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 economic, social, and environmental factors. The lack of an appropriate structure creates the impression that the entire effort is little more than a post-hoc rationalization of a previously selected group of facilities, including an isolated conveyance facility, and other measures for achieving goals and objectives that are not clearly specified. Furthermore, unless goals are not only stated but also prioritized, 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 structure 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 strategically 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 effects 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 conservation actions. In addition, the plan remains silent on the probable effects of proposed actions on target species. Second, the descriptions of the BDCP’s purpose 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
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 agencies at the federal, state, and local levels and the many stakeholder groups involved. 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 generation of solutions to California’s chronic water problems.