“A high and irreducible level of complexity”

Those are the words used by Dr. Chris Earle of ICF International to describe the project underlying the Bay Delta Conservation Plan (BDCP). This month’s BDCP public meeting provided an update from ICF on Chapter 3, Conservation Strategy, and Chapter 8, Implementation Costs and Funding Sources. A little time was also devoted to an overview of preliminary draft chapters for the environmental documents being prepared by ICF in consultation with the Department of Water Resources.

The most important takeaway message: BDCP is focusing on environmental mitigation related to building the 15,000 cfs mega-project conveyance alternative but isn’t really looking yet at actual habitat restoration, which is supposed to be the reason for its existence. Under BDCP, real habitat restoration is decades away.

The Conservation Strategy chapter is already 807 pages long, and it isn’t complete yet; missing are adaptive limits for water operations, and monitoring and research actions.

As BDCP fumbles on into the future, lots of people would like to forget about CALFED, the 1990s effort of state and federal agencies, along with various stakeholders, to formalize cooperation on water supply reliability, water quality, ecosystem restoration, and levee system integrity.

But Deirdre Des Jardins of California Water Research raised the issue of the commitments made in the August 2000 CALFED Record of Decision.  She pointed out that the habitat restoration program discussed as part of BDCP is not new, and that CALFED had promised the restoration of 135,000 to 191,000 acres of habitat.   She questioned how much of the BDCP habitat restoration was new, and how much was previously promised under the CALFED Record of Decision.

Jerry Meral wondered to what extent previous CALFED commitments to habitat restoration were binding.  CALFED, he said, wasn’t a habitat conservation plan.  He opened the question to agency representatives at the table, noted that they were all looking in the air or at their feet, and told Des Jardins “We’ll get back to you with an answer.”

Des Jardins also argued that in creating management goals under BDCP, the state must consider the previous commitment under CALFED to recover endangered fish populations.   She stated that BDCP goals were weaker in that they only avoided jeopardy of extinction.   She also said that the CALFED goals of maintaining populations of harvestable species were not in BDCP, and asked if the state was abandoning these goals.

One of the fisheries agency representatives noted that recovery was only a guideline, and not mandatory.   Jerry Meral later said that of course the state was not abandoning the goals of recovery and maintaining fisheries.

Later, Des Jardins noted that there is already a habitat conservation plan in place for the Delta: the 30-year CALFED Multi-Species Conservation Strategy (MSCS). The existence of this plan would justify a “no action” alternative under BDCP. She said that while the BDCP considers only the Delta, CALFED included the Delta watersheds in its “solutions” area.   She said that these solutions areas were important to life stages of salmon, and expressed concern that the new BDCP goals narrowed the state’s commitment from “enhance fisheries for salmonids”  to just the Delta life stage — “improve survival rates of migrating juveniles.”   She also noted that the state had made commitments in CALFED to improve water quality in the Delta by reducing contaminants such as salt and selenium from upstream sources.

Meral said he was not aware that agencies would not honor commitments made under CALFED.   Is that the same thing as suggesting that agencies WILL honor those commitments?

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