2011 coastal plan substitutes process for progress – postponing action (part 2)
by Len Bahr*
This post concludes a two-part critique of the final 2011 annual state plan to protect and restore coastal Louisiana, a document that authorizes the expenditure of hundreds of millions of dollars. The plan was produced by the Office of Coastal Protection and Restoration (OCPR). It now awaits approval by the Louisiana legislature and a signature by Governor Jindal, before taking effect on July 1.
Part one of my critique described eleven specific issues that concern me about the final plan. This conclusion focuses exclusively on what I believe is the most problematic element, the ‘crown jewel’ of the plan, a so-called project prioritization tool described in Chapter 3, beginning on p35.
The prioritization tool will support a decision process based on coastal needs and on tax dollar value, rather than one that allows politics to intrude or that merely funds projects with the most vocal advocates. (p36)
Frankly, the phrase coastal needs and tax dollar value gives me pause. What do these six words mean?
I give the benefit of the doubt to those who drafted this tool that it was created to reduce subjectivity in project selection and sequencing. The draft version of the plan hyped the tool like Steve Jobs promoting the iPad, while providing no details.
After reading the fine print included in the final plan this prioritization tool appears to be a well-intentioned but I think Quixotic attempt to eliminate bias in policy decisions. In fact, I think that the actual effect of implementing this process will be to substitute process for progress, indefinitely postponing critical time-sensitive decisions, many of which would be locally unpopular.
In addition, attempting to apply this tool will further obscure the process by which one project is selected over another. This could set the stage for encumbering billions in boondoggles. The following three so-called ‘activities’ of the tool particularly leave me scratching my head:
1. Defining the goals and desired outcomes for protection and restoration activities.
2. Estimating how different projects and portfolios of projects contribute to the achievement of those goals and desired outcomes.
3. Using the information regarding predicted performance to prioritize projects and assemble high-priority project portfolios for implementation. (p38)
With respect to number 1, after two decades of planning are we still defining goals and outcomes? With respect to number 2, at this late date are we still attempting to estimate the effects of different projects (and portfolios of projects)? With all due respect to number 3, it’s meaningless.
I think that a basic flaw in the prioritization tool process involves assigning subjective number indices to project variables. Numbers are seductive; they provide digital fodder for computer algorithms that supposedly compare various combinations of projects and produce ‘objective’ outputs on which to base policy decisions. There’s a time-worn term for the credibility of such results, “Garbage in, garbage out.”
I’ve seen a number of similar unsuccessful efforts to develop coastal project selection tools. This tool reminds me of the notorious Wetland Value Assessment (WVA) procedure, sadly still being used in the Coastal Wetlands Planning, Protection and Restoration Act (CWPPRA) program to prioritize projects that can’t really be compared objectively.**
Consider the following description of the current situation in south Louisiana and imagine that you are the (elected) Czar of the Coast:
1) Your kingdom consists of an extensive piece of deltaic landscape barely above sea level, on which two million people, many with multi-generational roots, live, work and play.
2) This landscape is simultaneously sinking and shrinking like atrophying muscle, while sea level rises under the effects of climate change and global warming. Local land loss reflects misguided federal and state policy, exacerbated by ignorance, greed and a widespread failure to either believe in or comprehend modern science.
3) Now, imagine being responsible for developing a plausible strategy to offset land loss and to protect, restore and sustain the threatened landscape in the face of mounting evidence that the entire territory cannot realistically be saved.
You might choose between two very different strategies, one action oriented and one process-oriented. You could:
A) convene an independent panel of world-class scientists and engineers empowered to formulate de novo and within six months a technically defensible strategy for protecting and restoring the specific areas of landscape that could be sustained for at least 90 years. This process would also identify the converse, landscape that could not be protected into the 21st century.
Alternatively you could:
B) appoint a committee of staff bureaucrats (whose paychecks depended on their fealty) to spend an indeterminate amount of time developing a tool to prioritize competing project concepts. This tool would consist of a complex algorithm to convert vague qualitative estimates of project effectiveness into pseudo-quantitatve metrics. This process would allow you to claim progress while kicking difficult political decisions down the road.
Strategy A would generate a product, not a process. This product would doubtless include site-specific recommendations for large river diversions, complementary multiple layers of non-structural defensive elements and strategic structural projects, such as ring levees. It would include a project sequence and a detailed set of maps projecting how the landscape would look as a result of implementing the plan. Finally, this product would include specific recommendations for an organized retreat from (site-specific) high-risk areas, which would involve buyouts and fair compensation. On the down side, choosing A would doubtless rankle constituents from the areas that cannot be protected.
In contrast, choice B would produce a methodology, not a blueprint. It would perpetuate the proud tradition of describing coastal restoration in sweeping generic optimistic terms. By omitting a specific protection/restoration footprint, i.e., a map, strategy B would imply that any piece of landscape had an equal shot at remaining dry into the future. Unfortunately, this strategy would unfairly mislead and jeopardize at-risk constituents. On the up side your election term as Czar would probably expire before disaster strikes.
Unfortunately, the prioritization tool that is about to become official bears a striking resemblance to choice B. Look carefully at Figure 1 (page 43 from the final plan).
This pretty well summarizes the basics of the new prioritization tool. I underlined passages that suggest either subjective aspects of this process or that otherwise give me strong doubts that it can provide important new insights.
*Founding editor (email@example.com)
**I should note that among coastal restoration practitioners I’m in a mjnority with respect to my opinion that the WVA is voodoo science.