Dec 12, 2023 – by Chuck Parker
COMMENTS ON NEAR TERM COLORADO RIVER OPERATIONS – 2024-2026, BEING DEVELOPED BY THE US BUREAU OF RECLAMATION. THIS PROCESS IS TECHNICALLY KNOWN AS THE REVISED DRAFT SEIS (SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT) October 27, 2023.
To US BUREAU OF RECLAMATION: CRinterimops@usbr.gov
I am not a scientist, engineer, corporate employee, politician, or government bureaucrat. It has been a struggle for me to understand and penetrate the alphabet soup of acronyms and tortured language in your report. I am a retired postal worker and community activist who would like to see the health of the 500,000 people who live near the Salton Sea protected, and the Salton Sea restored.
For five years I have been a member of the Salton Sea Coalition which is an organization which is made up of community members who volunteer our time and energy to achieve these goals – Restore the Sea, and Protect Public Health. Until December of 2022 we participated in meetings of the Salton Sea Management Plan or 10 Year Plan. Our goal was to influence the state and local agencies to adopt ocean water importation as the plan for restoring the sea. We did get all nine Coachella Valley city councils, the Board of Trustees of the College of the Desert, the Energy and Environment Committee of the Coachella Valley Association of Governments, and the membership of the Torres Martinez tribe to pass resolutions in favor of ocean water importation to refill and restore the Salton Sea.
However, the Salton Sea Management Plan, and the Salton Sea Authority refused accept ocean water import. Instead they concocted the UC Santa Cruz Study which was a failure and later forwarded a list of so-called “in-basin” plans to the Army Corps of Engineers to evaluate in another three or four year study. The name given to this study is the “Imperial Streams Salton Sea and Tributaries” feasibility study or ISSST. The name would make any real estate salesman proud! It evokes images of sparkling streams rushing down mountainsides to a beautiful mountain lake. Sadly the primary tributaries to the Salton Sea are the New and Alamo Rivers which are two of the most polluted rivers in the U.S. They look like muddy irrigation ditches, and the only thing about them that is imperial is that they flow from Mexico through Imperial County to the Salton Sea. This name also reinforces the bias of the agencies who have recommended relying on the “in-basin” water sources and tributaries. (The idea that these small and shrinking tributaries could support the restoration of the Salton Sea is pure fantasy and magical thinking.)
The California Natural Resources Agency and the Salton Sea Authority will be advising the Army Corps in this study. These biased agencies, who are against restoring the Salton Sea through importing ocean water, should not be advising the Army Corps of Engineers in this feasibility study. It is imperative that the Army Corps conduct a feasibility level study of ocean water import as part of their current study. If they are unable, other federal agencies such as the Department of Interior, and the Bureau of Reclamation should do this as part of their planning for the post 2026 Colorado River Operations. An effective and permanent restoration of the Salton Sea needs to be part of the Post 2026 Program!
The Bureau of Reclamation, is formulating plans to address the water supply shortage of the Colorado River, which used to supply 100% of the water that ended up in the Salton Sea. The Salton Sea had been part of the Colorado River watershed for over five million years. It is one of the places where the river would flow as it flooded and ebbed over those many years. This natural connection to the Colorado River was severed when the government decided to build the Hoover Dam to prevent the flooding of the river in order to protect the agricultural industries developing in California. Agricultural runoff then became the primary source of water for the Salton Sea. For more than 100 years, federal management of the Colorado River has chronically ignored the Salton Sea.
This water supply was curtailed in 2003 when the QSA agreement set up the largest transfer/sale of water in U.S. history. 500,000 acre feet of water is now being transferred to San Diego, Los Angeles and the Coachella Valley. Everyone knew damage would be caused by the drying of the lake as water was transferred away to the cities. In order to get the QSA approved, the state of California passed the Salton Sea Restoration Act which obligated the state to prevent environmental harm to the lake, the wildlife, and the people. Until now the state has put off action to restore the Salton Sea and instead has studied and talked about lessoning the harm through temporary and piecemeal projects like the ones in their Ten Year Plan. However, as of 2023 the Ten Year Plan has not achieved any of its piecemeal goals, nor have any projects begun to operate.
