DELTA PROTECTION COMMISSION
Diane Burgis, Chair (Contra Costa County Board of Supervisors)
2101 Stone Blvd., Suite 200, West Sacramento, CA 95691
(916) 375-4800 | delta.ca.gov
June 14, 2024
The Honorable John Garamendi
United States House of Representatives
2004 Rayburn House Office Building
Washington, DC 20515
Subject: Support for H.R. 7719, Abandoned and Derelict Vessel Removal Act of 2024
Dear Congressman Garamendi:
I write to express the Delta Protection Commission’s strong support for this legislation. The Commission has long advocated for removal of abandoned and derelict vessels (ADVs) from Delta waterways, and remediation of the environmental damage ADVs cause to the rivers and sloughs that are vital to irrigating farmland, supporting recreational and commercial fisheries, and providing enjoyment in all kinds of water recreation. ADVs pose real and significant threats to public safety and property from navigation hazards, and damage to docks, marinas, and levees.
The Delta Protection Commission is a California state agency charged with protecting and enhancing the unique values of the Sacramento-San Joaquin Delta, a resource of state and national importance that, largely owing to your tireless efforts, was recognized by Congress as California’s first and so far only National Heritage Area in 2019. The Commission provides a “forum for Delta residents to engage in decisions regarding actions to recognize and enhance the unique cultural, recreational, and agricultural resources of the Delta” [Public Resources Code (PRC) § 29703.5(a)]. As such it includes representatives from city and county governments in each of the five main Delta counties, Delta reclamation districts, four state agencies and one non-voting, ex-officio member each from the Senate and Assembly.
As a primary function, the Commission maintains and oversees implementation of a comprehensive long-term Land Use and Resource Management Plan (LURMP) that includes goals and policies aimed at protecting, maintaining, enhancing, and restoring the overall quality of the Delta environment. Public Resources Code applicable to ADVs requires that the LURMP policies must “preserve and protect open-space and outdoor recreational opportunities,” “preserve and protect opportunities for controlled public access and use of public lands and waterways consistent with protection of natural resources and private property interests,” and “preserve, protect and maintain navigation” [PRC§29760 (b)(9-11)].
The Commission has worked with local law enforcement marine patrol units, the U.S. Coast Guard (USCG), the State Parks’ Division of Boating and Waterways (Boating and Waterways), State Lands Commission, Recreational Boaters of California, CalRecycle, the Bay Conservation and Development Commission, and other stakeholders to promote and facilitate abandoned vessel removal. The Commission’s collaborative project with the Department of Fish and Wildlife’s Office of Spill Prevention and Response to identify and map ADVs within the Delta in 2019 led to state legislation that provides limited funding for removal of commercial ADVs by the State Lands Commission. Additional funding by Boating and Waterways supports removal of recreational vehicles. The USCG can only remove hazards to navigation. Thus it typically falls to local law enforcement marine units with limited resources to remove non-commercial ADVs in their counties. However, the scope of all these efforts is significantly constrained, largely due to funding, and limitations on where and how federal agencies such as the USCG and the U.S. Army Corps of Engineers (Corps) could assist.
The Abandoned and Derelict Vessel Removal Act, H.R. 7719, would bring much needed cohesion to this patchwork management by providing additional funding and organization. Significantly, the bill would authorize the Corps to remove any abandoned vehicles regardless whether they impede navigation, and to create and maintain a national inventory of ADVs. Such an inventory could help identify more regional-based solutions and coordination in areas such as the Delta where there is overlapping jurisdiction among responsible agencies.
Thank you for your commitment to finding solutions to this complex public safety issue of concern to Delta farmers, residents, and business owners, and the many visitors who come to the Delta.
Sincerely,
Bruce Blodgett
Executive Director
CC: The Honorable Laphonza Butler, U.S. Senator
The Honorable Alex Padilla, U.S. Senator
The Honorable Mark DeSaulnier, U.S. Representative
The Honorable Josh Harder, U.S. Representative
The Honorable Doris Matsui, U.S. Representative
The Honorable Mike Thompson, U.S. Representative
RIO VISTA, Calif. (May 16, 2024) – The Delta Protection Commission appointed two new members and re-appointed four incumbents to the Delta Protection Advisory Committee (DPAC) on Thursday.
