The Environmental Water Caucus on December 19 sent a letter to federal and state agency officials asking for an 120 day extension in the public review and comment period for the Bay Delta Conservation Plan Draft Plan and EIR and EIS, noting that the 40,214 actual pages of the document represent 20% more pages than the 32 volumes of the last printed edition of the Encyclopedia Britannica.
"You may recall that in a November 21 letter to you, prior to the December 13 release of the BDCP Draft Plan and EIR/EIS, we requested that the public review and comment period be extended beyond the planned 120 days, based on the anticipated 25,000 page estimate of the BDCP documents," wrote Nick Di Croce, Co-Facilitator of the Environmental Water Caucus, in the letter addressed to Samuel D. Rauch, Administrator for NOAA Fisheries Service, and five others.
"We have now determined that there are 40,214 actual pages of the released documents and we request that you extend the public review and comment period for at least 120 additional days, due to the extraordinary size of the documents to be reviewed," he stated.
"Based on the dictated 120 day review time period, the public is being asked to review 473 pages of technical and scientific material per day during the 85 working days that are available during the public review and comment period. Additional time would be required to understand, research, and prepare comments on the voluminous documents," said Di Croce.
He pointed out that the BDCP web site provides instructions that: “Comments should identify the specific part of the document at issue and should include supporting evidence and facts.”
He also noted that NEPA regulation 40 CFR 1502.7 declares that the text of an EIS for “proposals of unusual scope or complexity shall normally be less than 300 pages.”
"As we also stated in that previous letter, it is impossible for organizations interested in thoughtfully responding to these BDCP documents to be staffed for a thorough NEPA/CEQA review based on the outlandish size of the documents to be reviewed," said Di Croce.
"Moreover, individual members of the public attempting to comprehend and comment on the BDCP documents would be overwhelmed. It is worthwhile noting that these documents represent 20% more pages than the 32 volumes of the last printed edition of the Encyclopedia Britannica," he stated.
Di Croce, representing the EWW and its 33 grassroots members, requested that the public review and comment period be extended for an additional 120 days, until August 15, 2014, based on the size of the actual documents they released on December 13.
"Without such additional time, the public’s essential role in the NEPA process of commenting on the agencies’ findings contained in the BDCP’s environmental review documents will be severely constrained," he concluded.
For more information about the EWC and its Responsible Exports Plan, an alternative to the Bay Delta Conservation Plan to build the peripheral tunnels, go to: http://www.ewccalifornia.org