Yesterday, I posted this piece about the role of science in developing plans to solve environmental and public health problems. Over the coming months, I’ll write about specific efforts that exemplify effective use of the “three step” approach and of the challenges and opportunities for integrating scientific analysis into management and policy. I am going to start with California’s Bay Delta Conservation Plan, an illustrative and cautionary tale of environmental planning going on in my own backyard.
First—some background: The Delta, formed by the confluence of California’s two largest rivers as they flow into San Francisco Bay, is the upstream reach of the west coast’s largest estuary. It is vital habitat for a host of fish and wildlife species and the major hub for the state’s largest water projects where more than a trillion gallons of water are diverted for export to the San Francisco Bay Area, the San Joaquin Valley and southern California each year. Steep declines in native fish populations have been just one indication of the escalating ecosystem degradation. For each of the six local fish species now listed under federal or state Endangered Species Acts (ESA), water project operations, which kill fish at the Delta pumps and degrade their habitat, are identified as an ongoing threat. ESA-required actions to protect these species have restricted some water management activities, reducing the amount of water that may be exported from the Delta.
The Bay Delta Conservation Plan, or BDCP, is a Habitat Conservation Plan being developed by the state and federal water project agencies and their water contractors who use water exported from the Delta. This plan is intended to be the basis for state and federal permits under the ESA to continue exporting water from the Delta for the next 50 years. Throughout its five years of development, numerous critiques (see here, here, here and here for some of NRDC’s comments) and independent scientific reviews by the National Academy of Sciences and the Delta Science Program all recommended major changes to the planning process.
The BDCP has fallen short on all three of the simple steps I described yesterday. First, the plan developers have provided a poor description of the problem that the plan is intended to address. To use a medical analogy, BDCP’s description of “existing conditions” is like going to the doctor’s office for a diagnosis and getting an exhaustive description of human anatomy, voluminous but unhelpful. Beyond general description, there is little information on either current status or recent trends in species’ population levels (which, for most covered fish species, have declined sharply in the last two decades) or Delta water export operations (which increased to record highs in the 2000s).
Second, five years into the planning process and with a proposed plan now on the table, BDCP has failed to identify or quantify the project’s goals regarding either species recovery or water supply. How exactly do you develop a plan when you have not decided what you are trying to accomplish?
Finally, BDCP has studiously ignored large components of the scientific literature, including that which describes the important effects of flow and water project operations on the Bay-Delta ecosystem and its fisheries. This prompted the Delta Science Program reviewers to politely ask the plan developers “why other current science was excluded” and to “provide justification for the exclusion.” The consequence of this failure to incorporate important relevant science in the planning process is that some of the major causes of the problems that the plan is supposed to address are not considered. From a scientific perspective or a public policy perspective, there is no justification for such an approach.
The National Academy of Sciences reviewers summed it up well in their comments released more than a year ago (page 50): “The plan is missing the kind of structure usually associated with current planning methods, in which goals and objectives are specified, alternative measures for achieving the objectives are introduced and analyzed, and a course of action is identified based on analytical optimization of economic, social and environmental factors.”
Last month, we saw the fruits of BDCP’s flawed planning approach with the release of their draft “effects analysis,” a report that evaluates the likely impacts of the currently proposed plan on the Bay-Delta ecosystem and fisheries. While numerous reviewers (including NRDC) have expressed concerns with the analytical methods, BDCP’s own analysis indicates that, compared to current conditions, their plan will reduce freshwater flows to the Bay, further degrading the quality and quantity of estuarine habitat, and have either no effect or negative impacts on populations of ESA-listed fish species already at risk of extinction. In short, the analysis is flawed and its conclusion suggests that the plan won’t work, offering no logical path forward.
So this is the moral of the story. Embarking on a planning journey with a poor description of the problem, nebulous goals, an incomplete map and an intentionally limited route may be an interesting exercise but it is unlikely to get you where you need to go. Rescuing the Bay-Delta ecosystem and increasing the reliability of California’s water supply is important and has broad public and political support: it’s time to get serious about the planning process and take a logical, science-based approach.