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When science is lost in translation: Lessons from California's Bay Delta Conservation Plan

Tina Swanson

Posted January 10, 2012

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Yesterday, I posted this piece about the role of science in developing plans to solve environmental and public health problems.  Over the coming months, I’ll write about specific efforts that exemplify effective use of the “three step” approach and of the challenges and opportunities for integrating scientific analysis into management and policy.  I am going to start with California’s Bay Delta Conservation Plan, an illustrative and cautionary tale of environmental planning going on in my own backyard.

First—some background:  The Delta, formed by the confluence of California’s two largest rivers as they flow into San Francisco Bay, is the upstream reach of the west coast’s largest estuary.  It is vital habitat for a host of fish and wildlife species and the major hub for the state’s largest water projects where more than a trillion gallons of water are diverted for export to the San Francisco Bay Area, the San Joaquin Valley and southern California each year.  Steep declines in native fish populations have been just one indication of the escalating ecosystem degradation.  For each of the six local fish species now listed under federal or state Endangered Species Acts (ESA), water project operations, which kill fish at the Delta pumps and degrade their habitat, are identified as an ongoing threat.  ESA-required actions to protect these species have restricted some water management activities, reducing the amount of water that may be exported from the Delta.

The Bay Delta Conservation Plan, or BDCP, is a Habitat Conservation Plan being developed by the state and federal water project agencies and their water contractors who use water exported from the Delta.  This plan is intended to be the basis for state and federal permits under the ESA to continue exporting water from the Delta for the next 50 years.  Throughout its five years of development, numerous critiques (see here, here, here and here for some of NRDC’s comments) and independent scientific reviews by the National Academy of Sciences and the Delta Science Program all recommended major changes to the planning process.  

The BDCP has fallen short on all three of the simple steps I described yesterday.  First, the plan developers have provided a poor description of the problem that the plan is intended to address.  To use a medical analogy, BDCP’s description of “existing conditions” is like going to the doctor’s office for a diagnosis and getting an exhaustive description of human anatomy, voluminous but unhelpful.  Beyond general description, there is little information on either current status or recent trends in species’ population levels (which, for most covered fish species, have declined sharply in the last two decades) or Delta water export operations (which increased to record highs in the 2000s).

Second, five years into the planning process and with a proposed plan now on the table, BDCP has failed to identify or quantify the project’s goals regarding either species recovery or water supply.  How exactly do you develop a plan when you have not decided what you are trying to accomplish?  

Finally, BDCP has studiously ignored large components of the scientific literature, including that which describes the important effects of flow and water project operations on the Bay-Delta ecosystem and its fisheries.  This prompted the Delta Science Program reviewers to politely ask the plan developers “why other current science was excluded” and to “provide justification for the exclusion.”  The consequence of this failure to incorporate important relevant science in the planning process is that some of the major causes of the problems that the plan is supposed to address are not considered.  From a scientific perspective or a public policy perspective, there is no justification for such an approach.

The National Academy of Sciences reviewers summed it up well in their comments released more than a year ago (page 50): “The plan is missing the kind of structure usually associated with current planning methods, in which 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.”

Last month, we saw the fruits of BDCP’s flawed planning approach with the release of their draft “effects analysis,” a report that evaluates the likely impacts of the currently proposed plan on the Bay-Delta ecosystem and fisheries.  While numerous reviewers (including NRDC) have expressed concerns with the analytical methods, BDCP’s own analysis indicates that, compared to current conditions, their plan will reduce freshwater flows to the Bay, further degrading the quality and quantity of estuarine habitat, and have either no effect or negative impacts on populations of ESA-listed fish species already at risk of extinction.  In short, the analysis is flawed and its conclusion suggests that the plan won’t work, offering no logical path forward. 

So this is the moral of the story.  Embarking on a planning journey with a poor description of the problem, nebulous goals, an incomplete map and an intentionally limited route may be an interesting exercise but it is unlikely to get you where you need to go.  Rescuing the Bay-Delta ecosystem and increasing the reliability of California’s water supply is important and has broad public and political support: it’s time to get serious about the planning process and take a logical, science-based approach. 

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Comments (Add yours)

MikeJan 11 2012 12:02 PM

This author lays out her own criteria with which to judge research conducted by a host of BDCP researchers. If their responses do not match up with her opinion, then they must be false. Such an evaluation does not represent science. In addition, the author references only one factor that impacts fish populations---export pumps. Yet, she fails to acknowledge what scientists from multiple agencies have recognized--multiple factors impacting fish populations include predatory fish such as striped bass, water quality degradation resulting from tons of sewage wastewater being dumped into the Delta each month, and loss of habitat and food supply. According to the author's reasoning, these must not be credible factors since she does not mention them.

Mike Wade
California Farm Water Coalition

Jon RosenfieldJan 11 2012 04:04 PM

It's almost as if Mr. Wade did not actually read Dr. Swanson's blog post and certainly not the many comments that NRDC and other organizations (including disinterested parties like the National Science Foundation, Delta Stewardship Council's science advisory board, California's State Water Resources Control Board, etc.) have filed with regard to the BDCP planning process. The scientific community, of which Dr. Swanson is only a part (and which does not include consultants paid by the Plan's proponents) has consistently said that the multiple factors affecting fish populations in the Bay-Delta must be addressed.

