Delta Lead Scientist creates unprecedented conflicts of interest with multi-million dollar UC research grants

The Delta Lead Scientist, Dr. Laurel Larsen, is a hydroecologist at the University of California’s Berkeley campus. She is the first mid-career scientist to hold the position of Delta Lead Scientist, having received tenure in 2018. The Lead Scientist position and the Delta Science Program were first created under the 2000 CALFED Record of Decision, and were continued under the Delta Reform Act of 2009. The Lead Scientist is responsible for “leading, overseeing, and guiding” the state and federally funded Delta Science Program.

Dr. Larsen applied for the Delta Lead Scientist position in 2019, when a $1.85 million, five year grant to her UC Berkeley research group was ending. She took office in September of 2020, stating, “I plan to build on some excellent initiatives established by my predecessor to maintain reliable funding for science research that anticipates future needs and to get a better grasp of the social-ecological interactions and feedbacks that impact the Delta.”

In 2022, Dr. Larsen co-chaired a Delta Science Program committee convening workshops on salinity management in the Delta, as well as chairing the modeling subcommittee. There were no members from NGO or fishing groups on either of the committees.

Dr. Larsen used the workshops to create a $2.5 million grant application to the UC Multicampus Research Center Initiative, entitled, Just Transitions in large socioecological systems: Drought, sea-level rise & salinity in the Delta. She was Principal Investigator on the Letter of Interest for the grant. This was unprecedented for a Delta Lead Scientist, and created thorny issues with federal conflict of interest laws. Section 208 of Title 18 of the U.S.C. is a criminal statute which prohibits a federal employee from “participating personally and substantially in any particular matter that would have a direct and predictable effect on his own financial interests.” The Delta Lead scientist is also a designated employee for state conflict of interest laws and regulations (Cal. Code Regs, tit. 23, § 5000.) The regulations state (Cal. Code Regs., tit. 2, § 18730(b)(9)):

No designated employee shall make, participate in making, or in any way attempt to use the employee’s official position to influence the making of any governmental decision which the employee knows or has reason to know will have a reasonably foreseeable material financial effect, distinguishable from its effect on the public generally, on the official or a member of the official’s immediate family…

After contacting the USGS ethics team, Dr. Larsen changed the Principal Investigator on the Just Transitions grant proposal to a colleague at UC Berkeley, and submitted a new letter of commitment indicating she would be a collaborator on the four-year grant. The new grant proposal stated that Dr. Larsen’s role would be to “serve as a liaison to the Delta Plan Interagency Implementation Committee (DPIIC)…”, a role which is clearly tied to her position as Delta Lead Scientist.

In 2023, Dr. Larsen put together a new $8.2 million grant application for the UC Climate Action Initiative and made herself a co-Principal Investigator on the grant. Dr. Larsen’s key responsibilities on the grant were also clearly tied to her position as Delta Lead Scientist:

Key responsibilities will be coordination with agency partners at the Delta Stewardship Council, US Geological Survey, Department of Water Resources, State Water Resources Control Board, and US Bureau of Reclamation, as well as coordination with the Shingle Springs Band of Miwok Indians.

However, Dr. Larsen will only be continuing in the Delta Lead Scientist position through June 2024, which is halfway through the proposed two-year term of the project. Nevertheless, the grant proposal breathlessly touts Larsen’s access to state and federal agency leaders as Delta Lead Scientist:

The inclusion of the Delta Lead Scientist (Larsen) in the project team ensures that the team has direct access to state and federal agency secretaries, directors, and/or regional directors through regular coordination meetings and Larsen’s membership on the Delta Plan Interagency Implementation Committee (DPIIC). We plan to prepare briefing papers documenting results and containing a proposed budget and plan for sustained operation of COEQWAL, which we will formally present to DPIIC and partners at the State Water Contractors and Public Water Agencies, with an ask for funding contributions.

Dr. Larsen’s plans to establish a permanent research center would be commendable if she was only a UC campus researcher. However, using her position as Delta Lead Scientist to advance the project, without arranging to turn over the coordination responsibilities to the next Delta Lead Scientist, creates major issues with conflicts of interest.