Due to the decline of Colorado River water, the Reclamation’s Proposed Action for 2024-2026 has chosen the Lower Basin Proposal made by California, Arizona, and Nevada. The plan is to conserve an additional 3 million acre feet of water during this two year period. The Bureau proposes to use federal money from the Inflation Reduction Act to pay for 2/3 of the conserved water. This large reduction will greatly reduce the flow of fresh water into the Salton Sea. In addition to these proposed cuts, the Imperial Irrigation District announced on December 1, 2023 that they would conserve an additional 800,000 acre feet of water in 2024-2026. No wonder the Salton Sea is drying up so rapidly!
Due to those proposed cuts, the flow of water to the Salton Sea will be at least 267,000 acre feet less during 2024-26. Reclamation may be justified in thinking that these reductions are necessary because of the lower flows in the Colorado river, but they must also start to recognize the need to find water to prevent the destruction of the Salton Sea. We cannot allow the Salton Sea to become a zone of sacrifice when it can be prevented. The Bureau has expressed that it doesn’t matter if the proposed cuts will cause the Salton Sea to go down more quickly, because the damage done by the QSA water transfers will eventually kill the sea anyway. This is like saying that it doesn’t matter if a husband person murders his wife, because she would die eventually anyway! This is completely insane!
This Bureau of Reclamation document goes through the possible ways that their Proposed Action for 2024-2026 might harm the Salton Sea. It says that any harm done to the salinity, temperature, sedimentation, dissolved oxygen, nutrients and algae, metals and other contaminants, or air quality don’t matter. It repeats over and over again that any possible harm will be offset by the improvements to all these conditions made by the 10 Year Plan! There is no basis for this statement. As stated above, so far there have been no improvements made by the 10 Year Plan, and conditions continue to worsen. The Bureau of Reclamation is relying on the bad advice, and invalid assumptions of California Natural Resources Agency and the Salton Sea Authority.
Because of this reliance, the Reclamation report is neither scientific nor objective in the following ways:
a) to estimate future Colorado water flows it relies on the model used by Tetra Tech, a consulting firm used by the Salton Sea Management Plan to develop the various “in basin” restoration plans. Tetra Tech’s model is based on the Salton Sea Accounting Model which was developed 20 years ago by Reclamation, before the QSA and the drought. This model has been altered by Tetra Tech for use with the Salton Sea Management Plan. Criminally, Tetra Tech has concealed it’s methods so it can’t be evaluated by independent experts. During the meetings of the Long Range Planning Committee in 2023, several members raised objections to the role played by Tetra Tech because it was a conflict of interest since they wanted to be given contracts to complete some of the proposed projects. James Newcomb, chair of the committee, refused to discuss these objections. Tetra Tech’s integrity has also been questioned because it has been sued by the Department of the Navy because it falsified soil samples in the Hunter’s Point area in 2019.
b) the report fails to present remedies in case their modeling of water supplies are too high.
c) the discussion of impacts of the proposed cuts in water supply to the Salton Sea are inadequate and unreasonable.
d) the report relies on insufficient, speculative and ineffective mitigation measures.
Article 1 of the Colorado River Compact of 1922 states that the purpose of the Compact is to insure “equitable division and apportionment of the use of the Colorado River system.” However, the discussion, being undertaken by the Bureau of Reclamation to come to a new river Compact, has disregarded the inequity of denying a critical water supply to the Salton Sea.
The federal government must live up to its legal obligation to avoid harm to the environment, wildlife and human life under the National Environmental Policy Act (NEPA.) The only way to restore the Salton Sea is to import ocean water from the Sea of Cortez or the Pacific Ocean. This ocean water can be desalinated and made into potable water. This will guarantee a supply of fresh water to the Salton Sea that will be independent of the Colorado River and climate change. Restoring the Salton Sea will have beneficial effects on the whole environment of the drier and hotter Southwest. In this way federal water managers can equitably distribute the water from the Colorado river, restore the Salton Sea, and enhance the quality of life in the region.
P.S. The Arizona Department of Water has already completed a feasibility study of importing desalinated ocean water from the Sea of Cortez. This study was completed by the reputable engineering firm Black & Vetch. Their estimated costs for a dual pipeline were twelve times lower than the discredited UC Santa Cruz study of ocean water importation commissioned by the California Natural Resources Agency in 2022.
P.P.S. Many thanks to Jenny Ross whose Comments on the Draft Supplemental EIR for Near-Term Colorado River Operations, Dec. 5, 2023, and her Comments on Development of Post 2026 Colorado River Management, August 14, 2023 have been essential to my understanding of this complex process.
Thank you, Chuck Parker
Salton Sea Coalition 