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7
In Conclusion
The panel finds the draft BDCP to be incomplete or unclear in a variety of
ways and places. The plan is missing the type of structure usually associated
with current planning methods in which the goals and objectives are specified,
alternative measures for achieving the objectives are introduced and analyzed,
and a course of action is identified based on analytical optimization of econom-
ic, social, and environmental factors. The lack of an appropriate structure
creates the impression that the entire effort is little more than a post-hoc rationa-
lization of a previously selected group of facilities, including an isolated con-
veyance facility, and other measures for achieving goals and objectives that are
not clearly specified. Furthermore, unless goals are not only stated but also pri-
oritized, it is impossible to forecast the effects of projects that would achieve the
goals because it is impossible to identify the projects or the consequences that
would be deemed acceptable. One symptom of the absence of appropriate struc-
ture is the systemic lack of synthesis in the BDCP. Frequently, the plan appears
to be little more than a list of tactics or management options that are not strateg-
ically integrated. It is unclear how these tactics would be knitted together to
achieve the objectives of the plan which are themselves not always clear; and
there is no indication of how the various tactics and elements in the plan could
be implemented in a logical and strategic fashion.
Several errors of omission also complicate this review. First, there is no ef-
fects analysis that describes the impacts of the proposed project or alternatives
on target species, even though the BDCP notes that the effects analysis would be
“...the principal component of a habitat conservation plan...” Without an effects
analysis it is exceedingly difficult to evaluate alternative mitigation and conser-
vation actions. In addition, the plan remains silent on the probable effects of
proposed actions on target species. Second, the descriptions of the BDCP’s pur-
pose lack clarity. The confusion arises because it is unclear to what extent or
whether the BDCP is exclusively a habitat conservation plan, which is to be
used as an application for a permit to “take” listed species incidentally, or to
what extent or whether it is also intended to be a plan to achieve the co-equal
goals of providing reliable water supply and protecting and enhancing the Delta
ecosystem. Third, the proposed adaptive management plan is incomplete. Any
adaptive management plan requires a monitoring program and, although one is
described, it is unclear what purposes it is intended to achieve. The proposed
monitoring program has not been linked to the adaptive management plans in a
way that would allow managers to account for lessons learned from previous
experience, and more important, it is not linked to the effects analysis. In short,
there is no compelling information that would allow the panel to conclude that
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In Conclusion 51
the adaptive management program has been properly designed.
The lack of integrated management and coherence in developing the BDCP
is also a shortcoming. The plan reflects the perspectives of various public agen-
cies at the federal, state, and local levels and the many stakeholder groups in-
volved. Although this is not strictly a scientific issue, the panel concluded that
fragmented management is a significant impediment to the use and inclusion of
coherent science in future iterations of the BDCP. Moreover, the proposed
BDCP implementation arrangements appear unlikely to result in a well-
integrated, coherent implementation program because of the conflicting agency
and stakeholder interests and objectives that are built into the structure of the
proposed Implementation Office.
The panel underscores the importance of a credible and a robust BDCP in
addressing the various water management problems that beset the Delta. A
stronger, more complete, and more scientifically credible BDCP that effectively
integrates and utilizes science could indeed pave the way toward the next gener-
ation of solutions to California’s chronic water problems.
