New coastal plan NOT ready for prime time!
Editor’s note: The Coastal Protection and Restoration Authority (CPRA) has released what is arguably the most important official state document of the year, the draft Fiscal Year 2011 Annual Plan – integrated ecosystem restoration and hurricane protection in coastal Louisiana.
The final document* must be approved during the upcoming regular session. In my opinion, this plan needs serious work.
by Len Bahr, PhD**
The annual plan is the authorizing document for all money projected to be spent by the state during fiscal year 2011 for its expanding program to protect and restore south Louisiana. The plan includes the combined projected costs of administration, planning, contracting, engineering and design, research, coordination…and project construction, monitoring and maintenance.
The total budget includes the state tab for cost sharing state/federal projects. I’m not in a position to judge the cost estimates and so do not comment on the budget items in this post.
The plan should be much more than an annual coastal budget, however. It should also serve as a candid annual update on the state of the coast, i.e., whether or not the land loss rate of south Louisiana is being slowed – and by how much. Reversing the relentless inundation by the Gulf of Mexico is a challenge of historic proportions – closely comparable to reversing the national unemployment rate during the current recession.
Therefore it seems to me that the annual plan should include a graph similar to the following bar graph of American job losses during the past two years.
Specific comments and concerns***
1. Nowhere in this document is a reader informed that coastal Louisiana overlays the largest delta in North America, which is fundamental to the protection/restoration challenge.
2. The plan includes NO MAPS showing the projected boundaries of a restored delta.
3. The draft plan has no summary index by which a reader can judge progress – or lack of. Although considerable money is spent each year to monitor coastwide habitat change the plan includes no appraisal of net landscape lost during the year.
4. Overall, the tone of the plan is far too upbeat and sanguine. The odds of long term success are extremely low and getting lower – but a novice reader would never sense this. Quote from p ix:
While coastal Louisiana’s challenges remain formidable, the State has made tremendous progress in protecting and restoring Louisiana’s coast…
5. The scientific community is NOT on board with current alignments of the major cross basin levee projects, including Morganza to the Gulf, but these extremely expensive projects (still not blessed by the corps) are presented as non-controversial.Quote from p ix:
Responding to the need for urgent action, the State stepped out ahead of its Federal partners to expedite hurricane protection and restoration projects in coastal Louisiana. The State moved quickly, using surplus dollars to fund protection projects, including the Morganza to the Gulf of Mexico, Larose to Golden Meadow, and Lafitte Hurricane Protection Projects.
6. The plan stipulates a serious reliance on an undefined and not necessarily representative group of “stakeholders.” The public should NOT be expected to make technical recommendations. Quote from p xi:
…the State established three Regional Stakeholder Workgroups (RSWs), each of which represents a major geographic region on Louisiana’s coast. …RSW engagement with the State will significantly improve the Annual Plan’s responsiveness to dynamic regional forces and concerns within the affected coastal communities.
7. Statements in the plan about adherence to and incorporation of the ‘multiple lines of defense’ strategy are not borne out by evidence or examples, especially re cross-basin levee alignments. Quotes on pp 10-11:
…the FY 2011 Annual Plan continues to incorporate the Multiple Lines of Defense strategy adopted in the Master Plan for the design, construction, and operation of hurricane protection measures.
8a. Despite glowing references to the OCPR Science office (LACES) as though it were open to new information and alternative ideas, there is no explicit science ‘portal’ for access by interested research scientists and no independent science oversight (see 8d). Quote on p13:
OCPR’s LACES Division coordinates science and engineering activities from government agencies, non- government organizations, academia, and other interests to target areas of greatest need and inform decision making with the best available technical information…
LACES will also play a key role in the development of the new planning framework and prioritization tool presented in Chapter 3…
8b. I happily endorse and salute one LACES program that I proposed ten years ago – a river science team.
LACES applied research and development activities in FY 2010 included:
*Establishing a Lower River Modeling Working Group to develop a hydrodynamic and sediment model for the lower Mississippi River system.
8c. On the other hand, I have serious concerns about a state-run carbon credit evaluation effort, given the state’s campaign against the federal regulation of greenhouse gases!
8d. I’m curious about the official role of the LCA S&T Program, which seems to have morphed from a pre-hurricane protection program. For example, I’m told that this group (and its outside Science Advisory Board) is NOT allowed to deal with the biggest elephant in the room – cross basin levees!
