california, Environment, Justice, San Joaquin, Science, State Politics

Grasping at Straws: BDCP & DWR Drown Out Real Data

The California State Seal Outside that Natural Resources Building by Deanna Lynn Wulff

The California State Seal. Natural Resources Building

Gov. Brown’s twin tunnel plan has raised ire since its inception, but the battle has grown more heated with the publication of its latest economic report. Melinda Terry, manager of the North Delta Water Agency, called the document outright fraud, while state water contractors praised it with a fact sheet pointing out its strong points (primarily, its page length).

But what exactly does the economic analysis imply?

It suggests that if nothing is done to save the largest estuary on the West Coast, water exports to south of Delta contractors will be limited to 3.45 million acre-feet per year, on average. That’s roughly equivalent to the annual flow of the Tuolumne, the Merced and the Cosumnes Rivers. (So a lot of water will head south, with or without the tunnels.)

But with the tunnels even more water will head south. In fact, the economic analysis postulates that water exports will increase by 1.26 million acre-feet per year for a total of 4.71 million acre-feet on average.

Reality Check: The current export average is 4.5 million acre-feet, which implies that the increase is a paltry 210,000 acre-feet (a tiny fraction of California’s annual average water supply), but it’s an increase nevertheless.

And given the current conditions in the Delta, the data smells bad. The Delta is home to 750 species of plants and animals, 57 of which are endangered or threatened, and 11 are fish species, including salmon and steelhead. The Bay-Delta Conservation Plan (a.k.a the twin tunnels) is supposed to be a habitat conservation plan that protects these endangered species while allowing for continued water exports.

But fish species, in particular, need more water flowing from rivers out to sea—nearly 50 percent more. They also need less pumping in the South Delta, which is where state and federal contractors export water. Massive pumps create a north to south flow across the estuary, which is tidal and should flow east to west. Rivers flow backwards and endangered fish get caught in the pumps and die. This triggers a halt to pumping and to water exports.

So the question remains, how will the twin tunnels get around this conundrum and increase exports by 1.26 million acre-feet?

According to a representative from the Department of Water Resources (DWR), the tunnels would draw water out of the North Delta in high water years and store it in low water years. Dual water conveyance and an increase in land habitat will somehow free up more water. The premise sounds good, but it doesn’t take into account the associated environmental problems created by putting two 40-foot diameter tunnels 150 feet below the Delta and building another intake system in the North Delta. The proposed tunnels would destroy habitat, disrupt the ecosystem and degrade water quality.

These very problems have been pointed out, repeatedly, by the state and federal agencies who will ultimately determine whether the project gets built. Here are a few excerpts from a recent review of the plan:

  • Bureau of Reclamation:  The identification of adverse and beneficial impacts is very subjective and appears to be based on a misreading of NEPA regulations. (Page 4.)
  • Environmental Protection Agency: Compared to the No Action alternative and existing conditions, many of the scenarios of the Preferred Alternative “range” appear to decrease Delta outflow (p. 5-82), despite the fact that several key scientific evaluations by federal and state agencies indicate that more outflow is necessary to protect aquatic resources and fish populations. (Page 11.)
  • National Marine Fisheries Service: The lack of analysis of upstream operations and related effects may render this document insufficient to provide NEPA compliance for the full suite of actions necessary to integrate the BDCP into CVP operations.(Page 35.)
  • U.S. Fish and Wildlife Service: Our April 2013 staff progress assessment of the BDCP (see Appendix) identified several factual errors and significant analytical defects in Chapters 3 and 5…. In addition to factual and analytical errors, in certain cases ICF has treated the scientific information it presents unevenly, elevating information that is favorable to the preferred outcome and disparaging information that does not support it. (Page 42)
  • U.S. Army Corps of Engineers (USACE)In #2 is says the objective is to “reduce the adverse effects on certain listed species due to diverting water” and then in #3 it says we will continue to provide a certain quantity of water. Until the analysis is completed, and new EPA finalized, it’s hard to say if you can provide existing contracted amount of water–the two objectives are contrary to one another it seems. (Page 60)

These comments imply that the economic analysis and its conclusions are based on scientifically unsubstantiated data, which, at this point, is not surprising. It’s part of an overall pattern at the BDCP of ignoring fact in favor of fantasy. Complexities are hidden by complex language in a sea of documentation within which the most basic assumptions are often wrong.

Staten Island in the Delta

Staten Island in the Delta – Photo by Deanna Lynn Wulff

Take for example a BDCP blog post written by a DWR Spokeperson. In the first paragraph, it states that water exports have hovered around 5.3 million acre-feet for the last 20 years, but the DWR’s own spreadsheets show a different amount. The blog only refers to the last decade when export levels were at record highs. 

Adding to the confusion, the BDCP is now proposing to route the tunnels through Staten Island, a wildlife refuge for birds, particularly for Sandhill Cranes. This “habitat conservation plan” creates yet another set of legal and environmental tunnel muck.

Amid this detritus, there is at least one clear conclusion.

Without real analysis from an independent party, state and federal contractors, water districts, citizens and taxpayers can’t make sound economic decisions—they can only make emotion-laden political ones—which will cost billions.

About Deanna Lynn Wulff

Deanna is an activist, an editor and a writer. She is the Director of the Sierra National Monument Project ( and the author of the award-winning book, "The Girl's Guide to Getting Lost: Hard Hikes for Wild Women." Follow her blog, Minerva's Moxie, at


3 thoughts on “Grasping at Straws: BDCP & DWR Drown Out Real Data

  1. The fundamental problem with the present “use” of the Delta is that it is being asked to serve two contradictory functions: Be (1) a supply of fresh water for farms and cities (for which good “water quality” means “pure water”) and (2) an estuarine ecosystem (for which good “water quality” means algae, suspended sediment, chewy stuff for critters). The status quo isn’t working very well for either function.
    For all the tisk-tisking about DWR and others getting the data wrong, this article providing a few alarmist errors of its own, namely, will the exports increase by 1.26 million acre-feet, or (as the “Reality Check” paragraph points out) 210,000 acre-feet? 210,000 acre-feet is 4.7% of 4.5 million acre-feet. If the economic plan is proposing exporting 4.5 MAF. It’s also worth keeping in mind that these export numbers vary dramatically from year to year with California’s widly varying rain- and snow-fall conditions.
    I agree that the numbers in the BDCP proposal(s) need to be tightened up. But by throwing around other numbers, this article doesn’t contribute to a solution.

    Posted by TJ | September 5, 2013, 10:02 am
    • TJ – You make some solid points. And you’re right, all those numbers do get confusing, and the result is a lot of spin and not much clarity. Believe me, I work hard on being as clear as possible; it takes time and effort to weed through the maze of documents and policies that constitute California water policy. Ultimately, we need to work on real solutions (like you suggested) and I, as well as many others, have written about what we might do to resolve these issues…in fact…over and over. I’m sure I’ll write about it again.
      But first, as this article suggests, we need the BDCP and DWR reps to face reality and respect the science. It’s clear that we’re using too much water and putting it in places where it shouldn’t be – it’s time to make the appropriate changes in the right places. What’s needed is a higher level of integrity by all involved.
      Thanks for your comment.

      Posted by Deanna Lynn Wulff | September 5, 2013, 11:03 am


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