The new appointees are Emily Pappalardo, Delta Business Seat 2 (on the left in the photo), and Katherine Wiley, Delta General Public Seat 2 (on the right in the photo). Both are graduates of the Delta Leadership Program, a project of the Delta Protection Commission and Delta Leadership Foundation – Pappalardo in 2016, and Wiley this year.
Pappalardo is a principal engineer and partner in DCC Engineering Co. Inc. in Walnut Grove, which serves several reclamation districts in the North Delta and provides permitting, planning, and architectural services to the Delta community. She has an interest in Steamboat Resort, a private boat club and residence on the north end of Steamboat Slough, where she was raised. She is also incoming president of the Rotary Club of Walnut Grove, a board member of the Delta Leadership Foundation, an associate member of the Central Valley Flood Control Association, and a volunteer on the Pear Fair Committee.
Wiley owns Wiley Marketing & Design, which has a substantial client base in Rio Vista, Walnut Grove and Locke. She and her husband own a houseboat that’s been berthed in Walnut Grove for the past eight years, and both are avid boaters who spend most of their free time on the river.
The incumbents who were reappointed Thursday are:
- Craig Watanabe, Delta Agriculture (Seat 2)
- Douglas Hsia, Delta Cultural Preservation
- Morris Lum, Delta Recreation (Seat 2)
- Erin Chappell, State Agency (Seat 2)
All six will serve three -year terms.
DPAC provides recommendations to the Delta Protection Commission on diverse interests within the Delta, including the Delta’s socioeconomic sustainability, recreation, agriculture, flood control, environment, utility infrastructure, and other Delta issues. The Committee was created by the Delta Protection Act, Public Resources Code Section 29753(a).
Steven Hutchason
HOOD, Calif. (March 8, 2024) – The Delta Protection Commission appointed Steven Hutchason to the Delta Protection Advisory Committee (DPAC) on Thursday.
Hutchason is the Tribal Historic Preservation Officer for the Wilton Rancheria, a tribe whose indigenous territory encompasses Sacramento County. He is a descendent of the first people of the Delta.
Hutchason fills a new tribal-representative seat that was added in September when the Commission voted to expand DPAC. It also added a general public seat, bringing the committee size to 17. Hutchason will serve a three-year term.
DPAC provides recommendations to the Delta Protection Commission on diverse interests within the Delta, including the Delta’s socioeconomic sustainability, recreation, agriculture, flood control, environment, utility infrastructure, and other Delta issues.
The Committee was created by the Delta Protection Act, Public Resources Code Section 29753(a).
Top: Commissioners Paul Steele (left) and Jim Paroli (right). Bottom L-R: Commissioner Alan Nakanishi, NHA Advisory Committee Chair Elizabeth Patterson, DPC Program Manager Blake Roberts
HOOD, Calif. (March 7, 2024) – The Delta Protection Commission (DPC) today approved a draft of the Management Plan for the Sacramento-San Joaquin Delta National Heritage Area (Delta NHA) to submit to the Secretary of the Interior.
“There’s no place in the world like the Delta, with its unique geology, ecology, and history,” said Commission Chair Diane Burgis. “The Management Plan is our roadmap for how we talk about our history and how different agencies and community groups throughout the Delta’s five counties can work together to celebrate our shared heritage.
“Approving the Plan today is a big step toward receiving federal support and starting work on the ground,” she said.
The Commission’s action follows a 30-day public comment period on the draft plan. This is a critical part of the process, because unlike National Parks, National Heritage Areas are large, lived-in spaces. Local communities’ input is essential.
“We are so grateful to everyone who took time to attend meetings, review and comment on the draft Management Plan, and write letters of commitment,” said DPC Executive Director Bruce Blodgett. “Your input makes the plan stronger, and the partnerships that will come from letters of commitment ensure the Delta NHA becomes a vibrant resource that all Californians can be proud of.”
