The biggest difference between Sunding’s and Michael’s analyses is that Sunding’s analysis took a lot of economic credit for “regulatory certainty” under BDCP. Sunding assumed that under BDCP, exporters could make plans without having to worry about regulations changing in response to changing conditions.
Now remember that decision tree? Resources Secretary Jerry Meral said there’s no direct correlation between regulatory certainty and the decision tree.
This puts us back where we started. Either exporters will be guaranteed the water they want when they want it, with assurance that regulations will never change that. Or we will manage the Delta adaptively for the restoration of habitat, ensuring that the environment gets as much water as it needs.
A lot of scientists are saying that BDCP is not permittable. That means no regulatory certainty.
Sunding said that if they can’t show that BDCP is an economic benefit, they ought to stop. It appears that BDCP just shifts risk and costs from water contractors to the environment, fishermen, and Californians in general. So they ought to stop.