8e. Rather than presenting summary data on actual landscape change (see comment 1) the plan uses project starts and completions as an index of success, with no mention of net reduction in land loss! Quote on p 17:
The State’s implementation schedule for FY 2010 reflected this surge in progress. A total of 31 coastal protection and restoration projects were under construction in FY 2010, of which eight were completed.
8f. Large and small projects are lumped together without any sense of scale of cost or impact (or uncertainty).
9. The vision statement is highly questionable, e.g., an ideal outcome is far from what is posssible. Quote on p 28:
Vision – a description of the ideal outcome for the coastal protection and restoration effort. The vision answers the question, “What do we want the coastal regions to be like in the future?”
10. What are Parent Projects and children components? A number of scientists strongly disagree with claims made in the following quotes.
The State and the USACE are working jointly on four major hurricane protection projects. These projects differ from other hurricane protection projects in their size and complexity. Referred to as “parent” projects, each project contains numerous smaller “children” components with varying construction schedules. In most cases, all children projects must be in operation for the parent project to provide full protection. The parent projects are estimated to cost between $15 and $20 billion, and construction of some components will continue beyond FY 2013.
Morganza, Louisiana to the Gulf of Mexico Hurricane Protection Project (TE-64)…When complete, the project will provide hurricane storm surge protection to 150,000 coastal residents, property, and the remaining marsh in the vicinity of Houma…As of FY 2010, the State has funded construction of one child component of the project, comprising approximately 2.7 linear miles, at a cost of $16.9 million. Additionally, five components, totaling 15.6 linear miles of levees at a cost of $49 million, were under construction in FY 2010.
11. Whereas expanding the coastal zone is mentioned in the plan, the old planning units shown don’t reflect or mention any expansion.
OCM intends to submit its final draft of the study to the CPRA in February 2010.
12. The plan implies a good working relationship with the White House, which conflicts with new state policy opposing EPA regulation of industrial CO2 – despite extreme state vulnerability to sea level rise and other effects of climate change.
13. Speaking of EPA, the plan includes no specific discussion of gulf hypoxia. EPA has announced a new policy promoting more subsidies for ethanol promotion in the Midwest. This is where the state should be writing letters of objection to EPA Administrator Lisa Jackson! The following quote about a market for nutrient trading relates to hypoxia but with no explicit context for the need.
The State is investigating the development of a water quality market, in which water quality credits resulting from the operation of State coastal projects may be sold to produce an independent source of revenue for the coastal program.
14b. Photosynthesis, not respiration, absorbs atmospheric CO2! Also the statement re vast amounts of net carbon uptake is not settled and is hyperbolic.
The abundant flora in Louisiana’s coastal wetlands remove vast amounts of carbon dioxide through respiration—absorbing carbon and releasing oxygen back into the atmosphere…The State is currently quantifying and establishing standards relating to the volume of various gases sequestered and the means for increasing the uptake of carbon dioxide and other gases (such as vegetative planting within project areas). The State’s research into this initiative suggests Louisiana will become a world leader in this innovative approach to greenhouse gas sequestration.
15a. I find the priority planning process (chapter 3) totally incomprehensible.
15b. The ‘Proof of concept (POC) is highly touted but never shown.
15c. I challenge anyone in the OCPR or LACES to explain the following text:
While the prioritization tool uses MCDA methods to help prioritize projects, the tool evaluates projects based on a wide range of potential weights and is designed to be used interactively with the State and stakeholders in order to evaluate how their choices might be impacted by varying emphasis on the different metrics. This approach will avoid controversy and concern over any single set of analytically- derived stakeholder values and make the treatment of values transparent and flexible.
Finally, although the LACPR evaluated many projects, the study did not produce a final prioritization of projects or portfolios of projects. In contrast, after identifying the relative priority of different projects under different assumptions about the future and priorities, the prioritization tool evaluates actual planning constraints to develop feasible and implementable project portfolios.
15d. There is no chance for the public to comment on this so-called POC, which is arguably the most critical and controversial aspect of the entire plan. See quote:
The results of the POC analysis will be included in the Final FY 2011 Annual Plan.
This plan needs a lot of work…
*The plan will be presented at three public meetings on the afternoons of 2/8, 2/9 and 2/10 (see calendar above right). Public comments are solicited until March 12.
**Founding editor (firstname.lastname@example.org)
***Quotes in red are of particular concern.