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State Policy Office
106 St. Albans Road
Kensington, CA 94708
Tel. 510-558-0125
Fax 510-527-6478
www.ca.audubon.org

February 11, 2005

The Honorable Mike Chrisman, Secretary
California Resources Agency
1416 Ninth Street
Sacramento, California 95814

Re: Salton Sea Restoration Planning

Dear Secretary Chrisman:

I am writing on behalf of Audubon California's nearly 60,000 members to thank you and your staff for leading the restoration planning for the Salton Sea ecosystem. We understand that it is an enormously complex and largely thankless task, but one that is critically important to California's birds and other wildlife. We look forward to continuing to work together to ensure that restoration satisfies the goals adopted by the Legislature for the Salton Sea and surrounding ecosystem.

We also appreciate the information provided to the public through the Salton Sea Advisory Committee, especially the opportunity to review the Salton Sea Ecosystem Management Plan: Draft No Action Alternative Report, dated November 2004 (hereinafter "Draft Report"). Given the complexity of the ecosystem and restoration alternatives, an accurate and complete baseline assessment is essential. We understand that the Draft Report was intended as a preliminary draft and, as such, will be substantially revised before being adopted as the baseline for purposes of California Environmental Quality Act (CEQA) analysis and review.

We agree with the concerns and suggestions for improving the Draft Report made by the Pacific Institute in its December 30 letter to Joe Grindstaff. In addition, we believe the State must include a range of reasonably foreseeable climate change impacts in both the baseline assessment and analysis of alternatives for restoration. As the State has recognized, climate change is occurring and the impacts are likely to increase significantly over the next several decades. Certainly, any project that is expected to last 75 or more years, as this one is, must consider reasonably foreseeable changes to the baseline and impacts on proposed alternatives that result from climate change. Although there is uncertainty about what the precise impacts will be, there is no longer legitimate scientific disagreement about the fact that the climate is changing and that those changes will accelerate over the next century.

The State should consider and plan for the likely range of changes predicted by the best available scientific models and studies, and restoration alternatives should provide the flexibility to adapt to climate change over the next century and beyond. According to recent analyses, California is projected to experience temperature increases of at least 4-8 degrees Fahrenheit (if global emissions are significantly curtailed) and more likely temperature increases of 9-18 degrees Fahrenheit (current emissions path) over the next century ¹. Those temperature increases will, in turn, have enormous impacts on stream flow, precipitation, air quality, evaporation rates, agriculture, wildlife, fisheries, tourism and infrastructure ². For purposes of restoration planning, climate change should be addressed, at a minimum, in the areas discussed below.

1. Stream Flows

Numerous models and studies have been conducted in recent years to predict how climate change will impact Colorado River flows ³. Although current models reach different conclusions about the overall trend, the models all agree that there will be greater variability in flows ⁴. In addition, higher temperatures are likely to create greater demands for Colorado River water from both Upper and Lower basin states, which could impact flows into Imperial and Coachella Valleys.

2. Impacts on Agriculture

Higher temperatures and increased CO2 levels will significantly impact crop productivity, irrigation needs and, ultimately, choice of crops ⁵. Higher evaporation rates are also likely to reduce runoff into the New, Alamo and White Water Rivers.

3. Impacts on Wildlife

Higher air and water temperatures will add additional stresses to wildlife and fisheries ⁶. Some migratory patterns may change as a result, mortality rates may increase and the balance of species may shift ⁷. Changes in agricultural practices and crop choices will also impact wildlife.

4. Air Quality

Higher temperatures are likely to lead to changes in wind and storm patterns that may exacerbate air quality problems caused by a shrinking Sea, carrying more pollutants westward toward heavily populated urban areas ⁸. Higher temperatures also have direct impacts on air quality by accelerating the formation of smog ⁹.

5. Evaporation Rates

Higher air and water temperatures will mean greater evaporation rates throughout the ecosystem, from agricultural fields and irrigation systems to rivers and, ultimately, the Sea itself ¹⁰. Assumptions about evaporation rates from the Sea, surrounding canals and other parts of the ecosystem should be based on the range of temperatures projected by the best available scientific models.

Each of these impacts and changes will significantly affect restoration efforts and should, therefore, be included in all aspects of restoration planning. Perhaps most importantly, restoration plans need to provide the flexibility, ongoing monitoring and adaptive management tools to adapt to the changing climate and its impacts.

We look forward to continuing to work with the Resources Agency, the Salton Sea Advisory Committee and others toward a successful restoration plan for the Salton Sea ecosystem.

Sincerely,

Julia A. Levin
State Policy Director

cc: Mr. Lester Snow, Director
Department of Water Resources

Mr. Joseph Grindstaff, Chair
Salton Sea Advisory Committee

Mr. Ryan Broddrick, Director
Department of Fish and Game

Ms. Jeanine Jones
Department of Water Resources

Salton Sea Advisory Committee Members

¹ K. Hayhoe, et al., Emissions pathways, climate change, and impacts on California, published by the National Academy of Sciences, August 24, 2004, at www.pnas.org/cgi/doi/10.1073/pnas.0404500101.
² C. Field, et al., Confronting Climate Change in California: Ecological Impacts on the Golden State, published by the Union of Concerned Scientists and the Ecological Society of America, November 1999. Available online at www.ucsusa.org. See also, J. Lund, et al., Climate Warming & California's Water Future, UC Davis Departments of Civil and Environmental Engineering and Agricultural and Resource Economics, a report for the California Energy Commission. March, 2003. Available online at http://cee.engr.ucdavis.edu/faculty/lund/CLAVIN/.
³ L. Nash and P. Gleick, 1991, "The Sensitivity of streamflow in the Colorado basin to climatic changes, Journal of Hydrology 125: 221-241; L. Nash and P. Gleick, 1993, The Colorado River Basin and Climatic Change: The Sensitivity of Streamflow and Water Supply to Variations in Temperature and Precipitation. Washington, DC: US EPA, EPA230-R-93-009. Both studies estimate that Colorado River flow may vary by 15-20 percent more or less than current flows as a result of climate change.
⁴ Id.
⁵ C. Field, et al, infra, at pp 40-45.
⁶ Id. at pp 35-39.
⁷ Id. at pp 30, 33, 35-39.
⁸ Id. at p. 9; L. Koteen, et al., Hot Prospects: The Potential Impacts of Global Warming on Los Angeles and the Southland, published by Environmental Defense, 2001.
⁹ Id.
¹⁰ Field, et al, infra, and Lund, et al, infra.