Sites Reservoir —
Potential Benefits for Fish,
Potential to Worsen Conditions for Fish
Working Presumption: Thumbs Down

The proposed Sites Reservoir1 would be a new off-stream storage reservoir covering 12,000 -14,000 surface acres with 1.8 million acre-ft of storage capacity on the west side of the Sacramento Valley (Figure 1). The project would capture and store unregulated Sacramento River winter-spring runoff and some water previously stored in Shasta Reservoir. The diversion capacity to the reservoir would be 5400-6500 cfs, supplied by two existing river diversions (up to 1800 cfs at Red Bluff; up to 2100 cfs at Hamilton City) and a new diversion near Colusa (proponents are evaluating alternative capacities of 1500 and 3000 cfs, in addition to the currently preferred capacity of 2000 cfs). The Sites Authority webpage estimates that it could have diverted over 1 Million acre-ft to storage in Sites in 2018 and 1.8 Million acre-ft to storage in 2017; these figures assume bypass flow requirements at the diversion points and at Freeport, and sufficient storage capacity in the reservoir. The Draft Environmental Impact Report/Environmental Impact Statement (DEIR/DEIS) for the Sites Reservoir Project estimates the average annual diversion to Sites storage at about 500,000 acre-ft; actual diversions would vary depending on hydrology and regulatory constraints.

As an off-stream storage reservoir, Sites would store water behind a dam that is not on a major waterway. Water diverted to the reservoir would be pumped into canals from the Sacramento River, and then pumped into the storage reservoir from small holding reservoirs on the canals. The two existing diversions that would fill Sites have modern fish screening facilities. As currently envisioned, a pump-back hydroelectric operation would allow partial recovery of pumping costs.

The Sites project has potential benefits for fish, but also the potential to worsen conditions for fish.

Potential Benefits for Fish

  1. Under current operations, existing irrigation diversions on the Sacramento River draw water primarily in spring and summer via several major canal systems on the west side of the Sacramento Valley. These diversions draw mainly on water that was previously stored in Shasta Reservoir and released to the Sacramento River in part to keep river water temperatures cool. Shasta Reservoir’s cold-water pool varies in volume depending on storage and other factors, and can run out if it is not managed carefully. If the cold-water pool is depleted at the end of the summer, this threatens the viability of winter-run salmon. Under current operations, spring and summer irrigation diversions from the Sacramento River also cut flow and raise water temperatures in the lower river, which harms salmon, steelhead and sturgeon. Water diverted to storage in Sites in the winter could substitute for some of the spring and summer irrigation deliveries that currently come from Shasta. A greater percentage of water released from Shasta in spring and summer could then flow all the way to the Delta. More water could also be retained in Shasta Reservoir to protect the Shasta cold-water pool into the fall and as carryover for the following year.
  2. If more water were delivered to the Delta from Shasta Reservoir in the spring and summer, less water would theoretically be needed from Folsom and Oroville reservoirs to meet Delta water quality, outflow and other requirements. This could allow more targeted releases of water into the lower American and lower Feather rivers to protect fish in those waters. It could also allow better maintenance of cold-water pools and greater carryover storage in Folsom and Oroville, also very important for the respective fisheries downstream.
  3. Water stored in Sites could be delivered directly to the Delta via the Colusa Basin Drain (CBD) system and Yolo Bypass, reducing outflow demands from other Valley reservoirs. Water delivered directly to the Delta from Sites would be of higher potential productivity and could stimulate winter-spring Bay-Delta plankton blooms that would benefit Delta native fishes.

