CDFW proposes to close the Sacramento River above Redding to sport fishing from April 27 to July 31

The California Department of Fish and Wildlife proposes to close fishing in the 5.5 miles of the Sacramento River above Hwy 44 Bridge from April 27-July 31 this year.1 These upper few miles of the river below Keswick Dam provide a world-class sport fishery for rainbow trout (salmon fishing in this river reach is permanently closed). The premise of the ban is to reduce mortality on endangered Winter Run Chinook Salmon. The reach is where most of the Winter Run spawn, eggs incubate, and fry emerge in gravels from late spring through early fall (Figure 1). Last summer 95% of the 2014 Winter Run brood year perished from redd dewatering and high water temperatures.

The proposed closure would inappropriately place the drought-management burden on sport anglers when the problem is poor water management in the present drought. The low flows and high water temperatures in 2014 were caused by depletion of Shasta Reservoir’s cold-water pool to meet water demands of Central Valley Project Settlement Contractors in the Sacramento Valley. These senior water rights holders received 1.3 million acre-ft of Shasta storage during 2014. An additional 110,000 acre-ft released was sold to south of Delta contractors via water transfers from July through November. Shasta Reservoir storage peaked last year near 2.4 million acre-ft in early May, then declined to 1.1 million acre-ft in October.

Shasta Reservoir releases were over 6000 cfs from early May through August (Figure 2). Most of the Winter Run spawned in June and July at flows in excess of 8000 cfs. During the August through September incubation period, flows fell to near 4000 cfs, resulting in the dewatering of many salmon redds. Redd dewatering coupled with high water temperatures resulted in the loss of 95% of the brood year production during September, according to CDFW and NMFS.

Closing the fishery this summer implies that sport fishing activities would otherwise contribute to Winter Run mortality when there is no scientific evidence to support this assumption. Boat traffic is mainly drift boats, which minimally disturb fish. The most obvious risk from fishermen would be trampling redds in the low water period in the August-September incubation period, which is not included in the proposed ban. Even that risk is low, since few anglers wade the spawning reaches.

DFW’s blog states: “Given the gravity of the current situation, it is imperative that each and every adult fish be given maximum protection.”2
The “maximum protection” standard would be much better applied if the Department unequivocally supported measures to protect all life stages of Winter Run. Instead of burdening sport fishermen with the proposed ban, the solution is for the State Water Board to reduce deliveries from Lake Shasta to water contractors this summer. If releases had been cut by a third from May-July last year, the Winter Run could have been saved. Yes, this would have come at a substantial cost to state’s agricultural production (Settlement contractors were already cut 25%), but the drought is unprecedented. Winter Run salmon extinction should not be the price paid to keep rice production high this year in the Sacramento Valley.

Figure 1.  Water temperature (degrees F) in Redding reach below Keswick Dam (KWK) in 2014, along with percent of Winter Run life stage present.  Red line shows water temperature where egg/alevin survival is less than 50%.  Source: NMFS

Figure 1. Water temperature (degrees F) in Redding reach below Keswick Dam (KWK) in 2014, along with percent of Winter Run life stage present. Red line shows water temperature where egg/alevin survival is less than 50%. Source: NMFS

Figure 2.  Shasta Reservoir releases from April through October 2014.

Figure 2. Shasta Reservoir releases from April through October 2014.

What is wrong with NDOI?

Delta outflow is the amount of fresh water that exits the Delta for San Francisco Bay. Freshwater outflow is the most important ecological function other than perhaps the tides for the Bay-Delta Estuary. The Net Delta Outflow Index (NDOI) is the parameter that is used as a measure of Delta outflow to manage the ecology, water supply, and water quality of the San Francisco Bay-Delta Estuary. NDOI is a number estimated from a crude set of variables, some measured and some guessed. It is a relic of the past and deserves a quiet burial, the sooner the better. Continuing its use is meaningless, unreasonable, harmful, injurious, and unnecessary.

