et.
al. at the National Oceanic and
Atmospheric Association (NOAA) in January 2017.)5
Under the highest Greenhouse Gas Emissions Scenario (RCP 8.5)
OPC-SAT estimated a
5% chance that sea level rise at the Golden Gate will be greater
than 53 inches (4.4 feet) by
2100, and a 0.5% chance that sea level rise will exceed 6.9 feet
by 2100. The table on page 28of
the OPC-SAT report (reproduced on the following page) shows the
OPC-SAT estimates of
probabilities of sea level rise at the Golden Gate. The table
includes estimates for medium and
low Greenhouse Gas Emissions scenarios (RCP 4.5 and RCP 2.6.)
The NOAA extreme
estimate of 10 feet by 2100 is identified as H++.
Estimates in the OPC-SAT report for high GHG emissions are
similar to high projections
by the U.S. Army Corps of Engineers, and by NOAA in 2012 for the
National Climate Change
Assessment. Values from the U.S. Army Corps of Engineers online
calculator are shown in the
table on the following page.6
4 Griggs, G, rvai, J, Cayan, D, DeConto, R, Fox, J, Fricker, HA,
Kopp, RE, Tebaldi, C, Whiteman, EA (California Ocean Protection
Council Science Advisory Team Working Group). Rising Seas in
California: An Update on Sea-
Level Rise Science. California Ocean Science Trust. 2017.
Available at
http://www.opc.ca.gov/webmaster/ftp/pdf/docs/rising-seas-in-california-an-update-on-sea-level-rise-science.pdf
5 Sweet, W.V., R.E. Kopp, C.P. Weaver, J. Obeysekera, R.M. Horton,
E.R. Thieler and CZ. NOAA Technical Report NOS CO-OPS 083, Global
and Regional Sea Level Rise Scenarios for the United States. 2017.
Available
at
https://tidesandcurrents.noaa.gov/publications/techrpt83_Global_and_Regional_SLR_Scenarios_for_the_US_fina
l.pdf 6 U.S. Army Corps of Engineers, Sea Level Change
Calculator. 2015. Available at
http://www.corpsclimate.us/ccaceslcurves.cfm
http://www.opc.ca.gov/webmaster/ftp/pdf/docs/rising-seas-in-california-an-update-on-sea-level-rise-science.pdf
https://tidesandcurrents.noaa.gov/publications/techrpt83_Global_and_Regional_SLR_Scenarios_for_the_US_final.pdf
https://tidesandcurrents.noaa.gov/publications/techrpt83_Global_and_Regional_SLR_Scenarios_for_the_US_final.pdf
http://www.corpsclimate.us/ccaceslcurves.cfm
-
1Sea level rise at the Golden Gate Source: OPC-SAT, Rising Seas
in California, April 2017
-
The Draft Delta Plan Amendment requires that
B. 1. Plans for the operation or reoperation of water conveyance
and control facilities in the Delta, or new or modified storage
facilities in the Delta and
its watershed, should further the achievement of the coequal
goals by
[]
(d) Demonstrating that projects can contribute a more reliable
water
supply, and can protect and enhance the Delta ecosystem under
a
range of future conditions, including changing climate and
National Research Council median projections of Bay-Delta
sea
level in 2050 and 2100, or other appropriate projections.
Section B(1)(d) redefines goals of reliability of water supply
to only consider sea level rise of
up to 33 inches by 2100 -- the 2012 National Research Councils
mean projection. How likely is
it that the value of 33 inches by 2100 will be exceeded?
According to the table on p. 31 of the Ocean Protection Councils
Science Advisory
Teams (OPC-SATs) new risk report, there is a 28% chance that sea
level rise at the Golden
Gate will exceed 3 feet by 2100, under the highest Greenhouse
Gas Emissions Scenario (RCP
8.5), and an 8% chance it will exceed 4 feet. (Reproduced on the
following page.) Thus
DWRs use of sea level rise estimates of 18 inches for the
WaterFix tunnels could result in a
useful lifetime of less than 50 years for the project.