Potential to Worsen Conditions for Fish

  1. The proposal includes a new point of diversion on the Sacramento River with a capacity to divert 2000 cfs. This would give the project higher diversion capacity and the capability of diverting tributary runoff that would otherwise be unavailable to the two upper river diversions that now enters the Delta. This diversion would also affect flows and water temperatures in the lower Sacramento River, and subject migrating juvenile salmon, sturgeon, and steelhead to a third large screening facility. The new point of diversion would be particularly problematic if it diverted water outside the peak runoff season (late fall through spring).
  2. The new diversion and the reoperation of canal intakes at Red Bluff and Hamilton City to divert water in winter would compete for water with Delta diversions and would affect Delta outflow to the Bay.
  3. Water deliveries and hydropower releases from Sites Reservoir to the lower river at the new diversion site could affect water quality in the lower Sacramento River.
  4. With available winter off-stream storage, the existing diversions at Red Bluff and Hamilton City would be capable of diverting uncontrolled flows from tributaries that have otherwise remained relatively untouched down to the Delta.
  5. The greater diversion capacity may increase demands on Shasta storage and will increase diversion of uncontrolled tributary flows, further compromising fishes in the Sacramento River and the Bay-Delta.
  6. A small but potentially significant amount of water supply stored in Sites Reservoir would be lost to evaporation and groundwater seepage.

Above all, there is too much unknown to evaluate how Sites would affect fish.

As is the case for most proposed water supply projects, the project description in the draft DEIR/DEIS for Sites describes several potential configurations of project infrastructure and a description of proposed constraints. The DEIR/DEIS does not evaluate different constraints, such as different bypass flow requirements past each point of diversion; the DEIR/DEIS only evaluates one value for each point. In spite of numerous requests that the DEIR/DEIS evaluate project diversions with more stringent Delta flow and water quality requirements than the existing inadequate ones, the DEIR/DEIS only evaluates project yield with existing Delta constraints.

The benefit side is even more vague and conceptual. The entire construct of hypothetical Sites benefits would in fact require a new type of proscriptive rules and enforcement mechanisms that would be unprecedented for California water projects. There is simply no clue in any of the Sites literature what those rules would be or even could be.

The project description places no numbers on how much water stored in Sites the project’s operators would dedicate to actions designed to benefit fish. The project description defines no decision-making process for dedicating water to fish, other than to say that on an overarching basis fish agencies will decide. The project description defines no way in which project operators will apportion water for fish against water for water supply. For all the offsets that seem to comprise the lion’s share of fish benefits, the project description does not say how water from Sites will generate improvements in operation of state or federal reservoirs, or whether it will be Sites operators or state and federal operators who make the calls.

Then there is the question of whether there would be any offsets at all. There is no assurance that there will be any decreases at all in water use from Shasta or from other state and federal reservoirs. Water freed up by using Sites to meet Sacramento Valley water supply could simply allow Sac Valley water users to irrigate more land or sell more water for export at the Delta pumps. The DEIR/DEIS proposes no mechanism of enforcing offsets: who would regulate the project’s use of water, who would manage the interaction between Sites water and water from Shasta, Oroville, Folsom and perhaps Trinity reservoirs, and how and against whom any requirements would be enforced.

There are other problems. A shift to winter-spring diversions and use of canal systems would potentially change groundwater recharge and use patterns in the Sacramento Valley. The project would compete for water available to the proposed WaterFix Twin Tunnels project in the Delta. Sites and WaterFix have their “sights” on the heretofore untouched tributary inflows that are also protected by Delta export OMR limits so the flows reach the Bay. There will be a big fight over this uncontrolled water that now makes up a significant portion of the Bay’s freshwater input in drier years. Both projects have claimed future benefits of the same pot of water.

Conclusion

There are potential benefits from Sites project’s main features to Central Valley fishes, including salmon, steelhead, sturgeon, smelt, and striped bass. Most of the benefits would result from switching the diversion time period of the two existing upper river diversions and Shasta reservoir releases to these diversions. The added new diversion and increase in winter diversions will at important times reduce Sacramento River flow and Bay-Delta inflow and outflow, harming fish in certain but sometimes hard to quantify amounts.

Past water developments in the Central Valley have overwhelmingly made conditions for fish worse. The Sites project proponents claim that their project will be different. These proponents have not done themselves, the public, or public policy any favors by relying on generalities and politics as the centerpieces of their efforts to advance their project. At this time, there are too many unknowns to meaningfully evaluate the possibility that benefits might outweigh the harm and justify the costs. In the meantime, it is a reasonable working presumption that the Sites project will worsen conditions for fish as well.