The NDOI or QOUT is calculated as follows:

QOUT = QTOT + QPREC – QGCD – QEXPORTS – QMISDV1

Where:

  • QOUT Net Delta outflow at Chipps Island
  • QTOT Total Delta inflow
  • QPREC Delta precipitation runoff estimate
  • QGCD Delta-wide gross channel depletion estimate (consumptive use)
  • QEXPORTS Total Delta exports and diversions/transfers
  • QMISDV flooded island and island Storage diversion

All of these parameters are estimates themselves subject to gross errors, which compound to make NDOI useful only as a gross indicator of freshwater outflow to San Francisco Bay.

The main use of NDOI is in Bay-Delta water quality standards and drought emergency change orders:

“ The Delta outflow objectives included in the Bay-Delta Plan and D-1641 for the February through June time frame are identified in footnote 10 of Table 3 and Table 4 of footnote 10. Pursuant to footnote 10, the minimum daily NDOI during February through June is 7,100 cfs calculated as a 3-day running average. This requirement may also be met by achieving either a daily average or 14-day running average EC at the confluence of the Sacramento and San Joaquin Rivers of less than or equal to 2.64 millimhos per centimeter (mmhos/cm) (Collinsville station C2)… The minimum Delta outflow levels specified in Table 3 are modified as follows: the minimum Net Delta outflow Index (NDOI) described in Figure 3 of Decision 1641 during the months of February and March shall be no less than 4,000 cubic-feet per second (cfs) on a monthly average. The 7-day running average shall not be less than 1,000 cfs below the monthly average.”2

Reliance on NDOI is one thing, but using 3-day, 7-day, and monthly average limits borders on insidious. Government agencies have long recognized this and a decade ago commissioned the US Geological Survey to measure Delta outflow with UVM meters that measure water column velocities in real time.
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The new measurement is defined as Net Delta Outflow or NDO3.

Net Delta Outflow

We compared the two parameters for the month of March, 2015. The differences in the parameters as seen in the chart below are significant and appear to be related to the fact that NDOI does not incorporate tidal effects. NDO indicates that outflow is much reduced by high “spring” tides that effectively block freshwater outflow to the Bay. The effect is real and roughly amounts to over 100,000 AF of freshwater flow that did not make it to the Bay in March, which resulted in greater saltwater intrusion and degradation of the Bay-Delta Estuary, as well as degradation of Low Salinity Zone habitat quality and quantity.

March 2015 NDO vs NDOI

The effect also leads to saltwater intrusion into the central Delta via False River. Delta exports pull some of their water from the west Delta to the south Delta pumping plants via False River. The chart below shows higher salinity water entering False River during high tides with peaks in salinity during spring tides and low NDOs. The salt from these intrusions degrades Delta water quality and the quality of water exported from the Delta to Southern California. The salt is also a signature of the Low Salinity Zone, which is the primary nursery area for Delta Smelt, Longfin Smelt, and many other Delta fish. Pulling LSZ water into the central Delta kills many Longfin and Delta smelt.

False River

It is no longer reasonable to manage Delta outflow and exports with rules that include the NDOI. A vast array of flow, salinity, temperature, turbidity, chlorophyll, dissolved oxygen, and radio-tagged fish detection meters allow instantaneous management of the Delta. Changes are hung up on antiquated Delta standards that are frequently relaxed by the State Water Resources Control Board to satisfy the insatiable water demands of the state and federal water projects and their contractors. The NDOI needs a quick burial. If the Board can issue temporary drought emergency change orders involving the NDOI, why can’t it rely on better measurement to better protect, if only temporarily, the beneficial uses of the state’s water supply?

  1. Source:  http://www.water.ca.gov/dayflow/ndoVsNdoi/
  2.  Source: SWRCB March 5 Temporary Urgency Change Order for Central Valley Project and State Water Project
  3.  http://www.water.ca.gov/dayflow/ndoVsNdoi/