They have also noted that improved fresh water flows into, through, and out of the Delta are absolutely essential to any plan seeking to conserve and restore species like Chinook salmon, steelhead, sturgeon, and native endemics that form the base of the food web. Yet, according to the BDCP's own analysis (which is flawed in many ways), the critical freshwater flows that species in this ecosystem respond to will be further reduced under this so-called conservation plan. The same (unrealistically optimistic) analysis acknowledges that many species (including, for instance, winter run Chinook salmon) will decline as a result of the BDCP's impacts on fresh water flows.

There really is no disagreement among scientists (who are, after all, trained to understand what fish need) -- the Bay-Delta ecosystem cannot be restored without significant improvements in the timing and volume of freshwater flows into, through, and out of the Delta. And, the BDCP will not improve those conditions.

Jon Rosenfield, Ph.D. Conservation Biologist

Bruce TokarsJan 11 2012 05:17 PM

Mr. Wade, when you say: "According to the author's reasoning, these must not be credible factors since she does not mention them." Are you saying that if a credible factor is presented to you and your California Farm Water Coalition employer that you would seriously consider those facts? Because when you say, "...multiple factors impacting fish populations include predatory fish…water quality degradation…loss of habitat and food supply..." these are factors that Dr. Swanson and many others have pointed out for years. Yet in virtually every criticism of the science involved in the Delta debate, you dismiss anything having to do with fresh water flows, the pumps, or the huge amount of water sent to Westlands and others as having any relevance to the sad state of this most important part of California. Instead, you pull out your favorite list (as you have done here, again) add a healthy dollop of "ocean conditions" and that is the end of the discussion. And this, coming from your recent comment in the SactoBee that “…(water) it would flow to the Pacific Ocean with no measurable benefit.” Water flowing into the Pacific Ocean from inland mountain streams and rivers is how our natural system works. Even suggesting that water flushing the estuary on its way to the ocean has “no measurable benefit” either demonstrates a lack of even the most basic understanding of science facts or an arrogance so steeped in selfish greed (not you, Mr. Wade but the members of your employer) that we should dismiss anything you have to say as noise designed to obfuscate and shroud the greedy manipulations that others looking at the water struggle so clearly see.

I am not a scientist but I have interviewed many experts about the current state of the Delta. I have spent thousands of hours working on videos to help explain why California’s unique and troubled water resources are in so much trouble and the range of opinions about how to fix the problems. I know you’ve seen most or all of the Salmon Water Now videos and I invite readers of this post to visit this link to see any or all of our programs:

But given Mr. Wade’s comments above, I’d like to suggest that he take a look at our most recent video: Railroaded Salmon
The fate of wild salmon in California is destined to be determined by the political posturing that takes place deep in the weeds. It's easy to get lost in the weeds because every issue related to salmon is complex. Most people have little time in their busy life to keep up with the details of who is pushing what and how a particular piece of legislation or court challenge will impact them. In the case of the effort to fix the most important ecosystem in California, the broken San Francisco Bay-Delta Estuary, the stakes are particularly important.

This video looks at the BDCP (Bay Delta Conservation Plan) and highlights the voices of the biggest and most powerful players in the efforts that are railroading salmon. The Metropolitan Water District of Southern California and the Westlands Water District on the west side of the Central Valley have managed to inject their agenda into the process so seriously that the fate of wild salmon are critically threatened.

Mr. Wade and his farm water employers will look at this video and proclaim again that anyone who disagrees with their position is an "objectionist" and that if the opposition get their way, "that would all but guarantee that California and its citizens have less water in the future" (a quote from the California Farm Water Coalition website). So at the risk of being labeled an "objectionist", I am happy to say that Salmon Water Now points out that there is only so much water to go around and all of it has been spoken for.

Railroaded Salmon is yet another look at the way the BDCP is going. It's a reminder that those who care about developing a rational, fair, and effective water future for California need to stay informed and involved.

It would be a wonderful turn of events if the members of the California Farm Water Coalition could at least agree that the credible factors about the health of the Delta that Mr. Wade chooses to leave out of his comments – are valid and important contributors to why we are in this sorry mess.

MikeJan 11 2012 08:01 PM

Jon...Be assured that I read the blog. The author states: "water project operations, which kill fish at the Delta pumps and degrade their habitat, are identified as an ongoing threat." Her silence in acknowledging the role of predators, wastewater, and diminishing habitat and food supply speaks volumes.

The author's writing of yesterday set forth her criteria to judge others and their opinions with the clear message that these other opinions must measure up to her viewpoint.

Jon, you introduced studies by others to the discussion; it is disappointing that the author did not do that in her writing. It is equally disappointing that you have decided that anyone with views other than yours and the author's are not to be included in the realm of science. These dissenting viewpoints are to be rejected because they may be paid by those interests you do not agree with? Sounds like a pretty narrow view. Don't you think that discussion between differing points of view leads to a healthy discussion?

Mike Wade
California Farm Water Coalition

Mike Wade
California Farm Water Coalition

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