Figure 1. Proposed Sites Reservoir and associated infrastructure on west side of the Sacramento Valley.

More on Delta Smelt Tidal Surfing

The last post about risk to Delta smelt was on January 9. Adult smelt migrate into the Delta from the Bay in winter to spawn. They take advantage of the flood tide to move upstream. However, with flood flows as high as 100,000 cfs entering the north Delta from the Sacramento River, the Yolo Bypass, and Georgiana Slough in mid- to late January 2017, there are no flood tides to ride into the north Delta spawning areas.

The only option for the adult smelt is thus to ride the incoming tide up the San Joaquin River into the central and south Delta (Figure 1). South Delta export pumping is currently at 14,000 cfs, near maximum capacity, using four rarely used auxiliary pumps. This pumping increases the pull of the incoming tide, reducing the effect of the inflow from the San Joaquin, Calaveras, Mokelumne, and Cosumnes rivers. While Delta inflow from these rivers is relatively high (Figures 2-5), it does not offset the influence of the incoming tide as does the inflow from the Sacramento.

Net tidal flows in lower Old and Middle Rivers (OMR flows) remain at the allowed limit of -5000 cfs, consistent with the smelt Biological Opinion. Several adult Delta smelt were salvaged at the export facilities in mid-January. 1 This scenario is considered a “high risk” to Delta smelt by the Smelt Working Group, because of the continuing risk that the pumps will draw or attract adult smelt into the central Delta and subsequently into the south Delta.

Under lower San Joaquin River flows, the maximum allowed export pumping is 11,400 cfs. High San Joaquin River inflow allows exports of 14,000 cfs that do not generate OMR flows more negative than -5000 cfs. The theoretical benefit of high San Joaquin River flows is that it should keep flow into the central and south Delta moving westward. But a large portion of that inflow is diverted south into the Head of Old River toward the pumping plants (Figure 6).

Figure 1. Approximate flood tide flow in cubic feet per second in mid to late January 2016. Blue arrows represent high Sacramento River, San Joaquin River and Mokelumne River flows (during flood tides). Red arrows depict negative flows of incoming tides. Note the south Delta incoming tide of -20,000 cfs would be less if not for the 14,000 cfs export rate at the south Delta pumping plants.

Figure 1. Approximate flood tide flow in cubic feet per second in mid to late January 2017. Blue arrows represent high Sacramento River, San Joaquin River and Mokelumne River flows (during flood tides). Red arrows depict negative flows of incoming tides. Note the south Delta incoming tide of -20,000 cfs would be less if not for the 14,000 cfs export rate at the south Delta pumping plants.

Figure 2. San Joaquin River flow at Mossdale at the head of the Delta upstream of Stockton and the Head of Old River. Note that on Jan 6 when flow reached about 6,000 cfs, the tidal signal dissipated when flow overcame the tidal forces.

Figure 2. San Joaquin River flow at Mossdale at the head of the Delta upstream of Stockton and the Head of Old River. Note that on Jan 6 when flow reached about 6,000 cfs, the tidal signal dissipated when flow overcame the tidal forces.

Figure 3: Flow from the Calaveras River, upstream of the Delta. The Calaveras enters the Delta at Stockton.

Figure 3: Flow from the Calaveras River, upstream of the Delta. The Calaveras enters the Delta at Stockton.

Figure 4. Release from Camanche Dam to the Mokelumne River. CDEC does not show flow values for the Mokelumne at gages further downstream. The Mokelumne enters the Delta near Jersey Point.

Figure 4. Release from Camanche Dam to the Mokelumne River. CDEC does not show flow values for the Mokelumne at gages further downstream. The Mokelumne enters the Delta near Jersey Point.

Figure 5. Cosumnes River flow well upstream of the Delta. Much of the high flow peaks enters the river’s connected floodplain, roughly between Lodi and Elk Grove, and does not flow immediately to the Delta. Flows in the Cosumnes enter the Mokelumne before passing into the Delta

Figure 5. Cosumnes River flow well upstream of the Delta. Much of the high flow peaks enters the river’s connected floodplain, roughly between Lodi and Elk Grove, and does not flow immediately to the Delta. Flows in the Cosumnes enter the Mokelumne before passing into the Delta

 Figure 6. Flow entering the entrance to Old River from the San Joaquin River near Stockton.