-
21Sea level rise exceedances at the Golden Gate Source:
OPC-Science Advisory Team, Rising Seas in California, April
2017
The Programmatic EIR/EIS needs to consider the effects of
lowering the maximum sea level rise
considered from 55 inches to 33 inches.
B. Shifts in Hydrology
Water Code 85320(b)(2)(c) requires that, in order to be included
in the Delta Plan, the
BDCP EIR include
a comprehensive review and analysis of all of the following:
(C) The potential effects of climate change, possible sea level
rise up to 55
inches, and possible changes in total precipitation and runoff
patterns on the
conveyance alternatives and habitat restoration activities
considered in the
environmental impact report.
-
The new language would only require an analysis of possible
changes in total
precipitation and runoff patterns. This change would potentially
eliminate requirements that
the drier scenarios under climate change be included. This is
important because the ensemble of
112 climate change models in the Coupled Model Intercomparison
Project Third Assessment
Report (CMIP3) database, is known to have significant problems
in reproducing the climate
over Western North America.
A 2013 study by the Intergovernmental Panel on Climate Change
(IPCC) included
evaluations of how well the CMIP3 database of global climate
models represented regional
climates. (Gregory Flato et. al., Climate Change 2013 The
Physical Science Basis, Chapter 9:
Evaluation of Climate Models).7 This more recent study showed
that, while the CMIP3
ensemble does a reasonable job of reproducing historic
precipitation over Eastern North
America, Europe and the Mediterranean, and East Asia, there is a
significant bias for Western
North America. (p. 810-812.) Box and whisker plots in the study
show that for the 50th
percentile, the ensemble is approximately 30-40% wetter than
historical conditions for October
through March, and approximately 25% wetter annually.
7 Flato, G., J. Marotzke, B. Abiodun, P. Braconnot, S.C. Chou,
W. Collins, P. Cox, F. Driouech, S. Emori, V. Eyring, C. Forest, P.
Gleckler, E. Guilyardi, C. Jakob, V. Kattsov, C. Reason and M.
Rummukainen, Evaluation of Climate Models. In: Climate Change 2013:
The Physical Science Basis. Contribution of Working Group I to the
Fifth Assessment Report of the Intergovernmental Panel on Climate
Change, 2013. Cambridge University Press, Cambridge, United Kingdom
and New York, NY, US.
-
REGIONAL BIAS in CMIP3 and CMIP5 ENSEMBLE OF GLOBAL CLIMATE
MODELS
From Flato, G., J. Marotzke, B. Abiodun, P. Braconnot, S.C.
Chou, W. Collins, P. Cox, F.
Driouech, S. Emori, V. Eyring, C. Forest, P. Gleckler, E.
Guilyardi, C. Jakob, V. Kattsov, C.
Reason and M. Rummukainen, Evaluation of Climate Models. In:
Climate Change 2013: The
Physical Science Basis. Contribution of Working Group I to the
Fifth Assessment Report of the
Intergovernmental Panel on Climate Change, 2013. Cambridge
University Press, Cambridge, United
Kingdom and New York, NY, US.
p. 812
-
REGIONAL BIAS IN CMIP3
Figure 10. Close-up of Western North America (WNA) annual
precipitation bias,
From Flato et. al., Evaluation of Climate Models, p. 813
^
-
Appendix 5A-D of the BDCP Draft EIR/ Draft EIS shows that CH2M
Hill originally proposed to deal with uncertainty about regional
climate scenarios by developing projections for
subsets of the global climate model / climate scenario ensemble.
The ensemble was divided into
4 quadrants with projections of more warming and less warming,
and drier or wetter. A Central
Tendency for the ensemble was also calculated. SWRCB-4 (Appendix
5A-D, p. 35-36).
Appendix 5A-D, p. 33 stated that [t]he selected approach for
development of climate
scenarios for the BDCP incorporates three fundamental elements.
First, it relies on sampling of
the ensemble of GCM projections rather than one single
realization or a handful of individual
realizations. Second, it includes scenarios that both represent
the range of projections as well as
the central tendency of the projections. (emphasis added). This
would have been a reasonable
approach to uncertainty about regional climate change scenarios
if it was carried through to the
final WaterFix modeling. It also would have provided information
on possible climate shifts.
