DPC Letter: Twitchell Island Wetland Enhancement and Restoration Project

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