Last month, the website Water Deeply published an op-ed I wrote about the likely harm to salmon and other endangered species from the California WaterFix project. This op-ed followed a letter that NRDC sent to the Fish and Wildlife Service and National Marine Fisheries Service regarding major flaws in the draft biological assessment. Below is a more detailed version of that op-ed, which includes page citations to the WaterFix biological assessment.
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The California WaterFix project, which proposes to construct and operate twin tunnels that would divert millions of acre-feet of water before it reaches the Bay Delta estuary, would likely lead to extinction of several native fisheries, based on our review of the recent biological assessment prepared by the Bureau of Reclamation.
The assessment – which is required as part of the Endangered Species Act (ESA) consultation process with the U.S. Fish and Wildlife Service and National Marine Fisheries Service (NMFS) and analyzes the effects of the construction and operation of the proposed twin tunnels on endangered species – depicts a grim outlook for salmon and other native fish and wildlife species, many of which are already critically threatened by unsustainable water management.
This shouldn’t come as a surprise. For years, state and federal agencies, independent scientific peer reviews and conservation and fishing groups have warned that these tunnels would pose significant environmental harm without major changes.
For example, the biological assessment estimates that, once the tunnels are operational, water temperatures below Shasta dam will be so high that they will likely be lethal for endangered winter-run Chinook salmon during the critical spawning and egg incubation season more than 40 percent of the time in August, 50 percent of September and more than 90 percent of October, with the most adverse effects happening in drier years [see page 5.D-321 of Appendix 5.D of the BA, which is also pasted below. Earlier this year, NMFS concluded that to protect winter run chinook salmon, water temperatures should not exceed 55°F for the 7-Day Average of the Daily Maxima (7DADM) at the Clear Creek temperature compliance point on the Sacramento River.]. These effects are far more severe than is authorized for these imperiled salmon in existing biological opinion.
So how does Reclamation propose to deal with this impact? They want NMFS to ignore it. The assessment proposes that agencies exclude the effects of upstream reservoir operations from the WaterFix consultation [see BA at 1-3 to 1-4], even though they are inextricably linked to export operations in the Delta. After all, much of the water slated for export through the tunnels would be coming from upstream reservoirs.
In addition, instead of helping salmon migrate through the Delta, the biological assessment estimates that the tunnels are likely to reduce survival of juvenile winter-run salmon as they migrate downstream through the Delta and out to sea [See BA at 5-146 to 5-148, 5-165 to 5-167, 5.D-507 to -508]. Salmon are already threatened by low survival rates as they migrate through the Delta, yet the assessment shows that survival would worsen with the tunnels.
These same state and federal agencies are well aware of how close these fish species are to extinction. Only a few days after initiating consultation on the WaterFix projects, they also reinitiated consultation on the effects of existing water project operations under the Endangered Species Act. This process will revise the existing biological opinions for the Central Valley Project and State Water Project, and is necessary because water project operations during the drought have driven multiple fish species to the very brink of extinction. In addition, this process will incorporate new scientific information and studies from the past few years that demonstrate that additional environmental protections are necessary to stave off extinction [for instance, NMFS’ recent letter to Reclamation regarding Shasta water temperature management states that “Various RPA actions within Action Suite I.2 are not performing as designed to achieve their objective to avoid jeopardy of winter-run Chinook salmon during extended drought conditions…. Therefore, we propose to review potential modifications to the Shasta RPA Action Suite 1.2 that incorporate new information regarding temperature management that has been developed during the recent drought period.”].
Yet inexplicably, the biological assessment for WaterFix wholly ignores much of this new scientific information. For instance, new scientific data and analysis from state and federal agencies shows that more Delta outflow in the spring and summer is needed to protect delta smelt [FWS’ letter in response to the reinitiation request states that, “We recognize that this new information is demonstrating the increasingly imperiled state of the Delta Smelt and its designated critical habitat, and that emerging science shows the importance of outflows to all life stages of Delta Smelt and to maintaining the primary constituent elements of designated critical habitat.”]. Yet the biological assessment completely ignores this data and the effects of reduced flows on delta smelt.
The analyses that the biological assessment does include hardly demonstrate a benefit to delta smelt from WaterFix: They predict that adult entrainment of delta smelt will be similar to today’s levels and that there would be little to no difference in entrainment of juveniles in drier water years [see BA at 6-93, 6-97, 6-99, 6-104, 6-107]. Furthermore, it understates the adverse effects on delta smelt from other effects of the tunnels, such as reduced turbidity in the Delta and increased harmful algal blooms like microcystis [BA at 6-129 to 6-130, 6-140 to 6-157].
Moreover, for species like longfin smelt and green sturgeon, Delta outflow is one of the primary factors affecting their abundance, survival and successful reproduction. WaterFix proposes that it will at best maintain existing flows in the spring months, even though both species have been declining rapidly under existing flow levels. That means continued population declines for both of these species is likely, even though they are already approaching extinction [see BA at 5-195 to 5-200 for sturgeon; longfin smelt are not analyzed in the biological assessment because while they are listed under CESA and the Fish and Wildlife Service concluded that listing is warranted under the ESA, it has not occurred yet].
Even worse, many of these impacts are likely to be far worse in future years as a result of climate change. The biological assessment only looks at these environmental impacts in 2030, which the document shows is before construction of the tunnels will even be finished [see BA at 3-45, which describes “…the whole period of construction (2018 to 2030)” for the tunnels; see BA at 4-51, which states that the intermediate forebay will not be constructed until July 2031.] Climate change is likely to increase water temperatures, reduce flows, worsen salinity and increase harmful algal blooms, all of which increases the harm to fish and wildlife from the tunnels.
The WaterFix biological assessment fails to provide sufficient scientific information for a legitimate consultation under the Endangered Species Act, and the information that is provided demonstrates that the tunnels are likely to jeopardize the continued existence and recovery of salmon and other native fish species in the Bay Delta watershed. Far from protecting our native fish and wildlife, WaterFix is tunneling toward extinction.