Kate Poole at the Natural Resources Defense Council fires back at the State’s analysis of the portfolio approach on the NRDC’s Switchboard blog, saying the State has built it’s rejection on ‘on misinformation and flawed analyses.’
She cites five points as to why the why the Agency’s refusal to consider the portfolio approach doesn’t hold water.
- The portfolio approach would generate more water and do so more reliably: The NRDC recently completed an analysis that determined that a $5 billion investment in water recycling and urban water conservation would yield between 926,000 and 1,240,000 acre-feet of permanent new water annually. “If you add this new water supply to the 4.2 MAF average supply from the Delta that the State says a smaller, less expensive tunnel would yield, the portfolio approach provides more water and a more reliable water supply at less cost than provided by the current BDCP two big tunnels approach,” says Ms. Poole.
- The negative benefit-cost ratio relies on a cost estimate that is $2 billion too high and doesn’t include water generated by $5 billion in recycling and conservation: The benefit-cost ratio determined in Chapter 9 uses a cost estimate that is $2 billion higher than the cost estimate contained in the 9/11/13 analysis. Ms. Poole points out: “Resources’ assertion that the costs of a smaller facility outweigh the benefits is based on overestimating costs by at least $2 billion and underestimating water supply yield by about 1 million acre-feet, rendering it inapplicable to the portfolio alternative.“
- The analysis that a $3 billion investment would doubtfully provide even 100,000 acre-feet is contrary to experience as well as DWR’s own analyses: Ms. Poole notes: “Using DWR’s estimates, a $3 billion investment in water recycling would produce around 400,000 acre-feet in reliable new water supplies, and a $3 billion investment in urban efficiency could produce several million acre-feet of new supplies. That’s a far cry from the less than 100,000 acre-feet that Resources’ 9/11/13 analysis claims.”
- The analysis that the portfolio alternative would undermine biological objectives is faulty: The pumps would be operated according to a set of operations developed by the fish and wildlife agency biologists that are more protective than those in the current BDCP proposed project, and there is very little scientific support that restoration of tidal marsh habitat will benefit native fisheries, and could potentially worsen conditions by bolstering invasive species if not done carefully, says Ms. Poole.
- Levee investments called for by the portfolio approach would improve the Delta’s seismic resilience: She notes that a $1 billion investment in improving Delta levees would protect water exports as well as property and infrastructure in the Delta, which would suffer the devastating impacts of a catastrophic levee collapse even if the twin tunnels were built.
Kate Poole writes:
“We agree wholeheartedly with Secretary Laird when he notes in his cover letter that “California stands at a precipice [regarding] decisions in the California Delta….” Whether the State launches headlong over that precipice or pulls itself back from the edge by implementing a balanced portfolio of sound water management practices depends on the decisions made by Governor Brown and his responsible State officials over the next few months.
NRDC stands ready to assist the State in moving California to a sustainable water future. Viable solutions have been presented, including the portfolio alternative. The public wants a mix of water supply sources. We need leadership that will listen to the public and make the tough calls.”
Read the full rebuttal from Kate Poole at the NRDC Switchboard blog by clicking here.