Figure 6. Flow entering the entrance to Old River from the San Joaquin River near Stockton.

  1. https://www.usbr.gov/mp/cvo/vungvari/dsmeltsplitdly.pdf Note: website has changed to this new site.

What Caused the Impending Extinction of Delta Smelt?

CSPA’s fisheries biologist Tom Cannon gave a presentation entitled “Contributing Cause of Smelt Decline: Water Exports” at a symposium on March 29, 2016 at UC Davis. The theme of the conference, sponsored by the Delta Stewardship Council, was: “Delta and Longfin Smelt: Is Extinction Inevitable?”

In his presentation, Tom put forth the hypothesis that the cause of the probable extinction of Delta smelt was the commencement of operation of the State Water Project’s Banks Pumping Plant in the mid-1970s. When Banks came on line, South Delta exports tripled, going from 2 million acre-feet to 6 million acre-feet per year. Tom’s hypothesis is that the mechanism of likely extinction was entrainment of Delta Smelt into the inflow to State and Federal South Delta pumping plants: exports.

The presentation’s first slide shows the familiar long-term Fall Midwater Trawl Index (Figure 1). Tom emphasized the sharp drop in the Index in 1981 (red circle in Figure 1), the first dry year of operations under the 1978 Delta Plan (water quality standards limiting operations of the Delta pumping plants). He noted that the decline likely started in the mid-1970s, but was most severe in 1981. There were recovery periods in the non-drought years of the 1990’s and 2010-2011. However, in 2001-2005, smelt and other Delta species crashed, a period now known as the “Pelagic Organism Decline,” or POD. Following a mild recovery in the wet year 2011, Delta smelt collapsed to record low indices in 2014 and 2015 (indices of 9 and 7, respectively, not shown in Figure 1).

Other slides depict (1) the huge losses of adult smelt as indexed by January1 salvage numbers in 1981 (Figure 2), and (2) the salvage counts of juvenile Delta smelt in spring 1981 (Figure 3). The total salvage for January 1981 alone was over 10,000 adult Delta smelt, which compares to a total of 56 in January 2015 and 12 in January 2016. The total juvenile Delta smelt salvage in spring 1981 exceeded 100,000; in 2015, it was 4.

An example of salvage during the 2001-2005 POD is winter-spring salvage in 2003 (Figure 4). Tom attributes the POD decline to the tens of thousands of Delta smelt lost to entrainment in winter and spring, including a likely large number of non-detected larvae under conditions of maximum exports.

According to Tom, export entrainment is the primary causal factor for the death spiral of Delta smelt, not low outflow. There were relatively high or improved smelt abundance indices in 1972, 1990, and 1991 (see Figure 1), which were all years with low outflows but also low exports. This is not to say, however, that low outflows are not also factors that contribute to high entrainment (Figures 2 and 3).

Tom concludes that Delta smelt are virtually extinct because their adult spawning numbers are insufficient to provide recovery even under 2016’s good (wet) conditions. Adult numbers are simply too low to produce sufficient offspring (Figure 5). The proof will come this spring, summer, and fall when indices of Delta smelt juveniles will likely remain critically low and not reach 2010 or 2011 levels, the last years when habitat conditions were favorable.

Tom Cannon Presentation – Contributing Cause of Smelt Decline: Water Exports

Figure 1. Fall Midwater Trawl Index for Delta smelt 1967-2013. (Source: CDFW.)

Figure 1. Fall Midwater Trawl Index for Delta smelt 1967-2013. (Source: CDFW.)

Figure 2. January salvage of adult Delta smelt at South Delta export pumps in 1981. Also shown is export rate (cfs) and Delta outflow (cfs). The maximum allowed export rate is 11,400 cfs. (Data Source: CDFW.)

Figure 2. January salvage of adult Delta smelt at South Delta export pumps in 1981. Also shown is export rate (cfs) and Delta outflow (cfs). The maximum allowed export rate is 11,400 cfs. (Data Source: CDFW.)

