BDCP Independent Science Review: Still Not Passing Muster

Just about everyone agrees that the success of BDCP will rely on using sound science to guide the development of a plan for the Delta.   Not surprisingly, both state and federal law require use of the best available science in this process.  But there’s lots of disagreement about what constitutes the best available science.  That is why independent peer review is critical to the success of BDCP and other projects in the Delta.  Getting the science right in BDCP is critical not only to the future of the Bay-Delta ecosystem and California’s salmon fishery, but equally important, high quality analysis is needed to ensure that water rates aren’t increased unnecessarily by billions of dollars as compared to a different BDCP project (such as one that would decrease reliance on water exports from the Delta and invest in local and regional water supplies).   

Yesterday, the Delta Science Program released an independent peer review (online here) of two chapters of the Bay Delta Conservation Plan (BDCP) effects analysis. Unfortunately, like all of the prior independent science reviews of BDCP (including the National Academy of Science’s scathing review earlier this year, the independent review panel expressed significant concerns that the BDCP’s scientific analysis to date continues to be inadequate.  The executive summary to their report concluded that:

  • “However, the Effects Analysis does not yet provide the “big picture” necessary to evaluate how the effects of complex hydrodynamic, geophysical and ecological changes in the Bay-Delta are going to be synthetically analyzed as a system to ensure conservation and management of covered species, and that ecological processes of the Bay-Delta will be preserved and enhanced under future operations.”
  • “We found the present draft with only the two (of proposed nine) appendices to be somewhat confusing, incomplete and fragmented, and as a result, our review seemingly premature.”
  • “While we recognize that the BDCP Effects Analysis involves a large, complex process with various levels of completion and detail that have yet to be satisfactorily integrated, the Panel’s Phase 1 review raises many issues that suggest the findings of the Effects Analysis could be highly uncertain under its present formulation.”

The independent peer review identified numerous specific criticisms and recommendations for the next draft of the effects analysis.  Many of these criticisms and recommendations echo concerns that NRDC, the Bay Institute and Defenders of Wildlife raised in our comments on the same chapters (attached here).  Moreover, many of the comments on the effects analysis submitted by state and federal agencies (available online here) also were confirmed by this initial peer review.  

While we all should be grateful that the state and federal agencies have committed to independent peer reviews of the science used in BDCP, the real question is whether and how the effects analysis – and how the BDCP project – change in response to these comments and critiques of the science.  The review panel stated explicitly that “review and refinement of such an effects analysis requires an iterative process” in light of the current status of the effects analysis. This means that the state and federal agencies must ensure that the effects analysis is substantially revised in response to the comments from the agencies, NGOs, and the independent peer reviews.  Equally important, it also means that the project currently described in BDCP will almost certainly have to change in response to a scientifically valid effects analysis.  Both of those tasks are undoubtedly difficult on the present timeline (and may be politically difficult if a valid scientific analysis demonstrates that BDCP may not result in increased exports), but they are essential to the success of BDCP. 

There’s broad recognition that the status quo in the Delta is not sustainable, and the job facing the BDCP and the Delta Stewardship Council in crafting an effective plan is not an easy one. Getting the science right could be the difference between success and gridlock.