In a tersely worded letter to Reclamation, Director of the Department of Fish and Wildlife Chuck Bonham urges Reclamation to implement the action as written in the 2008 biological opinion.
He writes, “While Reclamation and the USFWS may wish to make a permanent, long-term change to this measure through your reinitiated consultation, right now, the 2008 BiOp and this measure control, no adaptive management has been completed consistent with those rules, and the USFWS specifies that there will be impacts from this change to an imperiled species.”
Director Bonham’s letter goes on to point out that there has been insufficient analysis of the impacts of making this change, and the analysis that has been done shows a reduction in habitat suitability of the Delta smelt as a result. He also notes that the Department of Water Resources is not in support of the change.
“Implementation of the CVP operations as described in Reclamation’s reinitiation request to USFWS is based on incomplete and inaccurate information and would undermine necessary species protections even as Delta smelt decline to record-low abundance,” he writes. “I urge you to shift course for CVP operations in 2019 and adhere to the monthly average of X2 of 74 during September and October as required.”