Among its supporters are members of the Delta’s Congressional Delegation: John Garamendi, Josh Harder, Ami Bera, Mike Thompson, Mark DeSaulnier, and Doris Matsui. They noted in support letters that approval of the management plan is key to unlocking funding authorized by Congress for the NHA – up to $10 million over 10 years.
The Delta National Heritage Area – the first and so far only NHA in California – was created in 2019 by Congress (PDF). It is one of 62 NHAs – places where historic, cultural, and natural resources create cohesive, nationally important landscapes.
The NHA’s boundary extends from Sacramento to Stockton to Vallejo with the junction of the Sacramento and San Joaquin rivers at its heart. The history of California’s Delta and Carquinez Strait is a rich tapestry of indigenous peoples and immigrants from around the world, natural beauty and wildlife and engineering marvels, bustling metropolitan areas and picturesque rural towns. The native peat soils provide for fertile cropland and its water supports 27 million Californians.
The Delta Protection Commission, a California state agency, was designated the local coordinating entity for the Delta NHA. It drafted the Management Plan in cooperation with the commission’s Delta NHA Management Plan Advisory Committee, the National Park Service, California State Parks, tribes, and stakeholders.
The Management Plan will now be submitted to the National Park Service, under the Secretary of the Interior, for approval, a process that could take six months. After federal approval, the plan will come back to the Commission for a final vote, and implementation of the plan can begin.
Media contact: Blake Roberts, (530) 650-6572 or blake.roberts@delta.ca.gov
The Delta Protection Commission reviews hundreds of local and regional land use projects in the Primary and Secondary zones of the Delta for consistency with the Land Use and Resource Management Plan (PDF) and submits comment letters to ensure projects stay on track with the Plan. Under state law (Public Resources Code Sections 29770-29772), any action taken by a local government or agency in the Primary Zone that is inconsistent with the Plan can be appealed to the Commission. Appeals may be brought by any interested person, or by the Commission itself. Learn more here.
March 4, 2024
Leanne Mueller, Senior Planner
Sacramento County Planning and Environmental Review
827 7th Street, Room 225
Sacramento, CA 95814
Dear Ms. Mueller:
We are providing comments on the application for a use permit for the Twin Cities Composting Facility located on the north side of Twin Cities Road, west of Interstate 5, in the Delta community on Parcel 146-0080-040-0000. As defined in the Delta Protection Act (the “Act,”), this proposed facility occurs in the Primary Zone of the Delta. As used in the Act the Primary Zone means “the delta land and water area of primary state concern and statewide significance which is situated within the boundaries of the delta” (California Public Resources Code Section 29728).
The Delta Protection Commission is a state agency charged with ensuring orderly, balanced conservation and development of Delta land resources and improved flood protection in the Primary Zone. The Commission reviews projects within the broad framework of the Delta Protection Act of 1992 and Delta Reform Act of 2009, which declare that the State’s basic goals for the Delta are to provide a more reliable water supply for California and protect, restore and enhance the Delta ecosystem “in a manner that protects and enhances the unique cultural, recreational, natural resource and agricultural values of the Delta as an evolving place” (Public Resources Code section 29702(a) and Water Code section 85054).
We understand that the County must issue a discretionary use permit for this facility and must conduct design review. This letter provides our comments and the results of our initial review of the project for consistency with the Act (California Public Resources Code Section 29700 et seq.) as well as our Land Use and Resource Management Plan (required by California Public Resources Code Section 29760), and our Economic Sustainability Plan (required by California Public Resources Code Section 29759).
Proposed local government-approved projects within the primary zone of the Legal Delta must be consistent with the Commission’s Land Use and Resource Management Plan (LURMP) (California Public Resources Code Sections 29700-29780). California Public Resources Code Section 29760(b) states that the Land Use and Resource Management Plan “shall. . .preserve and protect agricultural viability” and “shall. . .protect the delta from any development that results in any significant loss of habitat or agricultural land.” “Development” is defined by the Delta Protection Act as “the placement of. . . any solid material or structure” over land or water in the Primary Zone of the Delta (California Public Resources Code Section 29723(a)). A list of excepted activities that are not regulated as development are provided in California Public Resources Code Section 29723(b). None of these exceptions apply to the proposed facility thus it is regulated “development” within the meaning of the Act.
