FEIS on Long-Term Operations of the Central Valley and State Water Projects
By Tom Cannon/thomascannon0@gmail.com
This is another post in the series on salmon recovery in the Central Valley. Normally, the environmental permitting process with its Environmental Impact Statement (EIS), biological assessments, and responding biological opinions and incidental take permits would lead to a viable recovery program. But that is simply not going to happen with the process of defining long-term operations of California’s two large water projects. There is too much at stake and political forces are far too strong. The sixth largest economy in the world will move ahead sacrificing natural resources in its wake – not willing to reasonably compromise and share in the pursuit of the mighty dollar. We as citizen stakeholders are forced to except the use and abuse of our public trust resources by governments we elect.
On Nov. 15, 2024, the US Bureau of Reclamation, the federal agency charged with operating California’s Central Valley Project, released the final Environmental Impact Statement for the Long-Term Operation of the CVP and SWP. The FEIS was prepared in accordance with the National Environmental Policy Act. The final EIS presents Reclamation’s analysis of the four alternatives and no action alternative that reflect a “reasonable” range of options for the operation of dams, powerplants, and related facilities of the CVP and Delta facilities of the State Water Project (SWP) that balance water resource allocation among beneficial uses.
“The preferred alternative includes a new framework for Shasta Reservoir operations to benefit winter-run Chinook salmon; revised operational criteria for Delta exports that supply water to cities, farms, and wildlife refuges and supports implementation of the Healthy Rivers and Landscapes Program, to provide more Delta outflow/habitat restoration in the Sacramento-San Joaquin Bay-Delta.”
“On Sept. 30, 2021, Reclamation and the California Department of Water Resources requested reinitiation of consultation on the Long-Term Operation of the CVP and SWP with the U.S. Fish and Wildlife Service and National Marine Fisheries Service due to anticipated modifications to the proposed action that may cause effects to ESA-listed species and/or designated critical habitat not analyzed in the 2019 biological opinions.”
The two biological opinions have been issued with the FEIS. A summary of my recommendations regarding the FEIS and issues covered in the biological opinions follow.
Alternatives
The alternatives described in the FEIS other than the No-Action Alternative are not real alternatives with specific operations and infrastructure elements. Basically, the alternatives described are only concepts. For example: Alt 2 is an operating concept that prioritizes storage and cold-water pool management. Each of the alternatives should prioritize these objectives otherwise the concepts would be unreal. Alternatives should not be defined by objectives but represent a specific operational and structural scheme/regime that may approach the objectives a different way or with a different degree of implementation. One alternative or alternative type could involve an array of structural fixes and no changes to the basic flow regime. Another may simply be strictly operational regime that focuses on varying degrees of implementation – some with dramatic effects and some with less dramatic effects, with each having different degrees of benefits and effects on other beneficial uses. Another alternative may focus on new infrastructure. Another may involve changes to mitigation (e.g., hatcheries). Another may involve only salmon habitat improvements. A further example may involve different ways to deliver water from storage (e.g. with or without new infrastructure – such as a new Sites Reservoir). An environmentally preferred alternative may have a mixed or variable array of actions to address objectives.
“Alternative 2 prioritizes storage of water in Shasta Reservoir for water temperature management during multiple years of drought and results in reduced temperature-dependent mortality during egg incubation. Alternative 2 would reduce deliveries for CVP water service and repayment contracts and Sacramento River Settlement (SRS) Contractors under specific drought conditions to increase storage in Shasta Reservoir. This increased storage would result in higher fall and winter releases in non-drought conditions. Higher fall and winter releases would improve juvenile Chinook salmon survival during migration down the Sacramento River. In drier years, Alternative 2 reduces fall and winter releases and reduces survival during migration.”
Comment: There are many factors regulated in the alternatives with widely differing degrees of implementation. Criteria should be defined for each factor and varied based on conditions in the watershed over that year. Criteria should be developed for different scenarios. Factors should include those that affect Keswick, Red Bluff, Wilkins Slough, Freeport, Rio Vista, and Chipps Island flows, stages, and water temperatures. Objectives should be specified for each of these locations. Comparisons among scenarios and effects of factor range should be shown between actual (historical), no-action, and alternative scenarios/examples to show benefits/effects of differing criteria/objectives. The decision process for selecting preferred scenarios should be documented. The effects of scenarios on benefits/effects of beneficial uses and target natural resources should be compared. Differences among and within factor criteria are often insignificant – greater ranges of important factors should have been considered.
“Alternative 3 prioritizes release of water for Delta outflow and reduces diversions to store water in Shasta Reservoir, which would generally decrease temperature-dependent mortality and improve juvenile Chinook salmon survival during migration down the Sacramento River. Delta inflow would generally increase and operations at the Delta fish collection facilities would generally decrease loss.”
Comment: There are many types of diversions if changed would have different responses in terms of Shasta and other system reservoir storage. Changes in demands on Shasta storage is a complex factor with widely varying effects on storage and the environment. Also, demands can be met in different ways. This is a complex process requiring a high degree of complex analyses and interpretation. Furthermore, Delta outflow is controlled by many factors involving different infrastructure. Criteria for outflow can be met in many different ways, some involving Shasta storage while some do not. Loss of fish in the Delta is also a complex process with many factors involved.
“Real-time management under Alternative 4 aims to store more water in Shasta Reservoir to decrease temperature-dependent mortality during egg incubation. Increased fall flows due to real-time storage management would result in higher releases that would improve juvenile Chinook salmon survival during migration down the Sacramento River.
Comment: There are many ways to store more water in Shasta Reservoir and many more to alter the volume and need for the cold-water pool supply. How the multi-factor management would be accomplished is beyond comprehension – for example how would the choice among factors employed and degree of employment would be made in real time has not been described. Criteria/objectives for temperatures in spawning reach can be met with the array of factors used in each alternative. The “best” way to meet criteria should be defined in each alternative. Letting criteria vary among and within alternatives is not the way to define or evaluate alternatives.
