RBOC Opposing Franks Tract Restoration Plan in Delta

RBOC is opposing the California Department of Fish and Wildlife’s proposed restoration of Franks Tract in the Sacramento-San Joaquin Delta as the project would negatively and permanently harm present and future boating opportunities in this prime area of the Delta.

The following key impacts are of great concern to recreational boaters:

  • Access to False River and the San Joaquin River to the East would be permanently blocked.   This access would no longer be a thoroughfare for boaters traveling from San Francisco, Pittsburg and Benicia to recreate in the Delta.  Boaters would be forced to navigate all the way around - adding up to an hour to their cruising time and fuel consumption.
  • The project would result in the loss of marinas and marine-related businesses.  The plan would block off and severely impact the marinas, launch ramps, marine-related businesses and restaurants that serve the boating public in the Delta – with a tremendous, negative economic impact on this region.
  • The project would harm striped bass and black bass fishing, which are a core component of the Delta recreation with 150 tournaments held in the area each year. This would occur as additional water is diverted for the purpose of eradicating invasive species and helping endangered smelt.
  • The project would eliminate an important State Recreational Area that provides the stimulus for recreational and economic activity for the region.

RBOC’s opposition to this project is consistent with the organization’s August 21 testimony before the State Water Resources Control Board in support of the proposed resolution amending the San Francisco Bay/Sacramento-San Joaquin Delta Estuary Water Quality Control Plan [Bay-Delta Plan] and adopting the final Substitute Environmental Document [SED] for Lower San Joaquin River and Southern Delta.

The proposed plan amendments would revise two elements of the Bay-Delta Plan: lowering San Joaquin River flow objectives for the protection of fish and wildlife; and adjusting the salinity requirements to a slightly higher level to reflect updated scientific knowledge of Southern Delta salt levels that reasonably protect agriculture.

RBOC testified in support of the American Sportfishing Association’s coalition submittal, encouraging the adoption of scientifically and legally adequate flow standards of the lower San Joaquin River and its Tributaries. The organization emphasized that, given the extremely perilous state of salmon runs and other species, it is imperative that the board issue robust flow standards that will restore salmon.

RBOC’s opposition to the Franks Tract Restoration Project is also consistent with and in furtherance of the organization’s opposition to the California WaterFix, a massive construction project that could seriously impact boaters’ access to the Delta for years to come. 

The California WaterFix, which could take 14 years or more to complete, involves digging huge, 47-mile long tunnels under the Delta to facilitate the movement of water.  During construction, major waterways and tributaries could be closed to recreational boaters.

Other concerns with the WaterFix include:

  • The significant, negative impact that will occur with the closure of waterways to navigation during the lengthy construction period.
  • The absence of a plan to ensure that the Delta infrastructure will not only be preserved, but improved.
  • The lack of surety that the plan will address the threat that climate change and increased water transfer pose to the amount and quality of water in the Delta.

RBOC has, for decades, been at the forefront of opposing proposals that would impair the ability of boaters to access to the over 1,000 miles of waterways in the Delta. The organization successfully opposed permanent barriers that would have blocked navigation to popular Delta destinations. It has supported legislation that would increase funds for fighting invasive species such as the water hyacinth.

RBOC’s efforts are in furtherance of the policy it has pursued for over ten years in support of the preservation of recreational boating access to navigable California Delta waterways, including:

  • Pursuing assurances that as any changes are contemplated which further alter Delta navigable waterways that alternatives are identified and implemented that will best preserve and sustain recreational boat passage at each location.
  • Advocating for assured access for continued navigation by recreational boats wherever any “control structure” [such as, but not limited to gates or barriers whether temporary or permanent] is planned for placement across a navigable Delta waterway.  
  • Promoting the provision for operable boat locks installed as an integral design component to mitigate for the placement of any control structure across any navigable Delta waterway. All control structures and boat locks or other alternatives should be installed, maintained and operated without cost or expense to recreational boaters.

RBOC Works to Protect Boating, Files Concerns with California WaterFix EIR/EIS

RBOC has filed its concerns with the negative impact that the California WaterFIx would have on the ability of recreational boaters to navigate and recreate in the Sacramento—San Joaquin Delta.  Of particular note:

1. There has been insufficient time to review the responses to RBOC and other comments that were submitted as far back as 2013.

RBOC is therefore urging that the public comment deadline on the 2016 Final BDCP/California WaterFix EIR/EIS be extended.

Based on our initial review of the responses to RBOC’s comments, our organization believes that many responses are insufficient, ambiguous and/or unresponsive.

2.    As discussed in the 2016 Final BDCP/California WaterFix EIR/EIS, the California WaterFix would severely restrict navigable waterways during construction of the twin tunnels.

This is contrary to the California State Constitution, Article 10, Section 4 of which provides that “No individual, partnership, or corporation, claiming or possessing the frontage or tidal lands of a harbor, bay, inlet, estuary, or other navigable water in this State, shall be permitted to exclude the right of way to such water whenever it is required for any public purpose, nor to destroy or obstruct the free navigation of such water; and the Legislature shall enact such laws as will give the most liberal construction to this provision, so that access to the navigable waters of this State shall be always attainable for the people thereof.”

3.  The planned temporary closure of significant recreational waterways including Twin Sloughs and Mildred Island are unacceptable, unmitigated and unconstitutional.

RBOC's concerns have been filed within the public comments on the 2016 Final BDCP/California WaterFix EIR/EIS. This is in addition to extensive comments that RBOC has submitted within this proceding in an effort to protect the ability of recreational boaters to navigate and recreate in the Sacramento-San Joaquin Delta.