Figure 3. Spring salvage of juvenile Delta smelt at South Delta export pumps in 1981. Delta smelt juveniles begin reaching salvageable size (>20 mm) in early May. Also shown is export rate (cfs) and Delta outflow (cfs). The maximum allowed exportsrate is 11,400 cfs. (Data Source: CDFW)

Figure 3. Spring salvage of juvenile Delta smelt at South Delta export pumps in 1981. Delta smelt juveniles begin reaching salvageable size (>20 mm) in early May. Also shown is export rate (cfs) and Delta outflow (cfs). The maximum allowed exportsrate is 11,400 cfs. (Data Source: CDFW)

Figure 4. Winter-spring salvage of Delta smelt at south Delta export pumps in 2003. Delta smelt young begin reaching salvageable size (>20 mm) in early May. Also shown is export rate (acre-feet per day) by pumping plant. The maximum allowed export rate is 11,400 cfs (about 23,000 acre-feet per day). (Data Source: CDFW). Winter salvage is primarily adult smelt. Spring salvage is predominantly juvenile smelt (>20 mm). April entrainment of 5-15 mm larval smelt is not accounted for at salvage facilities, because they pass undetected through salvage screens.

Figure 4. Winter-spring salvage of Delta smelt at south Delta export pumps in 2003. Delta smelt young begin reaching salvageable size (>20 mm) in early May. Also shown is export rate (acre-feet per day) by pumping plant. The maximum allowed export rate is 11,400 cfs (about 23,000 acre-feet per day). (Data Source: CDFW). Winter salvage is primarily adult smelt. Spring salvage is predominantly juvenile smelt (>20 mm). April entrainment of 5-15 mm larval smelt is not accounted for at salvage facilities, because they pass undetected through salvage screens.

Figure 5. Index of adult Delta smelt spawner abundance from winter Kodiak Trawl Survey 2002-2016.

Figure 5. Index of adult Delta smelt spawner abundance from winter Kodiak Trawl Survey 2002-2016.

  1. Salvage collections are notoriously inefficient on small fish entrained into the pumping plants. Predation loss before entering the salvage facilities has been estimated to be higher than 90%.

Delta Fish and Flows – Listen to our fish scientists

The Delta independent Science Board, made up mostly of non-Californians and non-fish biologists, waded into the fray on Delta issues again with their recent report:  Flows and Fishes in the Sacramento-San Joaquin Delta – Research Needs in Support of Adaptive Management 1

After 50 years of extensive research and adaptive management, the Delta water managers still believe we need the insights of outsiders before the secrets of the Delta are exposed to improve water management for fish.  Once the center of world-wide estuarine science beginning in the 60’s and 70’s, the San Francisco Bay Delta now has new advice sought from outside sources.  I came to the Bay-Delta in the late 70’s as an outsider to learn from and participate in comprehensive fish-ecosystem science going on in the Bay-Delta.  I was honored to participate in and contribute to Bay-Delta science.  Many of the young scientists who came with me then and since have contributed decades of their careers to Bay-Delta science.  Yet there is this continuing quest for more outside input fraught with non-fish science.

The Report

Delta Independant Science Board Report Cover

“The economic, ecological, and social costs of scientific uncertainty in water management controversies are significant – and to some degree unavoidable.  This report therefore recommends, first and foremost redoubling effects to identify causes and effects concerning fishes and flows in the Delta.”  (Page 5).  Uncertainty is not the cause of the failure in protecting the Bay-Delta ecosystem.  It is a failure to use science with its uncertainties to protect the ecosystem.  After 40-plus years of study, the answers are obvious.  Redoubling?  Why not simply recognizing the obvious?  There are no doubts that changes in flows are the cause of most of the Delta problems, and that changes designed to reduce entrainment of fish at the Delta export pumps (OMR, etc.) have proven ineffective.  There is no need to redouble efforts to understand the relationship between flows and fish.  We know why the Winter Run salmon were wiped out below Shasta in 2014 and 2015.  We know why Delta and Longfin Smelt populations have been at record lows the past two years.