Instead, only the single Central Tendency projection has been
used for most BDCP and
WaterFix modeling and model results. The Central Tendency
scenario provides no information
about uncertainty in the BDCP / WaterFix projections of shifts
in hydrology.
As one can see from the graph on the next page of potential
changes in runoff, the
differences are large. Under the plain language of Water Code
85032(b)(2)(c), a comprehensive
analysis would have required consideration of the drier
scenarios.
-
The Programmatic EIR/EIS needs to consider the potential effects
of NOT requiring
comprehensive analysis of shifts in hydrology, including
regional drying.
2. Levee Investment
The Delta Levees Investment Strategy Amendment is not available
at the time of these
scoping comments, and so is not adequately defined for the
purpose of scoping. California
Water Research provides these preliminary comments.
The Department of Water Resources spent $80 million on extensive
evaluations of urban
levees in Sacramento, West Sacramento, Stockton, and Manteca.8
The only information that has
been used from that analysis is LIDAR information on the shape
of the levees. The Stockton
Area Flood Control Agency (SJAFCA) has worked with the Army
Corps of Engineers on a plan
to upgrade the Stockton levees to a 200 year level of
protection, which does include other
information on the condition of the levees. The Army Corps
released the Draft Interim
8 AECOM, Projects, California Department of Water Resources
Urban and Non-Urban Levee Evaluations. Available at
http://www.aecom.com/projects/california-department-of-water-resources-urban-and-non-urban-levee-
evaluations/.
http://www.aecom.com/projects/california-department-of-water-resources-urban-and-non-urban-levee-evaluations/
http://www.aecom.com/projects/california-department-of-water-resources-urban-and-non-urban-levee-evaluations/
-
Feasibility Study and Environmental Impact Statement /
Environmental Impact Report in
February 2015 for the Lower San Joaquin.9 In the feasibility
study, the Army Corps of
Engineers noted that 264,000 people live in floodplains in the
Stockton area, with $21 billion in
damageable property and 23 critical structures:
The existing levee system within the study area protects over
71,000 acres of
mixed-use land with a current population estimated at 264,000
residents and an
estimated $21 billion in damageable property. In addition to the
residents and property,
the levee system protects approximately 23 structures considered
to be critical
infrastructure (hospitals, police and fire stations, etc.) as
well as the Interstate 5 and
State Highway 99 corridors.
and concluded that
There is significant risk to public health, safety, and property
in the project area
associated with flooding.
(p. 90)
The Army Corps of Engineers Interim Feasibility Study and Draft
EIR/EIS explains the
problems with seepage in the Stockton levees:
The potential for seepage problems to occur along the existing
levees in the project area
is created by discontinuous layers of coarsegrained pervious
soils (i.e., sands and
gravels). These are found at varying depths of up to 100 feet.
During highwater events,
water from the river can enter the pervious soil layers and then
move laterally through
these layers under/through the levee. Excessive seepage can
erode soil within the levee
and lead to a rapid collapse and subsequent breach.
Historically, foundation conditions
were evaluated assuming homogeneous materials, but the floods of
1986 and 1997 and
the resulting levee failures throughout the Central Valley
resulted in a revision of the
criteria for the evaluation of under-seepage. The risk of levee
failure is not due to design
deficiency or to lack of O&M of the existing levees, but to
a better understanding of the
mechanics of underseepage in the Central Valley. The project
levees within the study
area do not meet current USACE levee design criteria and are at
risk of breach failure at
stages considerably less than levee crest elevations. This is
evidenced by historical levee
boils and heavy seepage at river stages less than design flows.
(p. 90, emphasis added.)
Similar seepage problems were seen in West Sacramento levees.
The Army Corps of
Engineers estimated that the risk and uncertainty of levee
failure was as high as 50% a year for
some of the levees protecting the northern part of the city. The
Programmatic EIR/EIS on the
Delta Plan Amendments needs to consider the consequences of NOT
including other available
information on the condition of the Stockton levees, from both
the Army Corps of Engineers,
and DWRs $80 million investigation.
