The State Water Resources Control Board released the draft report on January 5. Although the State Water Board did not formally request the Delta ISB review the document, the Delta ISB felt it was within their purview to do a review, given their statutory responsibility to provide scientific oversight for adaptive management in the Delta.
Dr. Robert Naiman, the author of the Delta ISB’s review, noted that in recent years, individuals and institutions have become adept at using keywords such as adaptive management or uncertainty. The Delta ISB looks behind the words to see if there is scientific evidence or literature to support what the agencies say they’re going to do. So the Delta ISB’s review considered whether there was enough information that the DISB could feel reasonably confident that the voluntary agreement proponents would be able to achieve their objectives and be successful.
“The voluntary agreements in these documents are offered as a potential alternative to flow standards that state agencies would impose on water users,” said Dr. Naiman. “It was very gratifying, at least for me, that the MOU outlines terms for an eight-year program that will provide both flow and non-flow improvements to restore aquatic habitat. And they provided the details of the funding for implementation for monitoring, water purchases, and so forth.”
“So, the DISB’s comments will highlight that we fully understand that this is going to be a very complex undertaking by state agencies, and our comments are really geared towards trying to improve the process and help ensure that these voluntary agreements are going to be successful, not only in the initial eight-year program but really for the long term.”
Dr. Naiman said that the methods and modeling approaches are described well and generally with adequate detail and transparency. The conclusions are based on quantitative modeling coupled with hydrodynamic and operational models to show how flow-dependent habitat and abundance models can be melded to provide reasonable outcomes.
“The most positive aspect of the report that we’ve found is their plan for adaptive management,” he said. “They state they want to use structured decision and support processes to determine or adjust flow and non-flow measures going forward. … They’re proposing to do direct science, but they can incorporate the outcomes of testable hypotheses to continue to inform the decision-making, adjust on the fly, and be consistent with provisions of the government’s program. And there are funds specifically allocated for adaptive management in this process.”
Dr. Naiman said that while the DISB’s report is positive towards the voluntary agreements, it does express concerns related to having an effective adaptive management process, identifying and monitoring quantitative performance criteria, statistical design and the eventual programmatic evaluation, establishing a scientific team from the beginning, and adjusting for changes in climate and important environmental drivers, among others.
“We’ve tried to couch these in a very positive way because I think overall, what the agency is embarking upon here is really truly complex and just a grand experiment going forward. … They seem to have the bones of a potentially successful program here. But if it could be structured correctly, right from the beginning, it probably has a very good chance of eventual success.”
Dr. Stephen Brandt said that some of the science isn’t quite there yet. That is okay, but it should be stated explicitly that the quantitative capability to predict the relative impacts of flow and habitat acreage, given other environmental drivers, doesn’t exist yet. “I think it’s okay if the science is not there as long as one specifies the assumptions being made,” he said.
“They’re starting off on a new tack with these voluntary agreements, and they seem to have thought this through as best as you possibly could right now,” said Dr. Naiman. “They are trying something that is really quite new and untested. They are treating it as an experiment, and they are employing adaptive management. Maybe not to the level we’d like to see it right now, but they will come back and evaluate it in seven or eight years. So I would put my money on the fact that they will fail, but I also will put my money on the fact that we will learn a lot about a strategy for starting to restore part of the system. Not all of the system, but part of the system.”
The DISB members then discussed how uncertainty and the science (or lack thereof) support the planned activities and objectives. It was also noted that harmful algal blooms are not addressed in the document.
But overall, the board members spoke positively about the report and the voluntary agreements. “We don’t want to go too far towards emphasizing how little we know because I think we also know enough to forge ahead or to be advocates for these voluntary agreements as a step forward,” said Dr. Diane McKnight. “I do like the tone of what was written so far as, by all means, go for it as an underlying tone that this kind of approach is worth pursuing.”
“That’s consistent with my perspective as well,” said Chair Wainger. “This is worth doing. Just make sure you learn from it.”
The Board then voted unanimously to adopt the letter with some minor changes.