The Land Use and Resource Management Plan provides the following policy:
“The priority land use of areas in the Primary Zone shall be oriented toward agriculture and open space. If agriculture is no longer appropriate, land uses that protect other beneficial uses of Delta resources and that would not adversely affect agriculture on surrounding lands or the viability or cost of levee maintenance, may be permitted” (Delta Protection Commission 2010:12).
In addition to regulating development, the Delta Protection Commission is required to plan for and promote the economic sustainability of the Delta under the Act. The Commission prepares an economic sustainability plan to promote the “continued socioeconomic sustainability of agriculture and its infrastructure” in the Delta (California Public Resources Code Section 29759(b)(2)).
The applicant’s biological assessment indicates that the current project would result in the permanent loss of 39.4 acres of agricultural land (Madrone 2023). Between present and 2014, over 12,000 acres of farmland have been lost in the Delta (Delta Stewardship Council 2024). Our planning work documents that agriculture is the main economic driver of the Delta economy (Delta Protection Commission 2012:274). A dollar of agricultural crop revenue generates three to five times greater regional income than other leading revenue sources such as recreation or tourism (Delta Protection Commission 2012:274). For these reasons, the project would contribute to the incremental loss of agricultural land and the reduction of economic sustainability in the Delta.
The natural resource goals for the Delta also include the goal to “preserve and protect the natural resources of the Delta [and to] encourage compatibility between agricultural practices and wildlife habitat.” (Delta Protection Commission 2010:18).
The land in the project area proposed for conversion serves as foraging habitat for various raptor species including but not limited to Swainson’s hawk (Buteo swainsoni) (Madrone 2023). Swainson’s hawk is listed as a threatened species by the California Department of Fish & Wildlife (CDFW 2024). CDFW must make the determination for a “threatened” listing based on facts demonstrating the presence of one or more of the factors provided in California Code of Regulations Title 14, Section 670.1(i)(1)(A), including “present or threatened modification or destruction of [a species’] habitat.” The primary threat to Swainson’s hawk is loss of suitable foraging habitat, including suitable agricultural foraging habitat (CDFW 2016:3). The conversion of this parcel would reduce habitat for a threatened species that CDFW has identified as contributing factor to decline of the species consistent with its listing process and five-year review under California law (CDFW 2016).
To review the facts, the proposed facility:
- Falls inside the Primary Zone of the Delta subject to our Plan,
- Is inconsistent with the statutory mandates of California Public Resources Code Sections 29759 and Section 29760(b) to protect agricultural land and economic sustainability because it would permanently convert agricultural land to non-agricultural uses in the Primary Zone,
- Is inconsistent with the natural resource policy goals of our Land Use and Resource Management Plan adopted under California Public Resources Code Section 29760 because it would reduce habitat for a threatened species, and thus contribute to one of the factors CDFW has identified as a cause of the species’ decline.
Note that California Public Resources Code Section 29770 allows “any aggrieved person” the right to appeal land use decisions taken in the primary zone for inconsistency with the Act or our Plan. The exact language states: “the ground for an appeal and the commission consideration of an appeal shall be that an action, as to land located exclusively within the primary zone, is inconsistent with the resource management plan, the approved portions of local government general plans that implement the resource management plan, or this division [i.e. the Act]” (California Public Resources Code Section 29770).
In closing, our contention with this project is not about its merits. It appears to be a valuable facility; however, it is in a location that makes it incompatible with California law and our mandate to protect the Primary Zone of the Delta.
Sincerely,
Bruce Blodgett, Executive Director
Delta Protection Commission
CC: Patrick Hume, Supervisor, Sacramento County
References Cited
Delta Protection Commission. Economic Sustainability Plan for the Sacramento-San Joaquin Delta. 2012. West Sacramento, California.