9 Available at
http://www.spk.usace.army.mil/Portals/12/documents/usace_project_public_notices/LSJRFS_Draft_EIS-
EIR_Feb2015.pdf
http://www.spk.usace.army.mil/Portals/12/documents/usace_project_public_notices/LSJRFS_Draft_EIS-EIR_Feb2015.pdf
http://www.spk.usace.army.mil/Portals/12/documents/usace_project_public_notices/LSJRFS_Draft_EIS-EIR_Feb2015.pdf
-
Sincerely,
Deirdre Des Jardins
California Water Research
-
1 Stockton flooding, 1955 Source: Army Corps of Engineers
-
Deirdre Des Jardins
145 Beel Dr
Santa Cruz, CA 95060
(831) 423-6857
[email protected]
April 17, 2017 VIA electronic mail
Delta Stewardship Council
980 9th Street, Suite 1500
Sacramento, CA 95814
To Whom it May Concern:
California Water Research provides the following scoping
comments on Delta Plan
Amendments. The comments address risks from climate change and
not considering
information on levee condition in the Delta Levees Investment
Strategy.
1. Climate Change
The Scoping notice does not adequately describe the project. The
draft Amendment on
Water Conveyance, System Storage, and the Operation of Both
makes significant changes from
the mandates in the Delta Reform Act for analysis of sea level
rise in the BDCP/WaterFix
Environmental Impact Report.
These are the mandates in the 2009 Delta Reform Act:
85320 (b) The BDCP shall not be incorporated into the Delta Plan
and the public benefits
associated with the BDCP shall not be eligible for state
funding, unless the BDCP does
all of the following:
[]
mailto:[email protected]
-
(2) Complies with Division 13 (commencing with Section 21000) of
the Public
Resources Code, including a comprehensive review and analysis of
all of the following:
[]
(C) The potential effects of climate change, possible sea level
rise up to 55 inches,
and possible changes in total precipitation and runoff patterns
on the conveyance
alternatives and habitat restoration activities considered in
the environmental
impact report.
This is the revised language in the draft amendment:
B. 1. Consistent with Delta Plan policies and recommendations,
new and
improved Delta conveyance infrastructure should be based on
an
evaluation of alternatives for conveyance of CVP and SWP
water
supplies from the Sacramento River to the South Delta that
includes all of
the following analyses:
[]
(c) The potential effects of climate change, including possible
sea
level rise in 2030 and 2070 as projected by the National
Research
Council, or other appropriate projections, and possible changes
in
total precipitation and runoff patterns on the conveyance
alternatives under consideration.
The draft Delta Plan amendment significantly weakens the
statutory language in Water Code
85032(b)(2)(c), deleting the requirement that the climate change
analyses be comprehensive, and
consider possible sea level rise of up to 55 inches. The draft
Delta Plan amendment also does
not define what it means projections of the National Research
Council, or other appropriate
projections.
A. Sea Level Rise
The 2012 report by the National Research Council on Sea-Level
Rise for the Coasts of California,
Oregon, and Washington1 defines both a mean projection and a
range, as well as a range of semi-
empirical projections. The table below, from page 89, shows the
mean projection for 2100 is
82.7 centimeters, or 33 inches, with a range of up to 55 inches.
The semi-empirical projection
has a range of up to 175 centimeters, or 69 inches.
There are no NRC projections for 2070. The mean projection for
2050 is 28 centimeters,
or 11 inches, with a range of up to 48.2 centimeters, or 19
inches. Using a linear interpolation
to get values at 2070 gives a mean of 20 inches, with a range of
up to 33 inches. The NRC
mean projection of 20 inches at 2070 is considerably lower than
55 inches. It is close to the
1 National Research Council, Sea-Level Rise for the Coasts of
California, Oregon, and Washington: Past, Present, and Future.
Washington, DC: The National Academies Press. 2012. Available
at
https://www.nap.edu/catalog/13389/sea-level-rise-for-the-coasts-of-california-oregon-and-washington
https://www.nap.edu/catalog/13389/sea-level-rise-for-the-coasts-of-california-oregon-and-washington
-
value of 18 inches by 2065 used in the BDCP/WaterFix tunnels
engineering and Environmental
Impact Report.
