ACWA’s alternate Delta Plan: some specifics.

I was intrigued to see the continuation of a few themes I’ve detected before.  We’ve seen these in different sets of political talking points in the past couple years.

  • I’ve picked up hints of a new rift developing; not the traditional ag/urban/enviro, but an emerging big water user v. little water user.  Item 7, pg 23 is about ending illegal water diversions in the Delta.  Those might be illegal diversions, they might be poorly documented historic diversions; they are certainly individual diverters, outside the structure of a water district.  ACWA is gunning for them, perhaps rightfully.  I can’t speak to the legality or size of in-Delta diversions.  I only note that ag solidarity is crumbling.
  • On pg 30, ACWA wants to restrict ocean fishing of salmon.  Screw salmon fishers!  I understand the reasoning, but it is an assertive declaration that the state should value one use of our water resources over another type of use (growing over fishing).
  • On pg 35, ACWA brings up ammonia repeatedly.  This is code for the State Water Contractors’ strategy of blaming fish decline on the Sacramento Regional wastewater treatment plant rather than lack of flow.  I happen to think that Sacramento should upgrade their plant and that the fish decline is largely due to diverted flows.  I don’t mind this recommendation, but point out that it comes from a specific political strategy.


In roughly half a dozen places, ACWA’s Alternate Delta Plan directs the Delta Stewardship Commission come up with a plan for something (pgs. 7, 10, 21, 24, 28, 41, 44, 49).  DUDE!  That’s what they’re doing (sorta).  Why would ACWA and all those signatories like partitioned-out plans any better?  Oh yeah.  Because all of those fights are pushed to the future where the plans can individually weakened.  Even if that cynical reason isn’t right, the fact that ACWA’s default is “the DSC should make a plan for that sometime later” means that ACWA doesn’t have a plan of its own.  This is not a document with a solid detailed vision. It is some good points, some re-warmed talking points and some stalling.


In several places, ACWA’s Alternate Delta Plan is oddly focused on getting DWR to write reports (pgs 19: UWMPs, 20:levees (isn’t this what the DRMS reports were supposed to be?), 21: Bulletin 118, 21: more groundwater, 22: surface storage, 41: flood stuff).  Oh, and Fish and Game and SWRCB too.  One problem with this is that the point of the DSC is not to generate reports.  It is to meet co-equal goals.  Near and mid term actions shouldn’t be more studies and reports.  It is time for physical changes in the real world.

The second problem is that this is just weird.  Why would the DSC be an intermediary for demanding reports?  If you want reports (I agree that many of those would be fascinating and helpful), surely the Brown administration or the Legislature should be directing the agencies, not another agency.  Moreover, no one needs to exert political pressure to get those reports.  DWR would love to write those!  So would DFG and the SWRCB.  Departments don’t need direction from the Delta Stewardship Council.  They need staff and a state that can pass a damn budget.  I loved furloughs so I’m not complaining personally, but if you want reports out of a department, it doesn’t help to cut staff time by 15% for a couple years.  Finally, since ACWA is begging for a bunch of reports, I can’t help but point out that these reports and studies are the sort of thing that serve all the water users of the state and the departments that write them are appropriately supported by water user/public goods fees.


Getting more specific and trivial:

On page 13, ACWA’s Alternate Delta Plan shows more of their allergy to centralized control.

Athough the Act includes direction to pursue a Coastal Zone Management Plan type agreement with the federal government… a much more effective, timely and flexible  approach would be for the Council to … develop Memoranda of Agreement with the key federal agencies… .

Those two things are not the same.  A Coastal Zone Management Plan could include zoning that local agencies and individuals would have to abide by.  It can restrict some uses of the coastal zone.  It influences everyone in the area.  MOU’s are only binding on the agencies that sign them.  It would guide the federal agencies that sign on and the DSC, but not the rest of everyone in the managed zone.  This is consistent with ACWA’s “don’t boss me” philosophy, but if a Coastal Zone Management Plan is called for, an MOU with the feds is not a substitute.


I ended my last detailed review of a Delta plan with a rant about bald assertions.  There’s some of that in ACWA’s Alternate Plan as well, noticeable to readers who don’t share initial assumptions.  I object to unsupported statements that lack of reliability has had devastating effects on the state’s economy (pg 17, facts not in evidence), and that “California’s water supply is … sufficient to serve its economic needs today and into the future” (pg 17 as well.  Why then did the SWRCB’s report on the flows required to restore fisheries in the Delta send water users into such a tizzy?  If there is sufficient water to meet that environmental need and all the others, why were all y’all talking about how it was a single fish-focused report that would ruin the state if it ever got implemented?)  There were a couple other trivial ones, but I’ve been nitpicky enough for one night.


I can’t imagine you want more, but I marked up a paper copy.  Should anyone want an even more detailed critique, send me a Word version and you’ll get back a commented-up document.

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