Just a couple few, as it turns out.

Ch 5, p1, lines 8-11. I think this paragraph summarizing the source of water conflicts within the state substantially misses the point.

Yet, for at least 50 years, because of the amount of water assigned by permit or water rights or contract, the serious overdraft of our groundwater supplies, and the growing need to protect the state’s environmental resources, we find ourselves in an unsustainable trajectory of water conflicts.

There is no agency in this summary. I can see how agency doesn’t mean much when our directions were largely set in other eras, when people had understandable priorities for the time. But the fact is that people are the drivers in this. That’s mostly horrible, because people are all diffuse and complicated and don’t know what they want even while they want contradicting things simultaneously. So that’s maddening. But the problem isn’t that ‘rights were assigned.’ The problem is that people want and expect a lifestyle on a scale that has reached the physical constraints of the place we live in. We are in protracted conflict because of us and our wants, not because of the mechanisms we put in place to try to satisfy those wants.

Ch 5, p.5, right after line 10: I think you need another finding that the supplies can be gained from water conservation run along a cost curve, just as any other supplies do. They may well be the cheap supplies now, but eventually conserved water will not be the next cheapest source. The entire supply of water that can be generated from conservation may not be economically available to us, compared to developing sources like brackish de-sal or aquifer protection or buying out farmwater.

Ch 9, P1, lines 8-26, where it rhapsodizes about the Delta as a lovely place to visit. That’s nice and all, but in real life, the Delta is substantially unavailable to visitors. Much of it is privately owned; you can only reach it by boat; the natives aren’t looking for company tromping about. I’m sure it is a lovely place, but it isn’t welcoming or accessible. If we’re going to pour a lot of public money into the place because of its bewitching place-ness, that would have to change. (Then Delta natives are all, ‘but we don’t want to be a twee museum for visitors’ and I am all, ‘then pay for your own levees, which you can’t do to a level of risk that is acceptable to us at a statewide level’.)

Ch 9, p 9, lines 18-22. This finding sent me on quite the rant.

COMPREHENSIVE REGIONAL PLANNING BASED ON COORDINATED LOCAL EFFORTS CAN BEST ACHIEVE THE LEGISLATIVE OBJECTIVES OF THE DELTA PLAN. Regulation of land use and related activities that threaten the integrity of the Delta’s resources can best be advanced through comprehensive regional land use planning implemented through reliance on local government in its local land use planning procedures and enforcement.

OK. That may be a decision principle of the DSC. It may be a necessary sop to Delta activists or the Building Industry Association. It may have been declared in law by the 2009 water legislation, in which case it is stipulated. But it is not a finding, because it is not a fact. (Or if it is, you need to support it with citations.)

Mostly, local land use regulation is a seething cesspit of NIMBYism, self-interest, and local developers having just enough money to buy the marginal county supervisor. It is too small to have an enlightened longterm self-interest; the institutions were impoverished by Prop 13 and haven’t been able to consider anything but immediate self-interest since. I suppose some places may be better than others, but a landscape with development as ugly, unsustainable, and broke as pretty much everything built in California in the past half-century cannot possibly uphold successful local planning as fact.

Now, the state may be worse. That hasn’t been tried. But is certainly isn’t a finding of fact that the local or regional level is the best way to do land use planning. Support that or take it out.