The Delta Independent Science Board (ISB) was harshly critical
of the climate change
assumptions in the BDCP Draft EIR/EIS2, stating:
The potential effects of climate change and sea-level rise are
underestimated. . . . The
potential direct effects of climate change and sea-level rise on
the effectiveness of actions,
including operations involving new water conveyance facilities,
are not adequately
considered. . . . We believe this is dangerously unrealistic.
CEQA requires impacts to be
assessed "in order to provide decision makers enough information
to make a reasoned
choice about the project and its alternatives."
The Department of Water Resources (DWR) responded to the Delta
ISB's review, stating
that "the scope of an EIR/EIS is to consider the effects of the
project on the environment, and not
the environment on the project." However, the plain meaning of
85032(b)(2)(C) required
consideration of the effects of sea level rise of up to 55
inches on the project. In Chapter 9 of
the WaterFix Final EIR/EIS, DWR quietly disclosed that
underestimating sea level rise in the
WaterFix tunnel design could result in saltwater intrusion into
water supplies and damage to
infrastructure3:
Underestimating sea level rise in the project design will result
in harmful realized
impacts such as flooding. Harmful impacts are more likely to
occur if the project design
is based upon a low projection of sea level rise and less likely
if higher estimates of sea
2 Delta Independent Science Board, Review of the Draft EIR/EIS
for the Bay Delta Conservation Plan. 2014. Available at
http://deltacouncil.ca.gov/sites/default/files/documents/files/Attachment-1-Final-BDCP-comments.pdf
3 WaterFix Final EIR/EIS, Volume I, Chapter 9 Geology and
Seismicity. 2016. Available at
http://baydeltaconservationplan.com/Libraries/Dynamic_Document_Library/Final_EIR-EIS_Chapter_9_-
_Geology_and_Seismicity.sflb.ashx
http://deltacouncil.ca.gov/sites/default/files/documents/files/Attachment-1-Final-BDCP-comments.pdfhttp://baydeltaconservationplan.com/Libraries/Dynamic_Document_Library/Final_EIR-EIS_Chapter_9_-_Geology_and_Seismicity.sflb.ashxhttp://baydeltaconservationplan.com/Libraries/Dynamic_Document_Library/Final_EIR-EIS_Chapter_9_-_Geology_and_Seismicity.sflb.ashx
-
level rise are used. In situations with high consequences (high
impacts and/or low
adaptive capacity), using a low sea level rise value involves a
higher degree of risk.
(Examples of harmful impacts that might result from
underestimating sea level rise
include damage to infrastructure, contamination of water
supplies due to saltwater
intrusion, and inundation of marsh restoration projects located
too low relative to the
tides). (Chapter 9, section 9.2.2.6)
The Delta Plan Amendment Programmatic EIR needs to evaluate the
consequences of not
requiring a comprehensive analysis of the effects of sea level
rise of up to 55 inches on the
WaterFix project, which include the harmful impacts described in
the Final EIR/EIS.
Sea level rise of up to 55 inches by 2100 is no longer an
extreme estimate. It is now a
95% exceedance value, according to recent released risk
estimates of the Ocean Protection
Councils Science Advisory Team (OPC-SAT.)4 The extreme estimate
is now 10 feet of sea
level rise by 2100 at the Golden Gate (estimated by Sweet et.
al. at the National Oceanic and
Atmospheric Association (NOAA) in January 2017.)5
Under the highest Greenhouse Gas Emissions Scenario (RCP 8.5)
OPC-SAT estimated a
5% chance that sea level rise at the Golden Gate will be greater
than 53 inches (4.4 feet) by
2100, and a 0.5% chance that sea level rise will exceed 6.9 feet
by 2100. The table on page 28of
the OPC-SAT report (reproduced on the following page) shows the
OPC-SAT estimates of
probabilities of sea level rise at the Golden Gate. The table
includes estimates for medium and
low Greenhouse Gas Emissions scenarios (RCP 4.5 and RCP 2.6.)
The NOAA extreme
estimate of 10 feet by 2100 is identified as H++.