“The habitat and flow needs of the native species are difficult to define in the transformed place and in a novel ecosystem.”  (Page 5).  The habitat and flow needs are well known.  The ecosystem, though “transformed,” is not novel.  Anyone who has been here awhile and studied the fish knows.

“Focus on cause and effect – the mechanisms that enable flows to affect fishes.  Deeper causal understanding is important for identifying and reducing risks to water supply and fish populations.”  (Page 5).  We’ve been through this time after time.  Overwhelmingly, finding the political will to follow the science we already have is far more critical than fine-tuning the mechanistic understanding of how fish respond to flow.  The problem in the Delta is systemic: water management has turned the hydrograph on its head and deprived the estuary of half of its flow (in dry year sequences, more than half).  The State Water Board’s 2010 Delta Flow Criteria Report 2 got this fundamentally right: on a mass and systemic basis, Delta inflow and outflow need to be radically increased to provide basic system functions, including variability.   Not every effect is a direct effect.  Focusing only on direct effects – the “causal mechanisms” – is overwhelmingly about “risks to water supply.”  Beneath the surface of hunting for mechanisms is an engineering-style belief that one can surgically provide water to produce this or that benefit at the exact moment it’s needed.  Sure, better understanding is good, and different specific actions can help.  But the need isn’t met by adding up specific actions.  We need to restore underlying ecosystem function that serves as a foundation for targeted improvements.  Right now we aren’t even close.

“Understanding the dependencies of fishes on water flows is central to understanding the Delta ecosystem.  Relationships between fishes and flows drive state and federal policy and related regulatory and management decisions, and consequently have been central to legal arguments and decisions.”  (Page 9).  Delta water quality control plans, and water rights orders since the 1960s (mainly D-1485 and D-1641), have recognized (and focused) on the relationship between flows and fishes.  Earlier, the focus was on striped bass and flows (D-1485), but more recently the focus has been on smelt-salmon and flows (D-1641).  There have been changes in summer standards that hurt striped bass while strengthening winter-spring standards have helped smelt and salmon.  But after decades of management under the standards and an array of biological opinions, it is obvious to most that the level of protections has been inadequate.  The problem is not a lack of science and understanding; it is a lack of commitment to them.

 “A comprehensive, integrative, and well-planned scientific approach focused on processes, drivers, and predictions is needed to aid near-term and long-term adaptive management and to predict how future changes might affect fishes.”  (Page 21). The Bay-Delta has had this for 50 years.  The science, data, and adaptive management are well documented, as well as reflected in water rights, water quality standards, biological opinions, and management and recovery plans.  But most important of all, they are carried in the minds of hundreds of Bay-Delta scientists who have dedicated their careers to this purpose.

 “The development of a generalized fish model portable for different fish species and for different water management decisions is needed to forecast  expected consequences and timelines for adaptive  management strategies.”  (Page 23). Such models already exist in many forms that reflect and carry the knowledge of what has been learned over the past 50 years.  Models developed in the 60’s for striped bass still work today.

Follow-up Workshop

At the follow-up Delta Independent Science Board workshop in December, Dr. Lund, chairman of the Science Board, discussed the major findings of the report, the first being that connecting flows and fishes is central to achieving the state’s coequal goals. “The modern Delta is not a native ecosystem but is dominated by non-native species with some natives, and that’s a particular challenge for some of the ecosystem goals for the Delta,” he said.  “Statistical analyses show that flows do affect fish, but decisions need a little bit more causal understanding of how flows involve fishes, especially as we try to manage the Delta and make some larger changes over time. Where larger changes occur in the Delta that we have to respond to, we need a more causal understanding of how these relationships work.3  In my experience, when correlations that support science theory continue becoming more statistically significant with each added year of data, it is time to accept the theories and start doing something.  Using the same excuses for inaction and continuing to promote more science will not save the Bay-Delta ecosystem.

