Document Type

Response or Comment

Publication Date

7-15-2014

Abstract

In July 2014 CUEL submitted comments on the draft environmental impact assessment for the proposed Bay Delta Conservation Plan (BDCP).

The following comments are submitted by the Center on Urban Environmental Law (CUEL) at Golden Gate University School of Law. The focus of CUEL' s comments is on Chapter 11 (Fish and Aquatic Resources) of the December 2013 Draft Environmental Impact Report/Environmental Impact Statement for the proposed Bay Delta Conservation Plan (December 2013 Draft EIR/ EIS). The December 2013 Draft EIR/ EIS was prepared and circulated for public review pursuant to the California Environmental Quality Act (CEQA) and the National Environmental Policy Act (NEPA). CUEL's comments address the relationship between the proposed BDCP and the authority of the State Water Resources Control Board (State Water Board), the relationship between the proposed BDCP and the Ninth Circuit Court of Appeal's April 2014 decision on federal Endangered Species Act {ESA) compliance in San Luis v. Jewell, and CEQA/N EPA compliance issues pertaining to information on baseline conditions in the December 2013 Draft EIR/EIS.

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