Estimates in the OPC-SAT report for high GHG emissions are
similar to high projections
by the U.S. Army Corps of Engineers, and by NOAA in 2012 for the
National Climate Change
Assessment. Values from the U.S. Army Corps of Engineers online
calculator are shown in the
table on the following page.6
4 Griggs, G, rvai, J, Cayan, D, DeConto, R, Fox, J, Fricker, HA,
Kopp, RE, Tebaldi, C, Whiteman, EA (California Ocean Protection
Council Science Advisory Team Working Group). Rising Seas in
California: An Update on Sea-
Level Rise Science. California Ocean Science Trust. 2017.
Available at
http://www.opc.ca.gov/webmaster/ftp/pdf/docs/rising-seas-in-california-an-update-on-sea-level-rise-science.pdf
5 Sweet, W.V., R.E. Kopp, C.P. Weaver, J. Obeysekera, R.M. Horton,
E.R. Thieler and CZ. NOAA Technical Report NOS CO-OPS 083, Global
and Regional Sea Level Rise Scenarios for the United States. 2017.
Available
at
https://tidesandcurrents.noaa.gov/publications/techrpt83_Global_and_Regional_SLR_Scenarios_for_the_US_fina
l.pdf 6 U.S. Army Corps of Engineers, Sea Level Change
Calculator. 2015. Available at
http://www.corpsclimate.us/ccaceslcurves.cfm
http://www.opc.ca.gov/webmaster/ftp/pdf/docs/rising-seas-in-california-an-update-on-sea-level-rise-science.pdfhttps://tidesandcurrents.noaa.gov/publications/techrpt83_Global_and_Regional_SLR_Scenarios_for_the_US_final.pdfhttps://tidesandcurrents.noaa.gov/publications/techrpt83_Global_and_Regional_SLR_Scenarios_for_the_US_final.pdfhttp://www.corpsclimate.us/ccaceslcurves.cfm
-
1Sea level rise at the Golden Gate Source: OPC-SAT, Rising Seas
in California, April 2017
-
The Draft Delta Plan Amendment requires that
B. 1. Plans for the operation or reoperation of water conveyance
and control facilities in the Delta, or new or modified storage
facilities in the Delta and
its watershed, should further the achievement of the coequal
goals by
[]
(d) Demonstrating that projects can contribute a more reliable
water
supply, and can protect and enhance the Delta ecosystem under
a
range of future conditions, including changing climate and
National Research Council median projections of Bay-Delta
sea
level in 2050 and 2100, or other appropriate projections.
Section B(1)(d) redefines goals of reliability of water supply
to only consider sea level rise of
up to 33 inches by 2100 -- the 2012 National Research Councils
mean projection. How likely is
it that the value of 33 inches by 2100 will be exceeded?
According to the table on p. 31 of the Ocean Protection Councils
Science Advisory
Teams (OPC-SATs) new risk report, there is a 28% chance that sea
level rise at the Golden
Gate will exceed 3 feet by 2100, under the highest Greenhouse
Gas Emissions Scenario (RCP
8.5), and an 8% chance it will exceed 4 feet. (Reproduced on the
following page.) Thus
DWRs use of sea level rise estimates of 18 inches for the
WaterFix tunnels could result in a
useful lifetime of less than 50 years for the project.
-
21Sea level rise exceedances at the Golden Gate Source:
OPC-Science Advisory Team, Rising Seas in California, April
2017
The Programmatic EIR/EIS needs to consider the effects of
lowering the maximum sea level rise
considered from 55 inches to 33 inches.
B. Shifts in Hydrology
Water Code 85320(b)(2)(c) requires that, in order to be included
in the Delta Plan, the
BDCP EIR include
a comprehensive review and analysis of all of the following:
(C) The potential effects of climate change, possible sea level
rise up to 55
inches, and possible changes in total precipitation and runoff
patterns on the
conveyance alternatives and habitat restoration activities
considered in the
environmental impact report.
