Category Archives: Water Quality

Essential Needs for the Recovery of Endangered Winter-Run Salmon

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Summer spawning and egg incubation water temperatures in the upper Sacramento River below Shasta Dam is a well-known and documented key to the recovery of winter-run salmon Chinook salmon. In a December 2018 post, I noted the importance of early-fall flows to support the emigration of juvenile winter-run salmon from spawning and early rearing areas of the upper Sacramento River near Redding. In this post, I add another measure to the list of essential needs.

  • Late-fall flows – Flows to move winter-run juveniles from the upper and lower river into and through the Delta in the late fall.

What kind of late-fall flows are specifically needed? The type that occurred in December 2019 from a spate of storms (Figure 1). The 10,000+ cfs flow in the lower Sacramento River got wild winter-run salmon smolts through the lower Sacramento River, as seen from the Knights Landing screw-trap catches. The 20,000+ cfs early-December pulse of Delta outflow got wild winter-run salmon smolts moving through the Bay toward the ocean, as seen in the Chipps Island Suisun Bay trawl catches.

I have previously recommended extending Fall X2 Delta outflow protections1 and reducing Delta exports2 to help the winter-run smolts during their emigration to the ocean. As it was, 10,000+ cfs exports in the latter half of December 2019 took over half of the potential Delta outflow. Figure 1 clearly shows the importance of the late-fall flows to the emigration of winter-run.

Observed patterns of winter run emigration provide further evidence of the need for flows in the late fall. Figure 2 shows late fall 2017 conditions when there was no late fall flow pulse. The movement of winter-run smolts through the Bay was delayed, occurring in small spurts from late January through March. There is no doubt that one-to-three-month delays in smolt migrations from the river and Delta to the ocean are detrimental to the population and to recovery.

Figure 3 shows the latefall flow pattern over the past decade. Recovery of winter-run salmon depends on protecting the flow pulses. The tendency is to export as much of the first flows of the water supply season as possible and get it stored in south-of-Delta reservoirs. Most of the late-fall rainfall was already captured in upstream reservoirs, so these flow pulses are just a fraction of Central Valley’s natural flows.

A close look at Figure 3 shows minimal Delta outflow in the late fall of 2011 and 2017. Both years were just coming off wet water years. Shasta Reservoir had above-average storage for December in both years (>3 MAF, two-thirds full). Modest commitments of reservoir water could have greatly benefitted winter-run emigration. Inflows to Shasta reservoir in December of both of those two years were over 200 TAF. An added release of less than half that inflow (100 TAF) could have provided five days of 10,000 cfs pulse flow to the December release pattern in both years. Such a pulse flow, in combination with reduced Delta exports (Figure 4), would have provided five days of 20,000+ cfs Delta outflows in December 2011 and 2017 to support wild winter-run smolt emigration and winter-run recovery.

Figure 1. Catch patterns of juvenile wild winter-run salmon in the upper Sacramento River at Red Bluff, the lower Sacramento River at Knights Landing, and at Chipps Island in the upper Bay in fall 2019. Red circles denote catch peaks associated with fall pulsed flows.

Figure 2. Catch patterns of juvenile wild winter-run salmon in the upper Sacramento River at Red Bluff, the lower Sacramento River at Knights Landing, and at Chipps Island in the upper Bay in fall-winter 2017-18. Red circles show dispersed timing of emigration and lack of large catch peaks in the absence of fall pulsed flows.

Figure 3. Delta outflow in late fall 2010-2019. Note lowest flows were in 2011, 2013, 2015, and 2017.

Figure 4. December 2011, 2017, and 2019 south Delta exports at the state Banks (HRO) and federal Tracy (TRP) pumping plants. Capacities are 7500 and 4400 cfs, respectively. Note the extremely high and unusual December 2019 exports.

Fall X2 should extend through December

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In a recent post, I described the Fall X2 provision in the 2008 Delta Smelt Biological Opinion that protects smelt by requiring a modest Delta outflow from mid-August through October in Above Normal and Wet years.  In the same post, I described how the 2019 Biological Opinion for smelt would move the compliance point for Fall X2 upstream into the Delta, reducing low salinity zone habitat.   In this post, I suggest that the Fall X2 requirement should not only be retained with the old compliance point, but also that the applicable time period should extend through December.