There are also ethical issues with the outreach about the proposal. The recruitment flyer for the Delta Lead Scientist position stated that responsibilities include upholding “the highest possible standards of scientific integrity” and maintaining “an unbiased, independent, policy-neutral perspective that equally serves all Delta interests” (Delta Stewardship Council, 2019).

However, the goals in the COEQWAL grant proposal manifestly fail to represent “an unbiased, independent, policy-neutral perspective that equally serves all Delta interests.” The proposal to use the grant to explore “relaxation of priority water rights allocations and/or D-1641 water quality standards” is of huge concern to Delta communities, Delta water agencies, and Delta farmers, many of whom have senior water rights. Crops in the Delta are also affected by violations of salinity standards. The relaxation of the D-1641 water quality standards in droughts has also had catastrophic impacts on pelagic fish populations in the Delta. Delta fishing, boating and recreation have also suffered.

The community engagement structure for the COEQWAL proposal also has issues with bias. It defines an end-user category of all “public water agencies, regional water districts, and senior water rights holders,” and then effectively appoints the Metropolitan Water District of Southern California as the “representative” for that category, stating,

… Given that the parties impacted by water allocations are multitudinous, it is infeasible for representation of our community partners to be comprehensive. Instead, we aim for representative and balanced participation of the three categories of community partners: representative meaning that all subcategories defined above are represented by at least one individual…

Not only does this engagement structure overtly favor one of the potential long-term funders of the COEQWAL project, it fails to acknowledge the long history of conflict over water resources in the Delta, or the different economic interests represented by Delta and South of Delta water users. Further, the community partners for the COEQWAL grant appear to have been selected without any public notice or outreach to the Delta water agency representatives and experts who participate regularly in Delta Science Program workshops.

The COEQWAL project also has “an advisory group of select community partners … to provide feedback on overall project goals, approaches, and implementation strategies.” However, the proposed COEQWAL advisory group members appear to have been selected without public notice or outreach to Delta community-based groups, fishing, or recreational groups, except for Delta Science Program contractors. This outreach for the advisory group is contrary to the Delta Stewardship Council’s Public Participation Plan, which states:

Advisory Groups Depending on the project, Council staff may convene advisory groups to assist and provide expertise in the development of projects. Members of these advisory groups typically possess relevant expertise and span the range of groups that or could be affected by the project. Interested members of the public are encouraged to be on the lookout for project advisory group calls for applications on the Council’s website, listserv, or social media in the future…

The Public Participation Plan is also a core part of the Delta Stewardship Council’s Environmental Justice Initiative, which is supposed to ensure that Council processes are “fair, transparent, and accessible” and provide opportunities for impacted communities to participate.

The Delta Lead Scientist’s involvement in these two large University of California grant proposals has created significant issues. Ted Grantham, the Principal Investigator on the COEQWAL grant, has indicated that he plans to resolve the issues by working with Dr. Larsen’s federal employer, the USGS, and the state agency she is housed in, the Delta Stewardship Council, as well as attorneys at UC Berkeley.

California Water Research has written a letter to the UC Office of the President requesting that UCOP ensure that the systemwide and UC Berkeley conflict of interest teams are in the loop and requested that the issues be resolved with transparency and inclusion of affected stakeholders.


California Water Research. 2023. Letter to UC Office of the President re: Federal and state conflict of interest issues with UC Climate Action Initiative grant COEQWAL: Equitable stewardship of California’s water in a changing climate.

Delta Stewardship Council. 2023. About the Delta Plan Intereagency Implementation Committee.

Delta Stewardship Council. 2023. Delta Lead Scientist.

Delta Stewardship Council. 2020. Delta Stewardship Council Public Participation Plan.

Delta Stewardship Council. 2019. California Delta Science Program Seeks Lead Scientist.

Doremus, H. et. al. 2022. Just Transitions in large socioecological systems: Drought, sea-level rise & salinity in the Delta. Grant proposal to University of California Multicampus Research Programs and Initiatives.

Grantham, T., Danner, E., Larsen, L. et. al. 2023. COEQWAL: Equitable stewardship of California’s water in a changing climate. Grant proposal to University of California Climate Action Initiative.

US Geological Service Office of Science Quality and Integrity. 2023. USGS Ethics Team.

University of California Research and Innovation. 2022. California Climate Action.

University of California Research and Innovation. 2022. Multicampus Research Programs and Initiatives.

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