Things fall apart; the centre cannot hold . . . “
– William Butler Yeats, “The Second Coming”
Dr. Meral moves on
In Sunday’s Sacramento Bee, reporter David Siders announced that Resources Deputy Secretary Dr. Jerry Meral will retire at the end of the month. Of course, we are speculating about whom Governor Brown will find to replace Dr. Meral. But what we know for sure is that the Governor will not have any difficulty finding someone else willing to push his Peripheral Tunnels agenda. After all, we’re talking here about the heady cocktail of California water and political power.
It is also worth remembering that Governor Brown is responsible ultimately for pushing the BDCP boondoggle onto Californians, as part of the special 50 year relationship between each and every California Governor and specific moneyed water interests in California. It’s a shame that Governor Brown cannot help himself, but instead continues operating within this less than honest status quo.
By Jane Wagner-Tyack
Karla Nemeth, Bay Delta Conservation Plan Project Manager, is out to debunk urban myths about the BDCP. (“Correcting Stubborn Myths.” ) Let’s see how well she does.
(To avoid getting confused here, just note that Ms. Nemeth’s material is on the left side of the table below and ours is on the right. The “myths” according to the Department of Water Resources, as in Ms. Nemeth’s original document, are in italics. Her responses “debunking” the myths follow the italicized “myths.” See the original for her hyperlinks.)
|“Myths” according to the Department of Water Resources and Ms. Nemeth||The Facts|
|Myth 1: No one knows how much water will be exported under the Bay Delta Conservation Plan. The BDCP would provide approximately 10% more or 10% less than the average annual amount diverted by the federal and state water projects over the last 20 years.||Actually . . . One reason why no one knows how much will be exported – and why “reliability” is an illusion – is that no one knows how much water Nature will supply under drought conditions and climate change. We do know that the system is oversubscribed – that more water has been promised than can be reliably delivered even now.A 20% range is pretty inexact. And an important thing to know about that plus-or-minus 10% is that the average was about 5 million acre feet (5 MAF). State Water Project planners knew 60 years ago that they could only take that much out of the Delta if they diverted North Coast Rivers into the Sacramento River. It didn’t happen, and because those rivers have Wild and Scenic Rivers protection, it isn’t going to happen. Early planners knew, and more recent studies have verified, that 3 MAF is the maximum that can responsibly be diverted from the Delta.BDCP’s operational guidelines are not reassuring. The video says that the amount diverted will be determined by scientists monitoring operations. What if 10% less still isn’t enough for fish?|
|Myth 2: This is a water grab for Southern California and San Joaquin Valley farmers. The BDCP is designed to secure existing supplies of clean, affordable, and reliable water to 25 million people from the Silicon Valley to San Diego, the farmers who grow crops on 3 million acres of farmland, and the whole of the California economy.||Actually . . . Twenty-five million Californians get some portion of their water from the Delta, but with the exception of Zone 7 in Alameda County, all of them have alternative sources of supply. The important thing to know here is that in the first decade of this century, just two San Joaquin Valley agricultural exporters – Westlands Water District and Kern County Water Agency – used more water than Santa Clara Valley urban users and Metropolitan Water District urban users combined. So there is really no question that this is a grab by San Joaquin Valley ag agencies that want to continue unsustainable farming of permanent crops on toxic, drainage-impaired land. They’re trying to protect huge almond and pistachio exports that represent less than half of one percent of California’s economy.People need to understand, as well, that not all San Joaquin Valley agriculture depends on water exported from the Delta. There are about five million acres of irrigated farmland in the San Joaquin Valley, and much of that does not use water from the Delta. Agriculture in the San Joaquin Valley would not come to an end if we used the 1.7 MAF of water that goes to Westlands and Kern County agriculture for more sustainable purposes somewhere else.Also, some of the 3 million acres of farmland that get water from the Delta lie west of the Coast Range in the Santa Clara Valley and other coastal valleys.|
