DISB Review of the Draft EIR/EIS for the Bay Delta Conservation Plan

The Delta Reform Act of 2009 (§85320(c)) instructs the Delta Independent Science Board to review the Bay Delta Conservation Plan (BDCP) Draft Environmental Impact Report/Environmental Impact Statement (DEIR/DEIS) and to submit our comments to the Delta Stewardship Council and the California Department of Fish and Game. We have focused our review on the adequacy of the science and the validity of the conclusions drawn from that science. The accompanying document constitutes our legislatively mandated review.

We commend the preparers of the Draft BDCP documents for assembling and analyzing mountains of scientific information, and for exploring environmental impacts of many proposed BDCP actions. The preparers faced a bewildering array of regulatory requirements and economic, social, and political pressures.

We find, however, that the science in this BDCP effort falls short of what the project requires. We highlight our concerns in the attached report. The report, in turn, draws on our detailed responses to charge questions from the Delta Stewardship Council (Appendix A) and on our reviews of individual chapters in the DEIR/DEIS (Appendix B). Our concerns raise issues that, if not addressed, may undermine the contributions of BDCP to meeting the co-equal goals for the Delta.