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CALFED Plan: Playing God in the Delta
If you're trying to recreate nature in a watershed where mighty rivers have been dammed and diverted, vast tracts of wetlands diked and filled, and wide reaches of floodplain planted and paved, where do you start? CALFED hopes its long-awaited plan for restoring the ecological health of the Delta, released in draft form over the summer, will help to answer that question.
The three-volume Ecosystem Restoration Program Plan (ERPP) includes more than 700 actions ranging from emulating natural patterns of freshwater inflow to the Bay to expanding the Delta's floodplain area and restoring Central Valley stream channel meanders. Among its provisions, the plan calls for the acquisition of 400,000 acre feet per year of water for instream flows, and the conversion of up to 250,000 acres from agricultural land to habitat. The plan is expected to cost $1.5 billion, and take 20 to 30 years to implement.
The plan breaks new ground, says CALFED's Dick Daniel, in that it "shifts the paradigm away from single-species restoration to the restoration of ecological processes at a landscape level." The plan identifies nine ecological processes for protection, enhancement and restoration including Central Valley stream flows and temperatures, natural sediment transport, floodplain processes and the Bay-Delta aquatic foodweb. "We want to reintroduce all the processes that contributed to the creation of the Delta and let them help us to reconstruct it," says Daniel.
The majority of the plan's actions will occur in 14 ecological zones, each characterized by predominant habitat types and species, stretching from the North Bay-Delta to tributary watersheds of the Sacramento and San Joaquin Rivers below major dams and reservoirs. Secondarily the plan addresses the upper watersheds and the near-shore ocean.
Daniel says the CALFED plan is far more ambitious than previous restoration efforts in that "a major objective is the recovery and eventual de-listing of endangered species dependent on the Delta, not just the protection of remaining populations." The plan identifies 26 individual species of fish, birds, mammals, reptiles and insects for recovery and also calls for sustaining healthy populations of other fish, invertebrates, waterfowl and upland game.
Although the plan outlines specific targets for ecosystem processes, habitats and species in each of the 14 ecological zones, its architects acknowledge that there is still much that is unknown about the ecological workings of the Bay-Delta ecosystem. For this reason, they say, the plan's "adaptive management" approach to implementation is its most important feature. Adaptive management is defned as the adjustment of restoration actions in response to new information gained as the program goes forward. CALFED is the multi-agency program established by the 1994 Bay-Delta Accord to develop a long-term solution to the environmental, water quality and water supply problems of the Bay-Delta. The public comment period for the draft ecosystem plan was scheduled to end on October 14. The final plan will be included in the draft Environmental Impact Statement for CALFED's Preferred Alternative, which is scheduled to be released for public review later this winter.
Sitting in Judgment
Among the stakeholders in the CALFED process, reaction to the plan has been predictably mixed. "It's the best game in town," says Friends of the Estuary's Elizabeth Patterson, adding that she thinks the plan's greatest strengths lie in its ecosystem-wide approach. "The plan is trying to restore function to rivers and the Estuary while looking at water quality in a watershed context. It also includes some immediate restoration plans that are consistent with the CCMP," she says. The CCMP is the Comprehensive Conservation and Management Plan for the Bay and Delta approved by government leaders and diverse interests in 1993.
One of the best things about the plan is that much of its $1.5 billion price tag has already been funded, according to Greg Zlotnick,who has been close to the CALFED process and now serves on the Board of Directors of the Santa Clara Valley Water District. Proposition 204, approved by voters last fall, designated $390 million for plan implementation, and on September 30 Congress approved $85 million in federal matching funds for fiscal year 1998. In addition, says Zlotnick, Category 3 funds established under the Bay-Delta Accord "provide funding for the early implementation of projects consistent with the ERPP."
Not everyone is impressed with the plan. One widespread criticism is that despite its large geographic scope, the plan shortchanges the Central and South Bay. "It's an incomplete document in that it is supposed to be an ecosystem-wide plan and it goes to the headwaters but not the bottom waters," says the Audubon Society's Arthur Feinstein.