|Myth 3: The BDCP will destroy the Delta’s environment. The current system is not working for the environment or for California’s water users. The pumps in the south Delta tend to pull channel flows backwards, killing two out of three fish in the area. The new system would divert water from the north Delta when fish are migrating near the south Delta pumps and would use state-of-the art fish screens. Additionally, over 100,000 acres of wetlands and tidal marsh would be protected or restored to improve conditions for wildlife and the natural environment.||Actually . . . BDCP proposes to divert water from the north Delta only 49% of the time. The rest of the time, and particularly in summer and in dry years, exporters would continue to use the south Delta pumps that Ms. Nemeth decries. And they have no plans to put state-of-the-art fish screens on those South Delta pumps.In return for the ability to divert up to two-thirds of the flows of the Sacramento River, the Delta’s main source of fresh water, BDCP offers habitat restoration, a strategy whose success is notoriously hard to predict. At a symposium held at UC Davis earlier this year, multiple speakers pointed out that the creation or restoration of wetlands and tidal marsh in the wrong location does no good. BDCP has been unable to produce an effects analysis demonstrating that the plan will lead to the recovery of endangered species, a requirement for a permitted Habitat Conservation Plan.If we’re going to manage flows and salinity to recreate something like historic conditions for the benefit of fish, it is hard to see how we can do it by dramatically reducing the amount of water available to manage.And let’s add that it isn’t just the Delta’s environment that is threatened by this plan. It will also further damage fisheries and the ecosystem in San Francisco and San Pablo Bays and in the estuary.|
|Myth 4: No one knows how much it will cost or who will pay for the BDCP. The state and federal water contractors who receive water from the Central Valley Project and the State Water Project would pay for infrastructure construction and mitigation. The Metropolitan Water District of Southern California has estimated that this will result in an additional cost to its ratepayers of approximately $5-6 per household per month over a 10-year time frame. Most of the habitat restoration and ecosystem improvements that provide a tangible benefit to the entire state would be borne by state and federal taxpayers.||Actually . . . No one knows how much BDCP will cost for the same reason no one really knows how much any huge infrastructure project will cost: the likelihood of cost overruns, plus financing costs. As recently as last month, a bond underwriter told Westlands Water District officials that the $14.925 billion they’ve been told construction of the tunnels would cost is already closer to $18 billion because of inflation. They were also told that engineering for the project is only 10% complete. So at this point, how reasonable is ANY cost estimate?Ms. Nemeth says that “most of the habitat restoration and ecosystem improvements” would not be paid for by the water contractors. Once upon a time, beneficiaries were going to pay for this entire project, but now they are identifying about a third of BDCP – the actual conservation part – as a public benefit. That is upwards of $7 billion just by current estimates, and BDCP expects to pay for it with water bonds both immediately and sometime in the coming 50 years, with some money thrown in by the federal government. Does that sound to you like a solid financing plan? Can we really predict what citizens voting on bonds are going to do next year, much less in 10, 25, or 40 years?Also, the final word isn’t in on the distribution of costs among agricultural and urban water contractors. It is already clear that farmers will have a hard time affording this water (we’ve heard figures from $200 to $1,000 per acre foot), which they won’t get for at least 10 years anyway. Urban contractors, on the other hand, are viewed as having deep pockets (that would be their hands in the pockets of urban ratepayers). Will urban ratepayers go along? Some Metropolitan Water District member agencies are already saying “No.”|
|Myth 5: There is no cost-benefit analysis and no evaluation of alternative options. There is a cost-benefit analysis and an evaluation of alternative options. The BDCP Chapter 9: Alternatives to Take tests different alternatives, in part to determine if alternatives would be economically feasible. Appendix 9A provides a detailed evaluation of the benefits of the proposed project to participating water agencies. A Statewide Economic Impact Study looks at the economic impacts of the BDCP on various interest groups, including Delta farmers, commercial fishing interests, recreational Delta interests, and others.||Actually . . . OK, there is a cost-benefit analysis, but it has been manipulated to justify the massive investment. It compares a best-case water supply scenario WITH the tunnels (even though state officials admit the tunnels would not significantly increase water exports) to a worst-case water supply scenario WITHOUT the tunnels. UOP economist Dr. Jeffrey Michael points out that “this dire prediction of no-tunnel water shortages . . . contradicts the plan’s own environmental impact report. Not only does the economic study assume future water exports without the tunnels are 25 percent lower than the EIR, it ignores the environmental benefits that would result from such a large reduction in water exports.”Dr. Michael notes that “The BDCP economic analysis did consider one no-tunnel alternative” that involves engineering through-Delta corridors and modifying channels. “The BDCP economic study finds that this alternative has a significantly higher benefit-cost ratio than the tunnel plans and some benefits for fish. And the economic study forgot to include $2-4 billion of water quality benefits to the exporters from this plan that I am told will be in the final revised study. That will put the benefit-cost ratio of this alternative significantly over 2, which blows away the tunnels plan on an economic basis. . . . In light of this evidence from their own reports, the continued tunnel vision of BDCP is inexcusable.”It would be accurate to say that there is no economically defensible cost-benefit analysis and no serious evaluation of alternatives to the twin tunnels for meeting the coequal goals.|