First, if the X2 provision is not extended into December, this is what happens:  (1) Delta outflow drops to zero or even negative, as occurred this past November 2019 (Figure 1); and (2) the low salinity zone moves up into the Delta via the San Joaquin River channel toward the export pumps (Figure 2).

Second, winter-run salmon smolts that pour into the Delta from the Sacramento River in November and December of all but the driest years (Figure 3) will have difficulty surviving and exiting the Delta for the Bay and ocean.

Third, what few Delta smelt that may be surviving will be put at risk of being drawn into the central and south Delta (Figures 4 and 5).

Fourth, longfin smelt will be at risk to being drawn into the Delta (Figures 6 and 7).

Fifth, the primary food of young Delta native fishes, calanoid copepod adults, which concentrate in the low salinity zone, would be drawn into Delta (Figure 8).  Bay-Delta pelagic plankton productivity would suffer.

In conclusion, there are presently few constraints on water project operations in the Delta in November-December.  Freshwater outflow to the Bay can be zero or even negative, as occurred this past month, November 2019.  The updates to the Bay-Delta Water Quality Control Plan and to state permits that regulate Delta exports should extend Fall X2 through December in order to protect Delta native fishes.  Compliance would entail Delta outflows in the 8000-10,000 cfs range and/or Jersey Point salinity of about 500 EC.

Figure 1. Tidally filtered flow in the Sacramento River channel at Rio Vista and Jersey Point in the San Joaquin channel in November 2019.

Figure 2. Salinity (EC) at Jersey Point in the San Joaquin channel of the west Delta in November 2019.

Figure 3. Cumulative catch of winter-run Chinook salmon at Knights Landing rotary screw traps in fall-winter of water year 2017. Source: DOSS 2017.

Figure 4. Trawl catch distribution of Delta smelt fall 2011, the last time Delta smelt were relatively common.

Figure 5. Salvage of Delta smelt pre-spawn adults in fall-winter of water year 2003.

Figure 6. Longfin smelt trawl catch distribution in November 2011.

Figure 7. Longfin smelt trawl catch distribution in December 2011.

Figure 8. Adult calanoid copepod catch distribution in November 2011 zooplankton survey.

Failure to Protect Winter-Run Salmon in Fall 2019

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In a December 2018 post, I focused on the importance of fall pulse flows in moving winter-run salmon juveniles downstream in the Sacramento River to the Delta and Bay. Without pulse flows, the juvenile winter-run are less likely to make or survive the downstream move from spawning and early rearing areas in the upper river. They are thus less likely to reach the ocean and contribute to subsequent recruitment into the adult population.

A gradual recovery of adult spawners, egg production, and wild fry production (Figure 1) has been helping recovery of the winter-run population since the population crash during the 2012-2015 drought. Wild fry production as estimated from Red Bluff screw trap collections is up sharply in 2019 (Figure 2 top chart).

However, in fall 2019, winter-run fry have received even less support in terms of river flow in their important journey to and through the Bay-Delta than in previous years. Numbers caught in lower river screw traps are very low (Figure 2 bottom chart), reflecting low movement rates from the upper river and poor survival. Both factors are a consequence of poor river flows. There are simply no reasons for Reclamation to be so stingy with Shasta Reservoir releases this fall, after a very wet year in 2019 and with Shasta Reservoir at or near a record-high level for this time of year.

A close-up of the Figure 2 data in Figure 3 shows some effort on the part of Reclamation to provide flow pulses,1 but the effort was not enough. Furthermore, Reclamation subsequently offset its meager augmentation by cutting reservoir releases in November (Figure 4). The November reduction further compromised the emigration and survival of juvenile winter-run salmon. Reclamation’s tendency to cut releases in fall and winter, the period when winter-run most depend on river flows, is pronounced in all but the wettest years (2011 and 2017) over the past decade (Figure 5). Such tendency probably has been deemed acceptable because downstream tributary flows (Battle Creek, Cow Creek, etc.) provide fall flow pulses in some years (e.g., fall 2016 Figure 6, fall 2011 Figure 7). But inflow pulses from those tributaries are downstream of the Redding spawning reach; in the spawning reach, flows come almost exclusively from Shasta Reservoir releases.