Despite his general enthusiasm for the plan, Zlotnick agrees. "We believe that if a species is of concern in the North Bay and Delta, then it is in the South Bay as well. Also, if the South Bay ecosystem is strong enough that we don't have to put additional water into it, that will help to reduce stress on the Delta. Finally, we put in restoration money and we'd like to see some of that come back to work for fish here too" (Santa Clara was the only Northern California district to make a second contribution to Category 3).
"Our mission is to restore the ecological health of the Delta," explains Daniel. "We just did not find a nexus between the biological and physical process of the South Bay and the Delta. But if we do find one, we are certainly open to expanding the focus area."
Many environmentalists believe that even within its focus area, the plan doesn't go far enough. "This is not as massive a step as it's being bandied about," says Feinstein. "The restoration in the plan is a drop in the bucket compared to what we've lost. For example, the plan promises 150,000 acres of wetland restoration in the Central Valley, but compare that to the 6 million acres that we've lost. To say that this restores the ecosystem is a gross exaggeration."
The Bay Institute's Gary Bobker agrees. "The riparian habitat and wetland acreages fall short of large-scale restoration numbers, although they are certainly not trivial" he says. "In terms of what we've identified as potential restoration areas, the numbers are small."
Others think the numbers are too big. "These recommendations would have a dramatic effect on agriculture in the Delta," says Margit Aramburu of the Delta Protection Commission. "They would convert a minimum of 110,000 to 140,000 acres of agricultural land to habitat, and we think this could have very detrimental socio-economic effects on the Delta and surroundings." Her Commission feels that the recommendations may even violate CALFED's principle of not displacing impacts.
Some are also concerned that the plan doesn't include enough species. For example, "They've left out the San Pablo Bay song sparrow and the saltmarsh yellow throat, and there aren't enough plants," says Audubon's Barbara Salzman.
"There are many more species that it would have been nice to include," admits CALFED's Terry Mills, a major architect of the plan. "The species we selected had to be manifest as problems in the Delta." Mills acknowledges that the plan is weak on plants and plant communities, but says new sections on plants will be included in a later draft.
Other plan critics object fundamentally to its species recovery goals, according to CALFED's Daniel. "Some water managers on streams where we may want to repatriate steelhead are not happy with the plan," he says. "They'd just as soon not bring the fish back, because whenever you have endangered species present you have regulatory headaches."
Others would like to see regulation beefed up, especially with regard to land use. "Land use in the watershed will determine the success of the restoration plan. It should address the land use action plans in the CCMP, such as requiring CEQA to specifically assess the effects of new development on the Estuary and requiring that city and county general plans be consistent with the CALFEDsolution," says Elizabeth Patterson. "It's politically difficult but CALFED is the best window of opportunity we have had for getting at these issues."
Greg Zlotnick says these criticisms are misplaced. "There are interests who are looking to use CALFED to get at overall water use in California, but that is a separate issue from ecosystem restoration. Growth management is not what this program was designed to deal with," he says.
Parting the Water
Daniel says he expects the most controversy over the plan's proposals for instream flow volumes. The 400,000 acre feet per year of water the plan calls for would be acquired through a combination of water management, purchase from willing sellers and new water supplies (such as conjunctive use or recycled water), rather than through the time-consuming, expensive and often contentious regulatory process. Daniel says CALFED has already received criticism from those who believe the plan calls for too much water.
Part of the problem is that there is very little reliable science on how much instream flow is needed for healthy anadromous fish populations. "We have made the assumption that fish evolved to take advantage of natural patterns of flow events and we want to mimic those patterns," says Daniel. The plan calls for providing high flows during the spring and the first significant rain event of the fall. "The question is, how much water do we need to do that?" he says.
