Last month, SF Baykeeper, GSSA, and coalition partners including Tribes, environmental and fishing organizations appealed the Department of Water Resources’ (DWR) consistency determination for its 2024-2026 geotechnical activities related to the Delta Tunnel. On December 19, a public hearing was held in Sacramento where our coalition challenged DWR’s strategy of fragmenting the Tunnel’s impacts into narrow segments to bypass the legal requirement for a comprehensive analysis under the Delta Reform Act. This approach by DWR obscures the Tunnel’s potential harm, disregards the clear intent of the law, and seeks preferential treatment from the Delta Stewardship Council, violating the statutory and regulatory obligations all parties must follow. DWR’s submission was criticized as incoherent, asserting that a minor component of the project qualifies for consistency determination under the California Environmental Quality Act, even while claiming that the action has no impact on the Delta Reform Act’s coequal goals or the policies of the Delta Plan.