More confusion than clarity in tunnels EIR

Gov. Jerry Brown spends quality time with the massive Delta tunnels EIR. Photo courtesy the governor's office

The final version of Gov. Jerry Brown’s twin tunnels plan is better than earlier drafts but still contains “key flaws,” independent scientists say, including an environmental impact report that is so chock full of facts that it doesn’t tell a clear story.

The latest draft critique marks the Independent Science Board’s fifth review of various iterations of the tunnels plan. Their criticism isn’t really about the tunnels themselves, but rather the documents that are being used to justify their construction.

The final EIR is like the drafts before it, “failing to communicate clearly the principal findings and uncertainties of an enormous report,” the panel concludes.

This isn’t all on the architects of the plan, the scientists add. EIRs are supposed to be understandable to the general public, but courts have often thrown them out because they’re not comprehensive enough. The result? EIRs that, for big projects like the tunnels, can total tens of thousands of pages filled with jargon and veritable acres of gray text.

In short, most EIRs now favor comprehensiveness over clarity and readability. And the the tunnels plan is no different.

The problem is that the lack of clarity puts many regular people (including yours truly) at a disadvantage. This includes members of the general public who may be most affected by a project — in this case, Delta residents themselves.

Those who wrote the tunnels EIR “followed what the laws, regulations and permitting processes require,” the science board says. “They faced enormous challenges from such a large and complex system. Yet the Delta’s problems are so important that project proponents should go far beyond the norm when providing and synthesizing scientific information.

“Environmental impact assessments for (the tunnels) have missed opportunities to increase understanding of the Delta as an ecosystem, a water supply, and as a place where people live and work.”

Some of the other issues raised by scientists in their latest review:

• The EIR doesn’t contain enough details about how so-called “adaptive management” would actually work. This criticism should sound familiar to those who have followed the tunnels issue over the last few years. Adaptive management is a way to deal with uncertainty about the future of the Delta that could lead to unexpected changes in how the tunnels must be operated.

The report explains why adaptive management is important, but not the details of how it will actually be done, the scientists say. That plan should be put in place now, they say, not after a decision has been made and officials have already pushed forward with the project.

• The report doesn’t “systematically” address how the tunnels might affect Delta levees and relies on seismic risk studies more than a decade old (a concern, since seismic risk is one of the justifications for building the tunnels in the first place).

• The report also doesn’t go deep enough on the potential impacts of climate change on the project, nor reductions in groundwater availability in the overtapped San Joaquin Valley, which could increase demand for Delta water.

Officials may not want to speculate about things like that, the scientists say, but “reasoned speculation… is an important part of science and public policy discussions.”

• The report doesn’t look closely enough at potential environmental impacts of providing more water to those agricultural areas, such as pesticide use and agricultural runoff.

• The report is “overly optimistic” about how quickly wetland restoration projects will offset environmental impacts of building and operating the tunnels.

• Finally, of particular interest to Delta residents, the impacts of construction are “substantively” addressed but are not presented in a coherent way, with the details scattered across many chapters and not summarized in a way that might help Delta people understand what to expect.

A final version of the critique is expected to be released this week. I’ll post it here along with any major changes to the draft.

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