What is needed are modest flow pulses from Shasta Reservoir in fall, especially when pulses in downstream tributaries occur. Releases for several days in the 10,000-15,000 cfs range, or of slightly less magnitude when coincident with tributary flow pulses, would help emigration (and survival) of winter-run juvenile salmon from the upper river. Such pulses should not be followed by offsetting flow decreases, as have occurred this fall (Figures 3 and 4). Low flows following fall pulses cause redd dewatering or fry stranding of spring-run, fall-run, and late-fall-run salmon, which spawn in the upper river later in the season than winter-run.

The late November 2019, Thanksgiving week storm should provide ample Shasta storage and tributary flows to allow modest flow pulses from Shasta Reservoir. Such flow pulses would benefit all four salmon runs in the Sacramento River.

Figure 1. Emigration timing of juvenile winter-run salmon from the upper Sacramento River and the estimated number of juvenile salmon (millions) passing Red Bluff during water years 2004-2018. Note the poor production in critically dry 2014 and 2015 from loss of cold-water pool and associated catastrophic egg mortality.

Figure 1. Emigration timing of juvenile winter-run salmon from the upper Sacramento River and the estimated number of juvenile salmon (millions) passing Red Bluff during water years 2004-2018. Note the poor production in critically dry 2014 and 2015 from loss of cold-water pool and associated catastrophic egg mortality.

Figure 2. Daily estimated juvenile winter-run salmon catch per trap day passing Red Bluff in the upper river and Tisdale Weir in the lower river in summer-fall 2019. The numbers passing Red Bluff are strong, especially when one considers that they were the offspring of poor brood-year 2016.  

Figure 2. Daily estimated juvenile winter-run salmon catch per trap day passing Red Bluff in the upper river and Tisdale Weir in the lower river in summer-fall 2019. The numbers passing Red Bluff are strong, especially when one considers that they were the offspring of poor brood-year 2016.

Figure 3. Daily estimated juvenile winter-run salmon passage per trap day at Red Bluff in the upper river, also showing river flow in summer and fall 2019.

Figure 3. Daily estimated juvenile winter-run salmon passage per trap day at Red Bluff in the upper river, also showing river flow in summer and fall 2019.

Figure 4. Shasta/Keswick Dam releases in fall 2019, along with daily median flow average for 55 years.

Figure 5. Shasta/Keswick Dam daily average releases from 2009-2019, along with daily median flow average for 55 years.

Figure 6. Daily estimated juvenile winter-run salmon passage per trap day passing Red Bluff in the upper river and Tisdale Weir in the lower river in fall 2016. Note that the flow pulses (and associated higher catches) in early and late November were from tributary storm-related inflows. Such events had not occurred as yet in 2019 (Figure2).

Figure 7. Daily estimated juvenile winter-run salmon passage per trap day passing Red Bluff in the upper river and Tisdale Weir in the lower river in fall 2010. Note the flow pulses (and associated higher catches) in late October and in December.

 

 

 

  1. Reclamation’s sporadic 2000 cfs flow pulses in late October observable in Figures 2 and 3 were likely part of Reclamation’s contribution to maintaining Delta inflow and outflow for the Fall X2 requirement. ↩

Reclamation and DWR Maintain Fall X2 at Chipps Island in 2019 for the Last Time

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Despite falling river flows and lower reservoir releases, the US Bureau of Reclamation and the California Department of Water Resources maintained Delta outflows and the prescribed fall salinity in the Delta (X2 located at Chipps Island, River Kilometer 74) in the last half of August, September and October 2019. They did this by sharply reducing Delta exports (Figures 1 and 2). These actions helped to maintain low salinity habitat in (and flow through) Montezuma Slough in Suisun Marsh (Figure 3).

High Delta outflow and reduced Delta exports in September and October are good for all Delta native fishes. These conditions protect wild juvenile winter run salmon that began migrating downstream into the Delta (Figure 4). Delta smelt and longfin smelt remained in the Bay, west of the Delta.

Fall X2 was a provision of the 2008 and 2009 Biological Opinions for the Long-Term Operations of the Central Valley Project and the State Water Project. It applied only in Wet and Above Normal water years. New Biological Opinions released in October 2019 have moved the initial compliance point for the Fall X2 requirement upstream to River Kilometer 80, reducing low salinity habitat by pushing it further up into the Delta. 1

Figure 1. Delta Exports (TRP and HRO) and Outflow (DTO), and Lower Sacramento River flow at Wilkins Slough (WLK), Verona (VON), and Freeport (FPT).