-
The new language would only require an analysis of possible
changes in total
precipitation and runoff patterns. This change would potentially
eliminate requirements that
the drier scenarios under climate change be included. This is
important because the ensemble of
112 climate change models in the Coupled Model Intercomparison
Project Third Assessment
Report (CMIP3) database, is known to have significant problems
in reproducing the climate
over Western North America.
A 2013 study by the Intergovernmental Panel on Climate Change
(IPCC) included
evaluations of how well the CMIP3 database of global climate
models represented regional
climates. (Gregory Flato et. al., Climate Change 2013 The
Physical Science Basis, Chapter 9:
Evaluation of Climate Models).7 This more recent study showed
that, while the CMIP3
ensemble does a reasonable job of reproducing historic
precipitation over Eastern North
America, Europe and the Mediterranean, and East Asia, there is a
significant bias for Western
North America. (p. 810-812.) Box and whisker plots in the study
show that for the 50th
percentile, the ensemble is approximately 30-40% wetter than
historical conditions for October
through March, and approximately 25% wetter annually.
7 Flato, G., J. Marotzke, B. Abiodun, P. Braconnot, S.C. Chou,
W. Collins, P. Cox, F. Driouech, S. Emori, V. Eyring, C. Forest, P.
Gleckler, E. Guilyardi, C. Jakob, V. Kattsov, C. Reason and M.
Rummukainen, Evaluation of Climate Models. In: Climate Change 2013:
The Physical Science Basis. Contribution of Working Group I to the
Fifth Assessment Report of the Intergovernmental Panel on Climate
Change, 2013. Cambridge University Press, Cambridge, United Kingdom
and New York, NY, US.
-
REGIONAL BIAS in CMIP3 and CMIP5 ENSEMBLE OF GLOBAL CLIMATE
MODELS
From Flato, G., J. Marotzke, B. Abiodun, P. Braconnot, S.C.
Chou, W. Collins, P. Cox, F.
Driouech, S. Emori, V. Eyring, C. Forest, P. Gleckler, E.
Guilyardi, C. Jakob, V. Kattsov, C.
Reason and M. Rummukainen, Evaluation of Climate Models. In:
Climate Change 2013: The
Physical Science Basis. Contribution of Working Group I to the
Fifth Assessment Report of the
Intergovernmental Panel on Climate Change, 2013. Cambridge
University Press, Cambridge, United
Kingdom and New York, NY, US.
p. 812
-
REGIONAL BIAS IN CMIP3
Figure 10. Close-up of Western North America (WNA) annual
precipitation bias,
From Flato et. al., Evaluation of Climate Models, p. 813
^
-
Appendix 5A-D of the BDCP Draft EIR/ Draft EIS shows that CH2M
Hill originally proposed to deal with uncertainty about regional
climate scenarios by developing projections for
subsets of the global climate model / climate scenario ensemble.
The ensemble was divided into
4 quadrants with projections of more warming and less warming,
and drier or wetter. A Central
Tendency for the ensemble was also calculated. SWRCB-4 (Appendix
5A-D, p. 35-36).
Appendix 5A-D, p. 33 stated that [t]he selected approach for
development of climate
scenarios for the BDCP incorporates three fundamental elements.
First, it relies on sampling of
the ensemble of GCM projections rather than one single
realization or a handful of individual
realizations. Second, it includes scenarios that both represent
the range of projections as well as
the central tendency of the projections. (emphasis added). This
would have been a reasonable
approach to uncertainty about regional climate change scenarios
if it was carried through to the
final WaterFix modeling. It also would have provided information
on possible climate shifts.
Instead, only the single Central Tendency projection has been
used for most BDCP and
WaterFix modeling and model results. The Central Tendency
scenario provides no information
about uncertainty in the BDCP / WaterFix projections of shifts
in hydrology.
As one can see from the graph on the next page of potential
changes in runoff, the
differences are large. Under the plain language of Water Code
85032(b)(2)(c), a comprehensive
analysis would have required consideration of the drier
scenarios.
-
The Programmatic EIR/EIS needs to consider the potential effects
of NOT requiring
comprehensive analysis of shifts in hydrology, including
regional drying.
