The National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (USFWS) have released new “red flag” documents in response to the administrative draft of the Bay Delta Conservation Plan (BDCP). These documents identify issues with BDCP that would make the fisheries agencies unwilling to issue the necessary “take” permits for a habitat conservation plan under the Endangered Species Act.
For example, the NMFS response identifies a potential for increased salmon egg morality upstream resulting from release operations at Keswisk Reservoir at Shasta required by BDCP. Juvenile salmon in the Sacramento River would also be at risk under some scenarios.
The likely extinction of winter and spring run Chinook salmon is an inevitable consequence of shifting water exports to the Spring months, which is what BDCP wants to do. Reducing flows in the upper Sacramento River in Summer and Fall of dry years creates problems that are not going to go away.
As for habitat in the Delta offsetting the loss of fresh water for fish, the USFWS called the prospects for fish such as Delta smelt and longfin smelt “uncertain.”
Since the point of a habitat conservation plan is to make things better for threatened species, not worse, you’d think a problem like this would be a game-changer. And it would, if the game weren’t rigged. It would be just like BDCP planners to tweak the models to eliminate or disguise the obvious problems that keep arising when they look for ways to get lots of export water without harming fish.