On 13 June 2012, CSPA submitted comments on the sixth draft of the Delta Stewardship Council’s Delta Plan. The letter criticized the Council for failing to define the “coequal goals” or provide defensible and quantifiable goals, yardsticks and mileposts for achieving the goals or to establish consequences for failing to make progress toward those goals.
The Council refused to undertake a water availability analysis that is essential to separating real water from paper water, addressing the legal rights to it and providing the information necessary for informed decision-making. It rejected conducting a comprehensive socioeconomic benefit/cost analysis indispensable for maximizing the use of limited resources for the greatest good for all Californians. It brushed off multiple appeals to develop a public trust analysis crucial for ensuring that the common property rights of all Californian’s are protected and balanced against those of special interests. And it declined to conduct a water quality analysis to evaluate the impacts to pollutant concentration and residence time from diverting additional dilution flows around an already degraded estuary.
Instead, the Council only recommended that agencies continue to pursue existing programs that have led to pervasive water quality impairment throughout the Valley. The absence of these analyses has sabotaged the entire Delta planning process.