|Myth 6: No one knows how the BDCP operations will be governed. Section 188.8.131.52 of the Draft Plan states that operation of the new and existing water conveyance facilities would be managed to specific criteria, and that flow criteria would be applied month by month based on water year type, and would always include a required amount of Sacramento River flow before water could be diverted.||Actually . . . Here we will refer to an independent study commissioned by American Rivers and The Nature Conservancy, two environmental groups with whom we do not often agree. The panel consisted of Jeffrey Mount, a professor emeritus at UC Davis; William Fleenor, an engineer at UC Davis; Brian Gray, a law professor at UC Hastings; Bruce Herbold, retired from EPA, and Wim Kimmerer, Research Professor at the Romberg Tiburon Center for Environmental Studies at San Francisco State University. It was funded by the Bechtel Foundation.One of the questions this panel was asked was “Does the plan provide an effective governance structure?”Said American River’s John Cain, “While most of the panel was technical in nature, a lot of the conclusions come from Professor Brian Gray at UC Hastings, and he found here that the BDCP blurs the lines between implementation and regulation, and grants the permittees unusual decision authority; it thereby places undue financial responsibilities on the state and federal governments,” he said. “Now to be fair to the project applicants, we’re told that they have corrected some of the deficiencies in the plan, and we’ll be happier with how it is structured, but unfortunately we haven’t seen the revised plan so as far as we’re concerned, this review still stands until we actually see a new plan that addresses these issues.” (Emphasis added.)That’s what we’re hearing from all quarters. When it comes to governance, BDCP puts the fox in charge of the hen house.|
|Myth 7: There is no clear science being used for the Bay Delta Conservation Plan. Fishery scientists acknowledge areas of debate and uncertainty regarding the best ways to sustain Delta fish. The BDCP deals with this scientific uncertainty by creating a rigorous Decision Tree (See Chapter 3, Section 184.108.40.206.4) process for scientists to evaluate and refine operational criteria in a structured, transparent, and collaborative way.||Actually . . . If you want to base a habitat conservation plan on science, and the habitat and species of concern are largely aquatic, then just about the first thing you need to know is how much water the system needs in order to support species recovery. In the case of the Delta, that still isn’t clear. And as soon as you make species recovery not the primary goal of the plan but a co-equal goal with exporting water at “reliable” levels, you hobble science. You further hobble science if you’ve already made up your mind that you can meet the needs of fish adequately by providing some new habitat for them.A Decision Tree cannot eliminate scientific uncertainty. The most likely result of using a Decision Tree to refine project operations is that even more restrictions will be placed on exports. “Collaborative” in this response really means that exporters decide how much water they have to get to make the project worth paying for, and then they look for scientists who will try to use the remainder for species recovery. Plus or minus ten percent.|
|Myth 8: The BDCP process has not been transparent or open to the public. The BDCP was developed with input from state and federal agencies and independent scientists after more than 600 public meetings and stakeholder briefings. All of the more than 3,000 documents are posted online in an unprecedented commitment to public access and government transparency. In 2011, a working draft BDCP was released. In 2012, administrative drafts of the BDCP and Environmental Impact Report/Environmental Impact Statement were released. Since then, the proposed project was significantly revised in response to stakeholder involvement.||Actually . . . This IS a myth, but not one that we’re advancing. Anyone with the time and inclination to plow through all the deliberately impenetrable documents and listen to the thousands of hours of meetings with their answers that obfuscate rather than clarify would have the whole story (minus the inevitable tête-á-têtes between participants meeting in groups too small to be covered by the Brown Act). In fact, we’re buried in information.But so what? The Bay Delta Conservation Plan has never been about asking people in the Bay and the Delta what should be done to conserve the Bay and the Delta. It has always been about water exporters trying to ensure their own ongoing supplies. The underlying message from BDCP planners to this region has always been “It’s our way or the highway.”|