ment Plans at the Nimbus (American River) and Trinity River hatcheries to benefit steelhead and fall-run Chinook salmon.
Rather than review every action and every detail, the committee comments on the broader concepts at issue and general categories of actions. Three important goals are to consider how well the RPAs are based on available scientific information; whether there are any potential RPAs not adopted that would have lesser impacts to other water uses as compared to those adopted in the biological opinions, and would provide equal or greater protection for the listed fishes; and whether there are provisions in the FWS and NMFS biological opinions to resolve potential incompatibilities between them. In addition we assess the integration of the RPAs within and across species and across all actions.
Addressing these goals requires explicitly recognizing the fundamental differences in the main conflicting arguments. There is concern, on one hand, that the increasing diversions of water from the delta over a period of many decades and the alteration of the seasonal flow regime have contributed to direct effects on populations of native species through mortality at the pumps, changes in habitat quality, and changes in water quality; and to indirect, long-term effects from alterations of food webs, biological communities, and delta-wide habitat changes. The RPAs propose that their collective effects will offset the impacts of the proposed operations of the SVP and the CWP by manipulating river flows and diversions, along with other actions. An alternative argument is that the effects of water diversions on the listed fishes are marginal. It is argued that the changes imposed by the RPAs would result, therefore, only in marginal benefits to the species, especially now that the delta environment and its biota have been altered (to a new ecological baseline) by multiple stressors. Those stressors obviously include water exports, but this argument suggests a smaller role for water exports in causing the fish declines and hence a smaller role for managing the exports to reduce or halt those declines. However, even with the copious amounts of data available, it is difficult to draw conclusions about what variable or variables are most important among the pervasive, irregular, multivariate changes in the system that have occurred over the past century.
The committee’s charge was to provide a scientific evaluation, not a legal one, and that is what is presented below. Nothing in this report should be interpreted as a legal judgment as to whether the agencies have met their legal requirements under the ESA. The committee’s report is intended to provide a scientific evaluation of agency actions, to help refine them, and to help the general attempt to better understand the dynamics of the delta ecosystem, including the listed fishes.