Delta Protection Commission. Land Use and Resource Management Plan for the Primary Zone of the Delta. 2021. West Sacramento, California.
Delta Stewardship Council. Updated Delta Plan Performance Measures Guidebook. Available: https://viewperformance.deltacouncil.ca.gov/ 2024. Sacramento, California.
California Department of Fish & Wildlife (CDFW:3). Five Year Status Review for Swainson’s Hawk (Buteo swainsoni). 2016. Sacramento, California.
CDFW. 2024. State and Federally Listed Endangered and Threatened Animals of California, January 2024. Sacramento, California.
Madrone Ecological Consulting (Madrone). Biological Resources Assessment Twin Cities Composting Facility. 2023. Citrus Heights, CA.
WEST SACRAMENTO, Calif. (Feb. 29, 2024) – The Great California Delta Trail may grow its network of trails with a new segment from West Sacramento to Clarksburg.
The segment would run along 6.4 miles of the Clarksburg Branch Line of the Sacramento Northern Railroad. West Sacramento acquired the right of way in 2005.
The addition would create a safe, healthy way for pedestrians and cyclists to reach Clarksburg, a historic Delta community with popular wine-tasting venues. It could also help improve broadband access in the Delta by including conduit for fiberoptic cable.
Project partners are West Sacramento, Yolo County, the Yolo Transportation District, and the Delta Protection Commission, which is the coordinating agency for the Great California Delta Trail. West Sacramento leads the project, and the DPC will:
- Contribute toward required local matching funds.
- Lead community outreach.
- Ensure the project meets guidelines for designation as part of the Great Delta Trail.
The partners have applied for a grant from the Sacramento Area Council of Governments to fund trail development. If funded, the next step would be seeking public input on design. The target completion date would be in 2029.
This project would extend one of five existing segments of the Great Delta Trail: the Clarksburg Branch Line Trail. The other four segments are:
- West Sacramento River Walk
- Sacramento River Parkway
- Big Break and Marsh Creek Trail
- Carquinez Loop Trail
The Great California Delta Trail is envisioned as a continuous regional recreation corridor extending around the Delta. Learn more about the Great California Delta Trail here.
WEST SACRAMENTO, Calif. (Feb. 5, 2024) – The Delta Protection Commission today released a public-comment draft of the Management Plan for the Sacramento-San Joaquin Delta National Heritage Area (Delta NHA).
All interested parties are encouraged to view the plan here, and submit comments on the Plan by 5 p.m. March 6, 2024. Comments can be emailed to submit@delta.ca.gov, or mailed to the Delta Protection Commission, 2101 Stone Blvd., Suite 200, West Sacramento, CA 95691.
In addition, members of the public may attend one of two scheduled meetings to comment in person: Feb. 21 in Walnut Grove and Feb. 22 in Antioch, both 6-8 p.m. An additional virtual meeting will be scheduled as well.
“We’re excited and pleased to be at this juncture – a critical point in the development of this National Heritage Area,” said Commission Executive Director Bruce Blodgett.
“A great deal of work has gone into the plan in consultation with a broad group of stakeholders and tribes,” he said. “But this public comment process is key to ensuring that the voices of the Delta and all who depend on it – whether for work, recreation, historical and cultural appreciation, or spiritual connection – are represented well in the final plan.”
The Delta NHA was created in 2019 by Congress (PDF). It is California’s first, and so far only, National Heritage Area.
The NHA’s boundary extends from Sacramento to Stockton to Vallejo with the junction of the Sacramento and San Joaquin rivers at its heart. The history of California’s Delta and Carquinez Strait is a rich tapestry of indigenous peoples and immigrants from around the world, natural beauty and wildlife and engineering marvels, bustling metropolitan areas and picturesque rural towns. The native peat soils provide for fertile cropland and its water supports 27 million Californians.
The Delta Protection Commission, a California state agency, was designated the local coordinating entity for the Delta NHA. It has drafted the Management Plan in cooperation with the commission’s Delta NHA Management Plan Advisory Committee, the National Park Service, California State Parks, tribes, and stakeholders.