Spring-run Chinook Salmon
“Under the No Action Alternative, Reclamation operates the Temperature Control Device (TCD) on Shasta Reservoir to manage water temperatures on the Sacramento River downstream of Keswick Reservoir to achieve fisheries objectives, including objectives for winter-run Chinook salmon, and suitable temperatures for spring-run Chinook salmon. Storage of water in Shasta Reservoir during the winter and spring reduces instream flows during the juvenile spring-run Chinook salmon migration period. Spring pulse flows help spring-run Chinook salmon juvenile outmigration, including spring-run Chinook salmon from non-project streams.
Comment: These factors are among the many affecting spring run salmon. All alternatives address the effects or needs of the salmon. An infrastructure alternative should include upgrades/maintenance of the TCD to fix/improve its effectiveness. Winter pulse flows also improve the emigration of fry to the lower river floodplains and Bay/Delta nurseries. Winter and spring pulse and base flows (river and Delta inflow/outflow) would benefit emigration of fry and subyearlings, respectively. Delta exports should be restricted during pulse flows. Winter-Spring flows are important for spring run migrants. Spring, summer, and fall conditions (flows and temperatures) are important in spring and winter run spawning reaches.
Delta Smelt
“Alternative 3 may result in minor increases and minor decreases in suitable habitat depending on water year type and the application of a temperature threshold and would likely have minor beneficial to minor adverse impacts on juvenile Delta smelt summer and fall habitat. Under Alternative 3, depending on the water year type, there would be a substantially higher population growth rate when compared with the No Action Alternative.”
Comment: None of the alternatives addresses recovery of Delta smelt from its present state of virtual extinction. A specific alternative should address this need: maintaining outflow to allow the LSZ to remain in Suisun Bay year-round and for water temperatures to be less than 72oF in the LSZ year-round. Given their one-year life cycle, these conditions are necessary at a minimum in all water year types.
Green Sturgeon
“Alternative 2 prioritizes storage of water in Shasta Reservoir for water temperature management during multiple years of drought and would reduce deliveries for CVP water service and repayment contracts and Sacramento River Settlement Contractors under specific drought conditions to increase storage in Shasta Reservoir. This increased storage would result in higher fall and winter releases in non-drought conditions. Alternative 2 relative to the No Action Alternative is expected to have negligible impacts and possible beneficial impacts on spawning habitat, minor adverse impacts on rearing and emigration, and beneficial impacts and adverse impacts on upstream migration and holding habitats dependent upon location, month, and/or water year type due to differences in flow. Alternative 2 relative to the No Action Alternative is expected to have beneficial impacts and minor adverse impacts on spawning and egg incubation, beneficial and adverse impacts on rearing and emigration, and negligible and adverse impacts on upstream migration and holding dependent upon location, month, and water year type due to differences in water temperature. Alternative 2 is expected to have negligible impacts on the loss of juveniles at facilities.”
Comment: None of the alternatives addresses recovery of green sturgeon from its present state of near extinction. A specific alternative should address this need: maintaining outflow and water temperatures in the lower Sacramento River from spring through fall in wetter years – to allow the lower Sacramento River to sustain early spring water temperatures at 60F, late spring water temperatures at 65F, and summer-fall water temperatures at 68F.
Fall-run Chinook Salmon
“Adult fall-run Chinook salmon use the Sacramento River as a migration corridor and as spawning grounds between September and June. Release reductions from Shasta Reservoir early in the fall under the No Action Alternative may adversely impact the fall-run Chinook salmon population from low flows and elevated water temperatures leading to unsuccessful outmigration and redd dewatering.”
Comment: None of the alternatives address recovery of the fall-run salmon from its present state of near extinction in the wild. A specific alternative should address this need: maintaining outflow and water temperatures in the lower Sacramento River from spring through fall in wetter years – to allow the upper Sacramento River to sustain summer-fall water temperatures below 56F, late spring water temperatures at 65F, and summer-fall water temperatures at 68F. Fall X2 and Rio Vista flows are prescribed to attract fall run from the Bay to and through the Delta and lower rivers to the spawning rivers in the Sacramento and San Joaquin valleys.
Conclusions
The FEIS indicates that the listed species would continue to be adversely affected by the project, regardless of the alternative operations adopted. In 2024, DWR and USBR obtained non-jeopardy opinions from NOAA-NMFS, USFWS, and CDFW, similar to those issued in 2019. These resource agencies are required to issue opinions regarding the future of the listed species under continued operations of the water projects. Reasonable and prudent alternatives to the proposed operations and infrastructure needs were not mandated, so these issues must now be addressed by the courts following lawsuits.
Tom Cannon is an fisheries population ecologist and biostatistician and has been involved in California fishery issues for more than 40 years. Over that period, Cannon has been a consultant to the California Department of Fish and Wildlife, U.S. Bureau of Reclamation, National Marine Fisheries Service, US Fish and Wildlife Service, US Army Corps of Engineers, US Forest Service, State Water Contractors, Metropolitan Water District, CalFed Bay-Delta Program, State Water Resources Control Board, PG&E, California Striped Bass Association, California Water Information Network (C-WIN), Fisheries Foundation of California, Cal Trout, Karuk Tribe, California Sportfishing Protection Alliance, and NCGASA.
*Note: NCGASA is providing a place for more information on salmon, but all of Cannon’s recommendations do not necessarily represent the views of our organization. Salmon management is a complicated issue and NCGASA strives to provide all the information that is presented to share with our membership. We hope to educate everyone with additional data and recommendations so our members can get a full picture of the decline of our fisheries.
