What happens then?

Today, Maven published excerpts from the findings of the Delta Independent Science Board May 2014 review of the Bay-Delta Conservation Plan’s draft Environmental Impact Report / Environmental Impact Statement.

Yes, that review was produced over six months ago, but it is worth restating the concerns that were identified by the DISB. Given their extent, it is clear why Federal agencies are so cool to the BDCP, and why we will continue to see Congressional coalitions making secretive (and soon, not so secretive) efforts to circumvent environmental law.

Digression moment: It is noteworthy that DISB member Jay Lund wrote recently that a new environmentalism is needed for California water. “New environmentalism is about diverse interests working together to create more promising environmental solutions,” Lund somewhat generically writes.

But isn’t that what the BDCP was, and in his capacity as a DISB Reviewer, is Lund simply following the letter of the laws he thinks need to change? The devil’s in the details I guess. And there are a lot of details, as Lund et al articulated. In principle, I agree with him, not necessarily with the implicit belief in more science, because ultimately a hybrid of science and design will break through the logjam, as I’ve written about, and worked on in the context of the Delta for many years. Here’s a low—res overall map of the geography of my efforts:

Back to the BDCP review: Can it be read as an index of where this new environmentalism must focus if it is to develop the mechanisms for doing what Lund is asking for? The DISP acted like a panel of scientists bound up in the contradictions of their disciplinary limits. They demanded more measurability, empirical tests, details of methods, despite the impossibility of arriving at a correct answer. What they seemed to be saying was that more certainty was possible, despite the explicit embrace of scientific uncertainty by the authors of the BCCP.

They seem to be saying that it is the responsibility of the Bay-Delta Conservation Planners to demonstrate that their assessments of the project’s impacts and mitigation efforts are realistic (or properly qualified if unknowable in advance - as they should have) - and that more explicit contingencies be put in place in the inevitable occurrence of failed environmental restoration objectives.


The following points are taken from a presentation of DISB’s review, made available by Maven:

Summary of Major Concerns:
Effectiveness of conservation actions, especially habitat restoration
“Many of the impact assessments hinge on overly optimistic expectations about the feasibility, effectiveness, or timing of the proposed conservation actions, especially habitat restoration.”

Treatment of uncertainty and use of modeling
“The project is encumbered by uncertainties that are considered inconsistently and incompletely; modeling has not been used effectively….”

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

Linkages between species, landscapes, and the proposed action
“Insufficient attention is given to linkages and interactions among species, landscapes, and the proposed actions themselves.”

Effects on SF Bay, effects of levee failures, effects of increased water availability
“The analysis 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.”

Implementation of adaptive management
“Details of how adaptive management will be implemented are left to a future management team without explicit prior consideration of (a) situations wherer 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.”

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

Presentation of the document itself
“The presentation, despite clear writing and an abundance of information and analyses, makes it difficulty to compare alternatives and evaluate critical underlying assumptions.”

“Many of the negative impacts of the project are expected to be mitigated by habitat restoration, some 150,000 acres….”

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

“In particular, the Panel observed that the critical uncertainties associated with presumed beneficial effects of tidal wetland restoration were not recognized in the Chapter 5 summary.”

The DISB recommended several improvements in the scientific framework of the BDCP:

Initiate pilot restorations actions as soon as possible.
“Pilot restorations actions (and other projects to address critical uncertainties) should be initiated as soon as possible, within a scientific framework that will allow BDCP and others to test, refine, and improve the effectiveness of restoration.

“Some students that are already underway can be incorporated into BDCP once (or if) it is permitted… other studies being planned could benefit by addressing needs identified in the Draft BDCP or DEIR/DEIS.

“Current and planned habitat restoration projects in the Delta should be aligned as much as possible with the priorities indentified in BDCP and the Delta Plan.

“Contingency plans….What if things do not go as planned? The history of ecological restoration shows that restoration shows that restoration projects rarely have exactly the intended consequences in the expected time frame….There will inevitably be situations….where there is a large-scale failure of restored habitat to function as anticipated. What happens then?”


Yes, what does happen then, embracers of scientific uncertainty, and demanders of more science?

Posted by John Bass on 23 Dec 2014 | Comments (0)


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