The Delta Protection Commission is scheduled to vote on the plan March 7, 2024, after which it will be submitted to the Secretary of the Interior for approval. After approval, implementation of the plan can begin.
Media contact: Blake Roberts, (530) 650-6572 or blake.roberts@delta.ca.gov
STOCKTON, Calif. (Jan. 18, 2024) – The Delta Protection Commission appointed Gerry Goodie to the Delta Protection Advisory Commission (DPAC) on Thursday.
Goodie is co-owner, with his wife, of Wimpy’s Marina Restaurant & Bar in Walnut Grove. A 2023 alum of the Commission’s Delta Leadership Program, he also serves as a board member of the Asian Pacific Islander American Public Affairs (APAPA) Delta Chapter, and is active in the Walnut Grove Rotary Club.
Goodie fills a new general-public seat that was added in September when the Commission voted to expand DPAC, adding a tribal representative and an additional general public representative. He will serve a three-year term.
The tribal seat remains open; applications will be accepted until it is filled. The application form is here.
The Committee meets every other month, and its next meeting is on Feb. 6.
DPAC provides recommendations to the Delta Protection Commission on diverse interests within the Delta, including the Delta’s socioeconomic sustainability, recreation, agriculture, flood control, environment, utility infrastructure, and other Delta issues.
The Committee was created by the Delta Protection Act, Public Resources Code Section 29753(a).
The 2024 class of the Delta Leadership Program. L-R front: Jacylyn Stokes, Pat Tirone, Priti Agarwal, Min Park, Samar Salma, Cintia Cortez, Matthew Brown, Nancy Young. L-R back: Tim Cook, Krystal Moreno, Malissa Tayaba, Katie Wiley, Ahmad Majid, Alice LLano, MacKenzie Owens.
SACRAMENTO, Calif. (Jan. 12, 2024) – The 2024 Delta Leadership Program kicked off Friday with its first meeting of the year for its 15 participants.
Run by the Delta Protection Commission and the Delta Leadership Foundation, the program is designed to build and support leadership within the Delta community.
The first seminar of the year covered Delta legislation; Delta agencies; and Delta trends, issues and interests. In addition to honing leadership skills, participants will team up on projects benefitting the Delta.
This years participants are:
Priti Agarwal, Alameda County: Recent volunteer with Lodi Sandhill Crane Festival, nearly 20-year career in Bay Area corporate positions (Director, Manager, Analyst).
Matthew Brown, San Joaquin County: Banking officer (Bank of Stockton since 2019, Bank of Rio Vista from 2011-2018), 3rd generation Rio Vistan, Walnut Grove Rotary Club since 2015, graduate of Leadership Lodi.
Tim Cook, Yolo County: Co-owner of Meyer and Cook Insurance Co. (Walnut Grove), Walnut Grove Rotary Club, Walnut Grove Fire Department (former Captain), Clarksburg Cub Scouts Pack 83 Den Leader.
Cintia Cortez, San Joaquin County: Restore the Delta (Policy Analyst since March 2022).
Alice LLano, Yolo County: Pear farmer in Clarksburg, community volunteer (school parent teacher council, Friends of Clarksburg Library, Clarksburg Rotary Club).
Ahmad Majid, San Joaquin County: National Women in Agriculture (Central Valley Chapter President since September 2022), Director of Environmental Initiatives – With Our Words (since Jan. 2023), Central Valley Neighborhood Harvest (multiple positions since March 2020).
Krystal Moreno, Placer County: Traditional Ecological Knowledge Program Manager (Shingle Springs Band of Miwok Indians – since 2018), DSC Adaptive Management Forum Advisory Board member, volunteer competitive softball coach.
MacKenzie Owens, San Joaquin County: Restore the Delta (Media and Communications Coordinator), Community Based Organization Advisory Committee for Estuary Youth Council (part of San Francisco Estuary Partnership).
Min Park, Contra Costa County: Bethel Island community volunteer (Bethel Island Municipal Improvement District), professional career in hospitality industry (New York, Oklahoma, Hawaii, and Bay Area restaurants, including Executive Director of Greens Restaurant).