2. Levee Investment
The Delta Levees Investment Strategy Amendment is not available
at the time of these
scoping comments, and so is not adequately defined for the
purpose of scoping. California
Water Research provides these preliminary comments.
The Department of Water Resources spent $80 million on extensive
evaluations of urban
levees in Sacramento, West Sacramento, Stockton, and Manteca.8
The only information that has
been used from that analysis is LIDAR information on the shape
of the levees. The Stockton
Area Flood Control Agency (SJAFCA) has worked with the Army
Corps of Engineers on a plan
to upgrade the Stockton levees to a 200 year level of
protection, which does include other
information on the condition of the levees. The Army Corps
released the Draft Interim
8 AECOM, Projects, California Department of Water Resources
Urban and Non-Urban Levee Evaluations. Available at
http://www.aecom.com/projects/california-department-of-water-resources-urban-and-non-urban-levee-
evaluations/.
http://www.aecom.com/projects/california-department-of-water-resources-urban-and-non-urban-levee-evaluations/http://www.aecom.com/projects/california-department-of-water-resources-urban-and-non-urban-levee-evaluations/
-
Feasibility Study and Environmental Impact Statement /
Environmental Impact Report in
February 2015 for the Lower San Joaquin.9 In the feasibility
study, the Army Corps of
Engineers noted that 264,000 people live in floodplains in the
Stockton area, with $21 billion in
damageable property and 23 critical structures:
The existing levee system within the study area protects over
71,000 acres of
mixed-use land with a current population estimated at 264,000
residents and an
estimated $21 billion in damageable property. In addition to the
residents and property,
the levee system protects approximately 23 structures considered
to be critical
infrastructure (hospitals, police and fire stations, etc.) as
well as the Interstate 5 and
State Highway 99 corridors.
and concluded that
There is significant risk to public health, safety, and property
in the project area
associated with flooding.
(p. 90)
The Army Corps of Engineers Interim Feasibility Study and Draft
EIR/EIS explains the
problems with seepage in the Stockton levees:
The potential for seepage problems to occur along the existing
levees in the project area
is created by discontinuous layers of coarsegrained pervious
soils (i.e., sands and
gravels). These are found at varying depths of up to 100 feet.
During highwater events,
water from the river can enter the pervious soil layers and then
move laterally through
these layers under/through the levee. Excessive seepage can
erode soil within the levee
and lead to a rapid collapse and subsequent breach.
Historically, foundation conditions
were evaluated assuming homogeneous materials, but the floods of
1986 and 1997 and
the resulting levee failures throughout the Central Valley
resulted in a revision of the
criteria for the evaluation of under-seepage. The risk of levee
failure is not due to design
deficiency or to lack of O&M of the existing levees, but to
a better understanding of the
mechanics of underseepage in the Central Valley. The project
levees within the study
area do not meet current USACE levee design criteria and are at
risk of breach failure at
stages considerably less than levee crest elevations. This is
evidenced by historical levee
boils and heavy seepage at river stages less than design flows.
(p. 90, emphasis added.)
Similar seepage problems were seen in West Sacramento levees.
The Army Corps of
Engineers estimated that the risk and uncertainty of levee
failure was as high as 50% a year for
some of the levees protecting the northern part of the city. The
Programmatic EIR/EIS on the
Delta Plan Amendments needs to consider the consequences of NOT
including other available
information on the condition of the Stockton levees, from both
the Army Corps of Engineers,
and DWRs $80 million investigation.
9 Available at
http://www.spk.usace.army.mil/Portals/12/documents/usace_project_public_notices/LSJRFS_Draft_EIS-
EIR_Feb2015.pdf
http://www.spk.usace.army.mil/Portals/12/documents/usace_project_public_notices/LSJRFS_Draft_EIS-EIR_Feb2015.pdfhttp://www.spk.usace.army.mil/Portals/12/documents/usace_project_public_notices/LSJRFS_Draft_EIS-EIR_Feb2015.pdf
-
Sincerely,
Deirdre Des Jardins
California Water Research
-
1 Stockton flooding, 1955 Source: Army Corps of Engineers
4-17-17 Deirdre Des Jardins 14-17-17 Deirdre Des Jardins 2