Figure 1. Delta Exports (TRP and HRO) and Outflow (DTO), and Lower Sacramento River flow at Wilkins Slough (WLK), Verona (VON), and Freeport (FPT).

Figure 2. Salinity (EC) at Mallard Island (km 74), the Fall X2 prescribed location under 2008 Delta smelt biological opinion. X2 is approximately 3800 EC.

Figure 2. Salinity (EC) at Mallard Island (km 74), the Fall X2 prescribed location under 2008 Delta smelt biological opinion. X2 is approximately 3800 EC.

Figure 3. Salinity (EC) in Montezuma Slough in late summer and fall 2019.

Figure 3. Salinity (EC) in Montezuma Slough in late summer and fall 2019.

Figure 4. Winter run catch in juvenile salmon monitoring in summer-fall 2019. Sacramento beach seine stations are in the north Delta.

Figure 4. Winter run catch in juvenile salmon monitoring in summer-fall 2019. Sacramento beach seine stations are in the north Delta.

  1. For discussion of the new biological opinions, see The Good, the Bad, and the Ugly in the New Non-Jeopardy Biological Opinions for CVP/SWP, http://calsport.org/fisheriesblog/?p=2889 ↩

The Good, the Bad, and the Ugly in the New Non-Jeopardy Biological Opinions for CVP/SWP

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The Endangered Species Act (ESA) directs all federal agencies to work to conserve endangered and threatened species and to use their authorities to further the purposes of the Act. The purpose of the Act is to protect and recover imperiled species and the ecosystems upon which they depend. Protect means to not allow “take” of listed species. If some take occurs despite best efforts, then “reasonable and prudent” alternatives (RPAs) may be needed to protect the threatened or endangered species.

The US Bureau of Reclamation and its partner the California Department of Water Resources (permittees) operate the federal Central Valley Project (CVP) and the State Water Project (SWP) under federal and state ESA “take” permits issued in 2008-2009 biological opinions that included RPAs. The RPAs constrained water supply deliveries and other project operations during the past decade to protect listed salmon, smelt, sturgeon, and steelhead.

Over the past decade, the parties have reinitiated consultation to revise take permits and RPAs. The initial motivation for reinitiation was that RPAs and take limits were not protecting or recovering the listed species. The US Fish and Wildlife Service (USFWS) and the National Marine Fisheries Service (NMFS) recognized that more stringent measures were needed. A series of draft opinions were developed with further protections, culminating with a July 1, 2019 draft jeopardy opinion from NMFS on Reclamation’s proposed action as of that time. A jeopardy opinion occurs when an action is reasonably expected, directly or indirectly, to diminish a species’ numbers, reproduction, or distribution so that the likelihood of survival and recovery in the wild is appreciably reduced.

Reclamation updated its “proposed action” in response to the draft jeopardy opinion. “It must also be acknowledged that the current status of all these species continues to be imperiled, and that one of the objectives of the proposed action is to maximize the available supply of water for irrigation, municipal, and industrial deliveries.”1 Reclamation doubled down. Reclamation’s most recent proposed action includes some provisions of the 2008/2009 biological opinions’ RPAs and recent jeopardy draft BO. In response, the Services relented under pressure from the Trump administration, replaced technical staff with a new group of managers, and recently issued final non-jeopardy opinions.

The new proposed action from Reclamation can now go into effect without RPAs that would hinder Reclamation from maximizing water deliveries. The new Biological Opinions will govern project operations under a wide array of vague commitments to protect and recover listed species: some good, some bad, and some simply ugly.2

The Good (Well, as Good as it Gets)

