A new Bay Delta Conservation Plan (BDCP) “Fact Sheet” was released today by the State Water Contractors.
The “Fact Sheet” is Bogus
- The “alternative” that the Fact Sheet claims Delta Stakeholders are advocating for is a made-up alternative. None of the alternate proposals that have been submitted have indicated that the solution is to solely upgrade levees. While several proposals include ongoing maintenance of levees, strengthening some, none suggest that huge upgrades throughout the Delta are required or necessary. The “Fact Sheet” presents a bogus alternative to replace all of the levees in the Delta with massive (significantly wider and higher) levees.
- This made-up “alternative” more closely resembles the BDCP’s own 2009 Peripheral Canal “Through-Delta” alignment, building a huge isolated canal through the middle of the Delta including an “armored corridor” and numerous gates to funnel fresh water from Hood to the pumps and keep any salt water from the ocean out. This Peripheral Canal alternative was resoundingly rejected by Delta stakeholders during early BDCP workshops; hence the BDCP chose their tunnel idea instead.
- The current BDCP proposal, the “Tunnel Plan”, will result in an enormous amount of “tunnel muck” being produced (a BDCP term, not mine). In the BDCP’s Final Draft Plan this “tunnel muck” is described, in detail, as being toxic and needing to be stored in lined ponds to keep it from leaching into the ground water table and away from sensitive habitat areas. However, now this “Fact Sheet” is trying to sell us that this toxic mud is actually “material for valuable uses in the Delta.”
Calling this a “Fact Sheet” is a complete misnomer.
What do Delta Stakeholders Advocate
There are several alternative proposals that are being offered as better solutions than the BDCP. See the side panel “ALTERNATIVE PROPOSALS” to view proposals that have been offered by Rep. John Garamendi and others.
The Delta Stakeholder alternatives are not, as the “Fact Sheet” claims, of narrow scope and limited benefits. Levee maintenance is only one piece of Garamendi’s and others’ proposals.
However, the levee system needs to be maintained to protect the $20 billion in infrastructure (railroads, gas lines, power facilities, highways) and 4 million people who live in the Delta. Most of the levees are now in good shape; some have been recently upgraded. Over the years, levee heights may need to be raised due to higher water levels from global warming, but the water rise would occur so slowly that a normal maintenance program can easily keep them of adequate height. Many feel this ongoing levee maintenance costs should be shared by the contractors. The Garamendi proposal states: “The BDCP has neither a plan nor funding for the maintenance of the levees that are crucial for their proposed water conveyance system.”
When did toxic tunnel muck become such a great commodity?
In Chapter 4 of the BDCP Final Draft Plan (issued March 2013), we read:
- “Tunnel muck generated by the boring process is a plastic mix consisting of soil cuttings and soil conditioning agents (water, air, bentonite, foaming agents, and/or polymers/ biopolymers). Before the muck, or elements of the muck, can be reused or returned to the environment, the muck must be managed and, at a minimum, go through a drying/water‐ solids separation process and a possible physical or chemical treatment. The daily volume of muck withdrawn from the tunneling operations is estimated at approximately 7,000 cubic yards per day.”
“Spoils and tunnel muck … areas will be located away from sensitive habitat areas. To ensure that underlying groundwater is not contaminated, the muck ponds will be lined with an impervious membrane.”
In the BDCP “Fact Sheet”, they are now claiming that:
- “Tunneling creates material for valuable uses in the Delta. The tunneling aspect of the BDCP is expected to produce about 24 million cubic yards of material for potential reuses nearby such as habitat restoration and levee strengthening.”
So which is it? Is tunnel muck toxic to be located away from sensitive habitat areas or useful to build sensitive habitat areas? Did the BDCP get such strong push-back from Delta stakeholders who were being told they would be left with acres and acres of toxic, smelly muck piles throughout the Delta that they decided they needed to change their “marketing”? Or is Chapter 4 of the BDCP Final Plan completely wrong as to how the tunnels will be drilled?
Yes indeed, between March and August they have updated their collateral and now, instead of tunnel muck which was “plastic mix consisting of soil cuttings and soil conditioning agents (water, air, bentonite, foaming agents, and/or polymers/ biopolymers)”, their new materials now describe “reusable tunnel material … Water and biodegradable, ecofriendly soil conditioners are mixed with the soils to create a toothpastelike material [which] will be tested and evaluated to determine suitability for various reuse options.” I guess it doesn’t need to dry out any longer and does that mean it won’t be smelly? It’s good if they can make that happen.
Fact or Fiction?
See what you think about this very odd BDCP “Fact Sheet”.
“Fun” with “Facts”
Contrary to the BDCP “Fact Sheet” claim, the BDCP is primarily a narrowly scoped “Tunnel Plan”. It’s always fun to see how marketing positions things. When I worked in the software world, our Marketing guru was excellent at finding the right way to position our product against the other guys. The water contractors apparently have a large marketing budget. So for fun, I took the “Fact Sheet’s” marketing and spun it.
Correction 8/24/13: The Fact Sheet was published by the water contractors, not the BDCP.
Update 9/25/13: The original chart showed a YES for “Does the BDCP increase reliability” but today we need to change even that to a big “NO”. According to Dr. Jeff Michaels, UOP, discussing the response of Dr. Meral to questions in public meetings said that taxpayers would need to agree to pay for even more habitat or water flows from upstream sources if needed to achieve BDCP recovery goals and comply with the ESA. This is due to the regulatory assurances in BDCP limiting additional contributions of water or money from the water contractors.”So this conceptual idea is a nice illustration of how the BDCP reduces regulatory uncertainty for the water contractors by increasing regulatory uncertainty for taxpayers, upstream water users, and the environment. And that transfer of risk is why I have not included any value for regulatory certainty in statewide benefit-cost analysis. If you want to count the value of this risk reduction benefit to the contractors, you also have to value the cost of the risk increase to upstream interests, taxpayers, the environment and the Delta. The BDCP economic studies released this summer do not provide this balanced assessment.”