Samar Salma, Solano County: External Affairs Specialist with FEMA, Certified California Naturalist.
Jacylyn Stokes, San Joaquin County: Walnut Grove grape grower, board member of Lodi Winegrape Commission, California Agricultural Leadership Foundation (Class 52).
Malissa Tayaba, El Dorado County: Vice Chair and Director of Traditional Ecological Knowledge for Shingle Springs Band of Miwok Indians (and other positions since 2008), member of Delta Conveyance Project Stakeholder Advisory Committee.
Patricia Tirone, San Joaquin County: Founder of Delta Sculling Center in Stockton, advocate for building the Delta Aquatic Center in Stockton.
Katie Wiley, Sacramento County: Marketing Manager for numerous Delta businesses (Wimpy’s, Al’s Place, Fosters Bighorn), Delta recreationist.
Nancy Young, San Joaquin County: Mayor, City of Tracy (on City Council since 2012), deep community involvement with numerous organizations in Tracy.
The Delta Protection Commission reviews hundreds of local and regional land use projects in the Primary and Secondary zones of the Delta for consistency with the Land Use and Resource Management Plan (PDF) and submits comment letters to ensure projects stay on track with the Plan. Under state law (Public Resources Code Sections 29770-29772), any action taken by a local government or agency in the Primary Zone that is inconsistent with the Plan can be appealed to the Commission. Appeals may be brought by any interested person, or by the Commission itself. Learn more here.
December 28, 2023
Jesse Barton
Reclamation District 1601
c/o Gallery & Barton, APLC
1112 I St, Suite 240
Sacramento, CA 95814
VIA EMAIL
Re: Twitchell Island Wetland Enhancement and Restoration Project Initial Study/Mitigated Negative Declaration (SCH #2023110643)
Dear Mr. Barton:
Thank you for providing the Delta Protection Commission (Commission) the opportunity to comment on the Initial Study/Mitigated Negative Declaration (IS/MND) for the Twitchell Island Wetland Enhancement and Restoration Project (Project). The Project proposes to enhance and restore approximately 40 acres of wetland and approximately 80 acres of riparian and scrub-shrub habitat within a 185-acre Project Area footprint on Twitchell Island. Approximately 50 acres within the Project Area would remain under agriculture use.
The Commission is a state agency charged with ensuring orderly, balanced conservation and development of Delta land resources and improved flood protection. Proposed local government projects within the primary zone of the Legal Delta must be consistent with the Commission’s Land Use and Resource Management Plan (LURMP) (California Public Resources Code Sections 29700-29780). Although proposed actions by a State agency are not subject to consistency requirements with the LURMP, we submit these comments under Public Resource Code Section 29770(d). This section states that the Commission may comment on projects that impact the Primary Zone.
The Commission is supportive of habitat restoration projects within the Delta. We urge the California Department of Water Resources to review the Project for compliance with LURMP policies, particularly those related to conversion of agricultural land to wildlife habitat, use of public lands for restoration, and employment of the good neighbor checklist and other best management practices to minimize impacts on surrounding residents, businesses, and recreational opportunities.
We are concerned about the Project’s conversion of existing farmland and pastureland on Twitchell Island to a non-agricultural use. The IS/MND states that agricultural operations for the property are not sustainable due to soil subsidence and high water table and that the Project will enhance farming practices in the Delta due to subsidence reversal. Nevertheless, the conversion of agricultural to non-agricultural use will displace agricultural operations to other locations, possibly outside of the Delta, and decrease the economic benefits of agriculture for Sacramento County and the Delta. These effects are heightened when considered with the cumulative impacts from other habitat restoration projects in the region. The IS/MND should provide mitigation measures that adequately address these impacts.
Thank you for the opportunity to provide input. Please contact Blake Roberts, Program Manager I, at (530) 650-6572 for any questions regarding the comments provided.
Sincerely,
Bruce Blodgett
Executive Director
cc: Pat Hume, Commission Member and Sacramento County Board of Supervisors