  1. Delta Smelt Conservation Hatchery
    This is long past due. However, the proposal is vague and limited in potential scope and funding commitment.
  2. New Habitat
    Most measures that require new habitat in the new BO were prescribed in past BOs. Now there are new vague commitments. Some listed species (e.g., Delta smelt) have populations too small to benefit from new habitat.
  3. Hatchery Management
    New and updated old prescriptions, though vague, are badly needed, especially for converting the program focus from mitigation hatcheries to conservation hatcheries.
  4. Proposed Funding for research and restoration
    The BOs contain an estimated total of $1.5 billion dollars in proposed funding to support threatened and endangered fish survival and recovery through research and restoration actions. However, the proposed funding is not dedicated and is vague, particularly in that much of the effort and funding may go to prior commitments that have not been funded.
  5. Delta Cross Channel Improvements
    Proposed upgrades to the Delta Cross Channel Gates are helpful but vague. The Delta Cross Channel should be screened, as should nearby Georgiana Slough.
  6. Modifying the Head of Old River Scour Hole
    This action is OK but addresses only one of many predation hotspots for salmon and steelhead caused by human actions and man-made structures in lower San Joaquin River.
  7. Fish Passage on Deer Creek (a non-Project watershed)
    This is one positive action for listed spring-run salmon among many in NMFS’s Central Valley Salmon Recovery Plan. All of the actions in the Recovery Plan should be included and funded. Deer Creek, a tributary to the lower Sacramento River, has a spawning run of wild spring-run salmon. Deer Creek does not have a project dam on it, but Deer Creek salmon pass through the lower Sacramento River and Delta. Deer Creek salmon and all other salmon-bearing tributary populations are thus affected by project operations.
  8. Adult Straying Barrier on the Knights Landing Outfall Gate (a flood and drainage system)
    This was constructed under prior commitments but failed.
  9. A “drought toolbox” to prioritize a proactive approach to drought planning, including early coordination with senior water right users
    Proactive coordination is fine and good, but the BOs contain no commitment to reduce diversions by senior Settlement and Exchange contractors or any others during droughts.
  10. Support for NMFS Steelhead Monitoring and Collaboration Activities with Non- Project Tributaries
    Monitoring may inform mitigation. However, monitoring in itself is not mitigation. All recovery plan actions should be supported because CVP/SWP operations and facilities have had major adverse effects on all Central Valley steelhead populations.
  11. $14 million commitment to expedited implementation of the Battle Creek Restoration Project including reintroduction of winter-run Chinook salmon
    The commitment to fund actions on Battle Creek is long overdue, but the funding in the BO is inadequate by an order of magnitude.
  12. A stronger commitment to actions maintaining low-salinity habitat in the Delta Smelt Summer-Fall Habitat Action with commitments regarding Suisun Marsh Salinity Control Gate (SMSCG) operations and projects for other elements of habitat
    It is important to acknowledge the importance of summer-fall habitat representing half of the smelt life-cycle, but the commitment in the BO is vague and likely ineffective as formulated. Rather than being used more often, the SMSCG should simply be removed. It has been a detriment to smelt, salmon, steelhead, and sturgeon populations since its use began in 1989.

