Haste makes waste, again

Back in April, Restore the Delta reported that Delta Stewardship Council Staff recommended that CH2MHill provide the primary support for developing the Delta Plan, as mandated by the legislature. CH2MHill was already heavily involved in the historic Cal-Fed process and developing the Bay Delta Conservation Plan, which the Delta Stewardship Council is set to either incorporate or not incorporate into the Delta Plan.

At that time, the Delta Stewardship Council recognized
that it needed an additional independent consultant because CH2MHill was too invested in the BDCP process. Thus, the DSC hired ARCADIS, Inc. to begin reviewing the BDCP. This was a good move as the entire process was looking more and more like a game of musical chairs between CH2MHill and various state agencies, with no chairs actually being removed. 
DSC staff have now made their report on the BDCP document, and they found a lot not to like. (Click staff report BDCP August_21 to read the staff report.)
They criticized the short review time between posting of the Steering Committee draft on the BDCP web site on September 24 and the scheduled posting of the final draft on November 18. They disagreed with Undersecretary Scarborough’s view that comments and questions could be picked up adequately in the EIR/EIS process.
Staff said, “Given that many critical portions of the document are still incomplete and there appear to be many comments and questions that will not be addressed, there is a serious question as to whether this document will provide a satisfactory basis for an HCP/NCCP and a single biological opinion.”
The staff report expressed reservations regarding the limitations of modeling of sea level rise and questions regarding the basic scenarios for levee failures. RTD is happy to see DRMS called into question. The staff report said “Phase 1 of DRMS is not a supportable basis for conducting analyses of likely future behavior [of levees].”
Other comments from the staff report: 
  • “It is also unclear if and how any recommendations from the Independent Science Advisors will be addressed.” 
  •  “There were several comments to the effect that estimates [for implementation costs] appeared to be low and that even schematic designs are missing.”
    Nevertheless, the staff analysis isn’t as rigorous as it could be. It does not get at what is incomplete in the BDCP process.
We are curious to know why the “significant findings” identified in the ARCADIS consulting report, which has been posted on-line, didn’t make it into the staff report. (Click here to see the arcadis report.)
For instance, the ARCADIS report identifies the following unresolved issues regarding the Bay Delta Conservation Plan.
  1. Compliance with Fish and Game Code for a Natural Community Conservation Plan
  2. Compliance with the CEQA (California Environmental Quality Act) including:
    a. A reasonable range of flow criteria
    b. A reasonable range of conveyance alternatives
    c. Potential effects of climate change
    d. Potential effects on migratory fish and aquatic resources
    e. Potential effects on flood management
    f. Resilience and recovery in the event of a catastrophe
    g. Potential effects on water quality
Why hire an independent consultant and then ignore the consultant’s independent report?
What is clear from both reports, however, is that the BDCP is a thoroughly flawed and incomplete process. If deadlines to create a thorough conservation plan cannot be met, then why not adjust the process to allow the time to get it right? And if the BDCP is not resolving issues related to necessary CEQA criteria, shouldn’t the Delta Stewardship Council be making it clear to the Bay Delta Conservation Plan Steering Committee that it is time to get the job done correctly?

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