The Delta Protection Commission and the Water Education Foundation co-sponsored a Delta Levee Standards Conference in Sacramento last week – coincidentally, just when the Department of Water Resources (DRW) is proposing to adopt a weak standard as a baseline for future state investments in Delta levees.
Central Delta Water Agency attorney Dante Nomellini provided background on the Hazard Mitigation Plan (HMP) standard that DWR is currently endorsing for the Delta. Developed in the early ‘80s, the HMP was a short-term, minimum standard used by reclamation districts to qualify for FEMA aid. It was never intended as a long-term measure, like the stringent Delta-specific Public Law standard – PL 84-99 – that qualifies reclamation districts for federal assistance and rehabilitation.
Delta engineers and reclamation districts have been designing levee improvements using PL 84-99. They argue that that standard should be used for state and local investment in the entire system of Delta levees because risks cannot be segregated island by island.
Even the Corps agreed that one size doesn’t fit all when it comes to levees and that the minimum standard doesn’t involve enough actual engineering.
But the state apparently would rather not treat the Delta as a system of levees, preferring a confusing array of standards depending on what assets are being protected (wildlife, agriculture, infrastructure, or urban) and how vigorously the state responds to flooding. The State Plan of Flood Protection covers state/federal project levees but not 700 miles of nonproject levees in the Delta. The state levee subventions program, which has provided a 75% match for some local levee maintenance, is scheduled to reduce that match to 50% in 2013.
In fact, Dave Mraz of DWR admitted that the state has no plan for the Delta as a whole and justified that by saying that there is no single owner, an argument that could be made about flood protection levees just about anywhere. North Delta Water Agency board member and farmer Steve Mello pointed out that local reclamation districts tax themselves annually to help maintain levees that protect not just them but water transfers and infrastructure of statewide value.
So the state has no plan for Delta levees as a whole or for protecting the whole region in the event of flooding. This leaves a convenient vacuum for water exporters to fill with their Bay Delta Conservation Plan (BDCP) and its conveyance proposal, which was the next topic of discussion.