The BAD

  1. Drought Mitigation
    Drought mitigation in the BOs focuses on maintaining Shasta Reservoir’s cold-water-pool. The proposed action drops mitigation actions for wet years such as Fall X2. The proposed action drops previous OMR constraints that provided some protection in drought years. The one-hand-giveth-while-the-other-taketh-away approach is an old tired gambit. The ostensible improvement at Lake Shasta eliminates numeric targets for Shasta carryover storage.
  2. Real time management – protect when and where the fish are
    This is poor prescription because some listed species populations are so low that they are undetectable (e.g., Delta smelt). Larval life stages also go undetected. Past detection rates even for larger populations have been poor, and actions to reduce impacts have been gamed and trimmed to the bone. Real time detection does not protect primary productivity and food sources and other elements of critical habitats. The managers charged with managing have a long history of choosing water supply over fish protection.
  3. A more detailed description of Shasta Dam operations and a commitment to Cold Water Management Tiers
    This prescription does not protect listed winter-run salmon in droughts from thermal shock or dewatering of redds, which are the primary factors in recent low survival and production. Prior RPA and Recovery Plan requirements to fix problems with Spring Creek powerhouse (Whiskeytown Lake thermal curtain) and Shasta Dam warm water power releases are not included in the new salmon BO.
  4. “New” Science
    A commitment to maintaining long-term monitoring programs and recognizing past and present science is needed. “New” science funded and conducted by water contractors or federal/state project operators will ensure any new science will be biased – foxes assessing their effects on the henhouse. The science and its presentation and analyses have become more and more controlled by water supply entities, and less and less by resource agencies. The BOs give more control of science to water suppliers. The revisions to the draft BOs are clear evidence of the new realignment of roles and new controls on science.
  5. Performance Metrics for managing Old and Middle River reverse flows to limit salmonid loss to similar levels observed under the previous BiOp through explicit reductions in export pumping.
    The BOs’ performance measures for reverse flows are vague, ineffective, and unenforceable. Wild components of salmon populations were hard hit in droughts under previous BOs. “Similar” levels of loss are not protective and will not promote recovery.
  6. Performance Metrics for incubation and juvenile production of salmonids under the proposed Shasta Cold Water Pool Management strategy
    The BOs’ performance measures for cold water management at Lake Shasta are vague, ineffective, and unenforceable.
  7. Commitments to manage Old and Middle River reverse flows for limiting larval and juvenile delta smelt entrainment based on modeled recruitment estimates
    OMR rules have been one of the major restrictions on exports under the past BOs. The rules proved beneficial to the listed species survival (primarily reduced salvage and improved through-Delta survival of tagged salmon smolts). The new strategy would allow changes that would allow greater levels of exports under OMR reverse flow prescriptions. The poor survival of San Joaquin salmon under existing rules would remain poor or further decrease. Entrainment of young smelt (not measured under existing rules), an existing serious concern, would only worsen. Modeling entrainment risk has not worked and has not been verifiable. The main risks to smelt are pulling larvae into the central Delta with its poor habitat (not just to the south Delta pumps) and the destruction of their critical pelagic rearing habitat.
  8. Independent Review Panels to evaluate the science behind actions and outcomes
    This is nothing new. There have been so many “independent” review panels. I remember working with Pete Chadwick back in the mid-70s. He consulted on my projects on the Hudson River Estuary. He and his CDFG staff working on the Bay-Delta were on the cutting edge of estuary science. They trained the next generation and they in turn trained the next. Outsiders have only verified what CDFG already well understood. Same goes for NMFS and the USFWS, as well as UC Davis. Together as IEP they manage Bay-Delta and Central Valley science more than adequately with the help of a huge cadre of capable scientists among NGOs. Water agencies and other water suppliers just can’t handle the truth, so they hire their own consultants and many outside “independent” consultants.
  9. Ramping rates specificity for reservoir releases to reduce the risk of stranding
    Ramping rates do not work for eggs and fry salmon that are in gravel beds for up to several months. Reductions in flows from Keswick Reservoir after winter-run fry have left their nests (redds) in the fall strands up to 80% of new fall-run redds.

The Ugly

  1. Commitment to implement appropriate actions after two years of low winter-run Chinook salmon egg-to- fry survival.
    Shasta operations in the 2014 and 2015 drought killed 90-95% of the egg production of winter-run salmon. The new Salmon BO would make that acceptable under the ESA. It would stretch the no-take standard to no take in more than two years out of three.
  2. More specificity on collaborative planning with specific habitat restoration and facility commitments.
    More planning for habitat restoration and facilities is not needed. Reclamation, DWR and other responsible agencies should get on with prior commitments. The history of foot-dragging on habitat restoration in the Central Valley is a worthy rival to the foot-dragging by PG&E in maintaining and upgrading its infrastructure.
  3. A commitment to sediment supplementation and food-web studies for the protection of delta smelt.
    As proposed the supplementation of sediment would come in the form of the discharge of warm, polluted agricultural drainage water full of non-native predatory fish into critical habitats of listed fish.
  4. Dynamic, real-time monitoring of changing conditions and potential species impacts, within an improved scientific and adaptive-management-based decision-making framework; avoiding or minimizing fishery impacts while increasing operational flexibility.
    Real time management will not work for rarer listed species like Delta smelt. This has been tried for three decades and has not worked. The adaptive managers will be the same managers who produced the revised non-jeopardy BOs. “Operational flexibility” is a buzzword for increased diversions, primarily Delta exports.
  5. Operational rules that lay the foundation for eventual voluntary agreements on water flows for rivers that feed into the delta. Those agreements promise even greater protections and investments in fish and the environment.
    Most of the “even greater protections” will have to backfill the protections that these BOs took away. The Voluntary Agreements offer pennies on the dollar in terms of necessary flow through the Delta into the San Francisco Bay.
  6. Eliminating or Modifying Existing RPAs and Take Limits
    • Modifying year-round temperature and Shasta reservoir storage management program to minimize effects to endangered winter-run salmon.
      NMFS and CDFW were just starting to get it right. NMFS’s 2017 draft RPA for Shasta would have required stronger carryover storage requirements.
    • Long-term passage prescriptions at Shasta Dam and re-introduction of winter-run to its native habitat in the McCloud and/or Upper Sacramento Rivers.
      They were ready to start this program after promising initial feasibility studies. The foot draggers strung it out until Trump administration officials threatened in 2019 to arrest DWR personnel who were installing equipment to begin a pilot implementation.
    • Old and Middle River flow levels that limit the strength of the reverse flows
      There will be less of the needed restrictions under Reclamation’s new plan.
    • Prescriptions for additional technological measures at the facilities to enhance screening and increase survival of fish.
      There will be fewer planned upgrades to project facilities to protect fish than were promised under the previous BOs.
    • Prescribed additional measures to improve survival of San Joaquin steelhead smolts, including both increased San Joaquin River flows and export curtailments.
      No longer apply.
    • Prescribed flow management standard, a temperature management plan, additional technological fixes to temperature control structures, and, in the long term, a passage at Nimbus and Folsom dam to restore steelhead to native habitat.
      No longer apply.
    • Prescribed year-round minimum flow regime necessary to minimize project effects to each life-stage of steelhead, including new springtime flows that will support rearing habitat formation and inundation, and create pulses that allow salmon to migrate out successfully.
      No longer apply.
    • The Fall X2 provision has been eliminated.
      This flow-salinity RPA protected longfin and Delta smelt in summer and fall of wet years.
    • Take limits have been eliminated.
      They should have been revised to be more protective.