In Conclusion

What has been missing for decades is this:  our locally grown fisheries scientists have no access to what are often called the “knobs” of management in the Delta.  Instead of scientists, resource agency managers and water purveyors constrict the range of adaptation to protect water supply at the expense of fishes and their habitats.  Adaptive management is driven by managers.  Our Smelt and Salmon Working Groups are stymied by senior management and by political oversight and control.  Adaptive management in the Delta has become a synonym for how far fisheries agency managers will agree to weaken resource protection.  Examples include weakening water quality standards in droughts; allowing unrestricted water transfers through the Delta; and closing the Delta Cross Channel gates in summer.

It is time to listen to our home-grown fish scientists and let them turn the knobs in the right direction.

NMFS on Salmon and the Drought, Part 2

As noted in the first blog of this series, the National Marine Fisheries Service (NMFS) is responsible under the Endangered Species Act for protecting the endangered Winter Run Chinook salmon of the Sacramento River. But when the US Bureau of Reclamation (USBR or Bureau) and the Department of Water Resources (DWR) have asked NMFS to comment on proposed changes in Central Valley Project operations during the present four-year drought, NMFS has consistently concurred, often going against its own previous prescriptions and advice. As a consequence, the Winter Run salmon were put at great risk, decimating the 2014 and 2015 year classes and again placing the population at the brink of extinction.

April 8, 2014 Drought Operations Plan

On April 8, 2014, the Bureau and DWR issued a 2014 Drought Operations Plan, in which they proposed low releases in the Sacramento River in April and May:

Keswick releases will be held to no greater than 3,250 cfs, or as determined necessary to reasonably target no more than 4,000 cfs at Wilkins Slough, unless necessary to meet nondiscretionary obligations or legal requirements;

The critical phrase here is “nondiscretionary obligations.” It is the view of NMFS, as described in its Biological Opinion for the Operation of the State Water Project and Central Valley Project, that the Bureau of Reclamation does not have the discretion to release less water to Sacramento River Settlement Contractors than 75% of contracted amounts. Thus, low April and May flows called for in the 2014 Drought Operations Plan were overwhelmed by calls for water by the Settlement Contractors.

April 8, 2014 NMFS Letter on Sacramento River Water Temperature Management

On April 8, 2014, NMFS wrote a letter1 to the Bureau and DWR in response to their April 8, 2014 Drought Operations Plan. In that letter, NMFS concurred with the Plan, but highlighted a concern regarding deliveries to the Settlement Contractors:

“Winter-run Chinook salmon viability and Sacramento Settlement Contractor deliveries: Reclamation is working with Sacramento River Settlement Contractors on options to shift a significant portion of their diversions this year out of the April and May period and into the time frame where Keswick releases are higher to achieve temperature objectives on the upper Sacramento River. The willingness and cooperation of the settlement contractors in this effort would allow a modified diversion pattern and create the benefit of increased Shasta Reservoir storage at the beginning of the temperature control operations and increased availability of water to these senior water rights holders in this critically-dry year. This deferral of irrigation would allow implementation closer to the lower range of the Keswick release schedule for April and May, as identified in Section V of the DOP (Drought Operations Plan).

Thus the agencies and the Settlement Contractors were left to work out on a voluntary basis a mechanism to keep enough cold water in Lake Shasta to protect Winter Run salmon throughout the summer and fall. The State Water Board approved the Plan.

It didn’t work. Though releases from Shasta in April, 2014 were low, the Bureau ramped up releases from Shasta to the Settlement Contractors in early May (Figures 1 and 2), and cold water in Lake Shasta was depleted by the end of August.

Graph of May 2014 releases from Keswick

Figure 1. May 2014 releases from Keswick to the Settlement Contractors were far above those advised by NMFS (

Graph of releases May 2014

Figure 2. May 2014 releases from Keswick to the Sacramento River were diverted by Settlement Contractors upstream of the Delta. Contrast flow at Wilkins Slough (~25 miles north of Woodland) with releases from Keswick in Figure 1: most flow increases over the month were diverted north of the Delta.

