That’s how the U.S. Fish and Wildlife Service describes the 20,000-page twin tunnels environmental impact report/study.

Recently released comments from federal agencies on the governor’s twin tunnels plan express concern that the EIR/EIS is written in a leading manner — that is, that the authors advocate for the preferred alternative as opposed to a fair and neutral discussion of all possibilities.

This L.A. Times story focuses mostly on these concerns of “bias.”

But the agencies also raise specific issues about the expected impacts of the project itself. A few that jumped out at me:

• Habitat isn’t enough: BDCP calls for extensive habitat restoration approaching 100,000 acres, but the Environmental Protection Agency makes it clear that greater freshwater flows are needed, too.

The EPA notes that the plan calls for only “minor changes” in the amount of water allowed to flow through the Delta — somewhere between -1 percent and 5 percent.

EPA goes on to say there is “broad scientific agreement” that existing flow is insufficient to protect the ecosystem, and that both increased flows and new habitat are needed. (emphasis mine)

Money quote: “If there is sound scientific information that supports the perspective that increased Delta outflows are not needed and habitat restoration alone would be able to restore ecosystem processes and protect fish species, it should be presented in this (draft environmental impact statement).

Selenium: If Sacramento River flow is rerouted into tunnels, then the San Joaquin River becomes a larger source of water for the Delta, in terms of percent. Problem is, the San Joaquin is laden with toxic selenium.

Currently, the San Joaquin contributes just 10 percent to 15 percent of flows into the Delta. EPA wants to know how much that percentage will change as a result of the project.

Great progress has made reducing selenium discharges from ag lands on the west side of the San Joaquin Valley, “but to imply that the San Joaquin source will not continue to be an issue is rather speculative,” the agency writes.

Saving fish: Will shifting the point of diversion in the Delta really make that big of a difference for fish?

The new northern intakes would be used mostly during times of higher Sacramento River flow. When the Sac River is high, the number of fish killed at the south Delta pumps tends to be low, EPA says.

The opposite is also true. The south Delta pumps will continue to operate when the Sacramento River flows are low, and those are the times when fish face the greatest risk in the south Delta, EPA says.

• Project purpose: In addition to ecosystem restoration goals, the tunnel plan aims to “restore and protect the ability of the (State Water Project) and (Central Valley Project) to deliver up to full contract amounts…”

The U.S. Army Corps of Engineers finds this confusing.

“Isn’t the amount of water diverted dependent upon the analyses of the alternatives in the EIS/EIR?” the agency asks. “Why would we consider providing up to existing contracted amounts of water when the NEPA/CEQA analysis needs to first show how much water is necessary to protect fish?… Until the analysis is completed… it’s hard to say if you can provide existing contracted amount of water — the two objectives are contrary to one another it seems.”

• Quakes: More info is needed about this often-cited Delta concern, the Corps says.

A simulation of the effects of the 1906 earthquake, were it to happen today, found that 10 million people in Northern California would be affected. Yes, Delta levees — if not properly engineered or maintained — are vulnerable, but so is the BART tube beneath San Francisco Bay, along with other infrastructure, the Corps says.

The agency notes that more information is needed to determine if the twin tunnels would pose any less seismic risk than retrofitted levees.

Bottom line: “Further study/simulation of infrastructure vulnerability and associated costs should be completed to determine if constructing new conveyance or retrofitting old infrastructure is most beneficial to the public and the Delta environment.”

The state’s response: This is only an administrative draft, so criticism by reviewers is to be expected. “It’s important to remember that regulatory agencies by their nature do not give out ‘gold stars’ for work, but road maps for improvement,” said Jerry Meral, deputy secretary for the Natural Resources Agency.

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