What is Missing

So much is missing that is within state and federal governments’ power and authority in the final approved Reclamation proposal. Here is a limited selection.

  • Effective Management of Shasta Cold-Water Pool
    Missing from the BOs are controls of Spring Creek powerhouse warm water releases into Keswick Reservoir, modifications to hydropower operations, long term Shasta storage rules, and modifications of water contractor deliveries. Combinations of these actions would have alleviated winter run salmon recruitment failures in 2014 and 2015. Reclamation’s approved proposal would allow such drastic recruitment failures in future droughts.
  • Commitment to comply with water quality standards on flow, water temperature, salinity, and export restrictions
    Reclamation has made no commitment to comply with state water quality standards or other state laws.
  • Commitment to provide needed pulsed flows
    Coordinated pulsed flows are needed to increase survival of hatchery and wild salmon. None are included in Reclamation’s plan, with the possible exception of a pulse from Shasta when it is likely to spill anyway.
  • Commitment to implement recovery plan actions
    Recovery, not just protection, is needed and is required by the ESA. These BO’s do not address recovery plans. The ESA goes beyond simple mitigation. The ESA focuses on minimization of effects, enhancement, and recovery.

In Conclusion: Ugly

Reclamation’s proposed action has been approved by the Services. The proposed action includes some good concepts for protective measures (though generally the requirements are vague, underfunded and not enforceable), and a suite of bad and downright ugly actions that will harm affected listed fish species. The overall mix will lead to much confusion, wringing of hands, blaming, ignoring of responsibility, initial lawsuits, and (if the initial lawsuits fail) further lawsuits when fish metrics fail to show improvement. Some actions will take time to implement, while some are already too little too late.

The Services should have issued jeopardy opinions with a suite of appropriate RPAs. That did not happen. Instead, the Services are allowing further risk of extinction to the listed species. The best example of this is allowing expected temperature-dependent egg mortality levels for Sacramento River winter-run Chinook salmon to occur in “Tier 3 and 4 years.” Mortality due to allowed temperature exceedance was a major cause in the recent decline in the winter-run salmon population, one of the few species listed as “endangered” rather than the more common “threatened” designation. The effect the salmon BO will allow is entirely avoidable and within the control of the state and federal agencies involved in permitting the CVP. NMFS has designated winter-run as a “Species in the Spotlight”; it’s more likely that it is now a “Target for Extinction.”

  1. USFWS summary, p. 13. ↩
  2. The US Fish and Wildlife Service’s summary of both its own Biological Opinion for smelt and the National Marine Fisheries Service’s Biological Opinion for salmon, steelhead and green sturgeon is available at: https://www.fws.gov/sfbaydelta/cvp-swp/documents/ROC_on_LTO_Summary_FINAL.pdf
    For the complete USFWS and NMFS Biological Opinions and appendices, go to: https://www.fws.gov/sfbaydelta/CVP-SWP/index.htm ↩