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3 Critical Gaps in the Scope of the Draft BDCP
Pages 20-28

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From page 20...
... The BDCP aims to address management and restoration of the San Francisco Bay Delta Estuary, an estuary that extends from the Central Valley to the mouth of San Francisco Bay. Thus, given that the BDCP purports to describe a Bay Delta Conservation Plan, the omission of analyses of the effects of the BDCP efforts on San Francisco Bay (aside from Suisun Bay)
From page 21...
... By contrast, a broadly focused conservation strategy, which the draft BDCP also says it is5, requires a similarly broadly focused, comprehensive effects analysis. Such an effects analysis would include a systematic analysis of the factors affecting species and ecosystems of concern and the likely contribution of human-caused changes in the system.
From page 22...
... An effects analysis is an essential element of the final BDCP, because it will help meet the legal requirement for a habitat conservation plan to evaluate whether the preferred action aids in the recovery of the species (state requirement) and does not appreciably reduce the likelihood or the survival and recovery of the listed species in the wild (federal requirement)
From page 23...
... Similarly, salinity gradients affect much of the central and western Delta, while some organisms like salmon, which spend a portion of their life cycles in sea water, occupy much of the North Pacific as well as the Delta and its tributaries. Within the biological realm, rates of primary production, nutrient and oxygen cycling, as well as microbial growth may respond rapidly to ecosystem conditions whereas the abundance of long-lived animals such as sturgeon is expected to integrate ecosystem dynamics over extended periods.
From page 24...
... . This information, when gathered in the BDCP's Monitoring and Evaluation Program, could then be used to conduct statistical analyses and calibrate models and the modeling framework to inform the adaptive management phase over the decades following implementation of the BDCP actions.
From page 25...
... If this is indeed how the BDCP developers intend to use the effects analysis, the panel recommends that the final version of the plan articulate a clear vision of how the effects analysis will be updated and how these results will be used to generate the ranges that will be the foundation for subsequent adaptive management. As an example, much of the recent discussion of changes in the Delta ecosystem has focused on declining planktonic primary production in the Delta and Northern San Francisco Bay (Jassby et al., 2002)
From page 26...
... .8 Under state law, the water users must submit a Natural Community Conservation Plan (NCCP) that, among other things, "aids in the recovery of the species." (Natural Communities Conservation Planning Act [NCCPA]
From page 27...
... The BDCP and the Delta Plan address the same ecosystem and are somewhat overlapping, but their goals and legal requirements are not identical. Unless the BDCP's relationship to the Delta Plan is clearly described, and its purposes clearly delineated, it will be difficult to assess the BDCP's underlying scientific basis, because the purposes of a broad conservation plan like the Delta Plan are not necessarily the same as those of a habitat conservation plan.
From page 28...
... . Finally, the federal approval process also will require an environmental impact statement that considers alternatives to the "proposed action," which includes construction of the alternative conveyance (National Environmental Policy Act, 42 U.S.C.


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