January 29, 2015 Letter on Sacramento River Water Temperature Management

On January 29, 2015, NMFS wrote a letter to the Bureau and DWR in response to a new January Temporary Urgency Change Petition (TUCP) to the State Board.2 In its January 29, 2015 letter, NMFS’s acknowledged lessons from 2014 regarding water temperature:

Temperature management is critical. Salmon rely on cold water, particularly during early life stages when fish are young and vulnerable. Shasta and Keswick dams block endangered winter-run Chinook from accessing their native cold water habitat in the Upper Sacramento and McCloud Rivers, so their eggs and fry are particularly vulnerable to high summer temperatures. Data from the Sacramento River indicate 2014 temperatures were at levels that impact the survival of juvenile salmon and steelhead. We found that the 2014 temperature criterion was exceeded starting in August, resulting in approximately 95% mortality of eggs and fry upstream of Red Bluff Diversion Dam. As of December 16, 2014, an estimated 390,000 juvenile winter-run Chinook salmon passed Red Bluff, compared to 1.8 million in the previous brood year and 850,000 in brood year 2011, the year of the winter-run collapse (see Nov. 18 USFWS/CDFW/NOAA Fisheries presentation to State Water Board). This is the fewest winter-run Chinook juveniles per female spawner passing Red Bluff in 11 years.

March 27, 2015 Letter

However, by the end of March, 2015, NMFS was once again tiptoeing through a proposal by the Bureau to repeat the previous year’s disaster. On March 27, 2015 NMFS once again concurred with the proposed TUCP, even while highlighting the “conflict” between Winter Run salmon and deliveries to the Settlement Contractors. 3

The Project Description meets all of the required aspects of the contingency plan required in Action I.2.3 .C, as follows:

  • Reclamation has provided an assessment of additional technological or operational measures that can increase the ability to manage the cold water pool.
  • Reclamation notified the State Board, through filing the TUC Petition, that meeting the biological needs of winter-run and the needs of resident species in the Delta, delivery of water to nondiscretionary Sacramento Settlement Contractors, and Delta outflow requirements per D-1641 , may be in conflict in the coming season.
  • In conclusion, NMFS concurs that Reclamation’s Project Description is consistent with Action I.2.3.C and meets the specified criteria for a contingency plan. … Furthermore, the best available scientific and commercial data indicate that implementation of the interim contingency plan will not exceed levels of take anticipated for implementation of the RPA specified in the CVP/SWP Opinion.

And once again in 2015, no one stepped up to maintain cold water in Shasta Reservoir in April and May (Figure 3).

Graph of 2015 releases

Figure 3. In 2015, releases to the Settlement Contractors ramped up in April and were high throughout May.

July 1 Letter4

By July 1, 2015, NMFS was already issuing a post-mortem.

“NMFS acknowledges that storage in Shasta Reservoir at the beginning of the temperature management season in June, and the quantity and quality of the cold water pool, will not provide for suitable winter-run habitat needs throughout their egg and alevin incubation and fry rearing periods.”

Final Comment

We should expect more from the federal agency mandated to protect our endangered salmon. At a minimum, NMFS should have not concurred, in 2015 (or in 2014, for that matter), and should have called out the fact that added take of Winter Run would occur, further jeopardizing the viability of the species through direct mortality and degradation of their critical habitat.

Regardless of the legal merit of NMFS’s position that it does not have authority under the Endangered Act to limit deliveries to the Settlement Contractors, its failure to defend listed Winter Run gave cover to the Agency that has that authority: the State Water Board. CSPA, the Bay Institute and others asked the State Water Board in February, 2015 and again in the spring to reduce 2015 deliveries to the Sacramento Valley Settlement Contractors to save the Winter Run (and to protect Delta smelt). In an Order denying Petitions for Reconsideration of the 2015 TUCP’s filed by CSPA and others, the State Water Board offered the rationale:

However, at the time the changes were approved, the tradeoff appeared to be reasonable based on the information available at the time, including biological reviews from DWR and Reclamation and concurrence from the National Marine Fisheries Service (NMFS), U.S. Fish and Wildlife Service (USFWS), and California Department of Fish and Wildlife (DFW) (collectively fisheries agencies) with the changes. For these reasons, the petitions for reconsideration of the past Executive Director actions are denied. 5