Delta Independent Science Board Blasts Tunnel Plan

Delta Independent Science Board Blasts Tunnel Plan

by Dan Bacher

The state officials who are fast-tracking the construction of the Bay Delta Conservation Plan to build the peripheral tunnels under the Sacramento-San Joaquin River Delta constantly claim that the controversial plan is based on "science."

For example, California Secretary for Natural Resources John Laird in March 2013 claimed, “At the beginning of the Brown administration, we made a long-term commitment to let science drive the Bay Delta Conservation Plan. Science has and will continue to drive a holistic resolution securing our water supply and substantially restoring the Delta’s lost habitat."

However, the hollowness of Laird's claim that the BDCP is founded on "science" was exposed on Monday, May 19 when the Delta Independent Science Board (Delta ISB) criticized the science in its review of the draft Bay Delta Conservation Plan (BDCP) Environmental Impact Report/Environmental Impact Statement.

This report follows numerous scathing criticisms of the plan's science from an array of federal and independent scientists and scientific panels over the past few years, who have said the construction of the tunnels may hasten the extinction of Central Valley Chinook salmon, Delta and longfin smelta, green sturgeon and other fish species.

The transmittal letter, addressed to Delta Stewardship Council Chair Randy Fiorini and Department of Fish and Wildlife Director Chuck Bonham, commends the preparers for assembling the documents while criticizing the science for falling short of what the document requires:

"We commend the preparers of the Draft BDCP documents for assembling and analyzing mountains of scientific information, and for exploring environmental impacts of many proposed BDCP actions. The preparers faced a bewildering array of regulatory requirements and economic, social, and political pressures.

We find, however, that the science in this BDCP effort falls short of what the project requires. We highlight our concerns in the attached report. The report, in turn, draws on our detailed responses to charge questions from the Delta Stewardship Council (Appendix A) and on our reviews of individual chapters in the DEIR/DEIS (Appendix B). Our concerns raise issues that, if not addressed, may undermine the contributions of BDCP to meeting the co-equal goals for the Delta."

In a remark made about the water supply section of the plan, the board provides this precious quote: “It is a bit like an orchestra playing a symphony without a conductor and with the sheets of music sometimes shuffled. The notes are all there and mostly well-played individually, but the experience is less than satisfying.” (Thanks to Alex Breitler of the Stockton Record for pointing out this quote).

The report addresses eight major points about how the DEIR/DEIS fails the "good enough" scientific standard, ranging from "overly optimistic expectations" regarding the "conservation actions" to the analyses' neglect of the project's downstream impacts on San Francisco Bay. Below is the summary from the report:

"We find that the DEIR/DEIS currently falls short of meeting this 'good enough' scientific standard. In particular:

1. Many of the impact assessments hinge on overly optimistic expectations about the feasibility, effectiveness, or timing of the proposed conservation actions, especially habitat restoration.

2. The project is encumbered by uncertainties that are considered inconsistently and incompletely; modeling has not been used effectively to bracket a range of uncertainties or to explore how uncertainties may propagate.

3. The potential effects of climate change and sea-level rise on the implementation and outcomes of BDCP actions are not adequately evaluated.

4. Insufficient attention is given to linkages and interactions among species, landscapes, and the proposed actions themselves.

5. The analyses largely neglect the influences of downstream effects on San Francisco Bay, levee failures, and environmental effects of increased water availability for agriculture and its environmental impacts in the San Joaquin Valley and downstream.

6. Details of how adaptive management will be implemented are left to a future management team without explicit prior consideration of (a) situations where adaptive management may be inappropriate or impossible to use, (b) contingency plans in case things do not work as planned, or (c) specific thresholds for action.

7. Available tools of risk assessment and decision support have not been used to assess the individual and combined risks associated with BDCP actions.

8. The presentation, despite clear writing and an abundance of information and analyses, makes it difficult to compare alternatives and evaluate the critical underlying assumptions."

Wow, that is quite a smackdown on the alleged "science" of the plan by a panel of respected scientists. Again, John Laird's claim that the Brown administration has "made a long-term commitment to let science drive the Bay Delta Conservation Plan" appears to have little or no basis in fact.

To read the review, go to: http://deltacouncil.ca.gov/sites/default/files/documents/files/Attachments

The board's criticisms of the "science" the BDCP documents are based upon are very similar to those that scientists from federal lead agencies for the BDCP EIR/EIS - the U.S. Bureau of Reclamation, U.S. Fish and Wildlife Service, and National Marine Fisheries Service - made regarding the preliminary BDCP documents last July.

They then provided the California Department of Water Resources (DWR) and the environmental consultants with 44 pages of comments highly critical of the Consultant Second Administrative Draft EIR/EISDraft), released on May 10. The agencies found, among other things, that the draft environmental documents were “biased,” “insufficient," "confusing," and "very subjective." (http://baydeltaconservationplan.com/Libraries/Dynamic_Document_Library/Federal_Agency_Comments_on_Consultant_Administrative_Draft_EIR-EIS_7-18-13.sflb.ashx)