Although they think the plan's approach is basically sound, several people say they would like the plan to increase baseline as well as peak flows. "If we are going to expand marshes in Suisun Bay, for instance, we are going to have to supply them with the necessary fresh water," says Bobker. Pete Rhoads of the Metropolitan Water District questions the plan's emphasis on instream flows for fish restoration. "Restoring flows won't restore salmon and steelhead," he says "Native fish need many different types of habitat, from stream spawning to estuarine rearing habitat. We see a lot of recommendations for flows, but we don't see enough of the diverse habitat restoration that's needed."
"If we removed stessors associated with tributary barriers and gave fish access to upstream habitat we might not need to implement all of the natural processes targets the plan is suggesting," says Serge Birk of the Central Valley Project Water Association. "There are immediate opportunities to remove stressors on fish, and these should be prioritized."
Lack of prioritization also bothers Doug Latimer of the Mill Creek Conservancy. "Without assigning priorities, the document implicitly gives the same weight to minor riparian problems in relatively pristine areas and the huge problems caused by pumping and diversions in the mainstream Sacramento River and the Delta," he says. "Mill Creek could still support many thousands of anadromous fish if they never had to leave. Sure there are little things we could do to marginally help them, but they won't do any good if the downstream problems are not addressed. We need to make sure that we spend time and money where they can do the most good."
Rhoads also says that the plan does not delve deep enough into the impact of harvesting and hatcherys on native fish. "Many of us feel that the salmon can't recover without addressing the harvest issues. We've had years where 65-70% of the total fish population was harvested, and weak native stock are harvested at the same rate as hatchery fish." Daniel notes that the plan includes California's first effort to assess the impact of hatcheries on native fish. "We will look at the whole range of issues associated with hatcheries, including competition, genetics, disease, and whether or not hatcheries are actually producing the mitigation they were intended to provide."
Both Birk and Rhoads advocate caution regarding the plan to mimic natural flow patterns in light of the massive alteration of the Central Valley's ecosystem over the past century. Rhodes points to the winter-run salmon that now spawn in the upper reaches of the Sacramento River. "They spawn there because of the cold water that's released out of Shasta Dam. If we use water from above the dam for additional flows, we don't know what effect that may have on the small remaining population of winter-run salmon." Birk adds that historically, the salmon would have been above the dam. "The mimicry of natural processes needs to be integrated with the life stages of the fish, and that's hard to do when the remnants of the population are not where they used to be," he says.
Because of the scientific uncertainties surrounding many of the plan's provisions, Daniel and Mills emphasize the plan's adaptive management approach, which includes phased implementation, ecosystem monitoring and focused research. The approach is put forth in Volume 3 of the ERPP, which Daniel emphasizes is a working draft. Nevertheless, some people are uncomfortable with the questions it leaves unanswered.
"Everybody has a different idea of what adaptive management means," says Rhodes. "The ERPP has started a dialogue, but there needs to be more. We need to reach consensus on an approach that makes sense."
Several critics say that they are uneasy about the adaptive management approach because the plan does not spell out its overall restoration objectives clearly enough, making it difficult to evaluate the success of restoration actions. "CALFED's mission is to restore ecological health, but they have not clearly defined what ecological health is," says Bobker. "What is the standard against which we are measuring restoration activities? This question is very important from a planning perspective. CALFED needs to do more work to define its objectives, and when it does that, some components of the plan will change."
Birk agrees. "We should have some specific objectives for restoration and we should have some degree of certainty that if we take certain actions we're are going to reach our objectives."
Bobker also sees a conflict between the idea of adaptive management, which is based on the idea of uncertainty, and the desire of water users and land owners to be protected from any surprises. How this conflict is resolved will largely depend on the mechanisms the CALFED Assurances Group is identifying to ensure that the Preferred Alternative is implemented as agreed. Possibilities include legislation, contracts and the establishment of new institutions to implement the program. Bobker thinks the key to achieving successful adaptive management while insulating water users from surprises is to have clearly defined objectives and enough dedicated resources-in terms of land, water and money-to "completely achieve the restoration agenda, plus respond to the unexpected."
Contact: CALFED (916)657-2666
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