Of Smelts and Smolts: A Cursory Internet Review of the NOAA’s Biologic Opinion Limiting Water Deliveries To The San Joaquin Valley
References reviewed in completing this overview include, but were not limited to:
1) US Dept of Interior memorandum Fish and Wildlife Service
2) Draft ESA, National Marine Fisheries Service 12-11-08
3) NOAA’s Peer Review and associated supporting documents
4) NOAA’s RPA Overview
5) Dr. Peter Moyle’s article on historical through present Chinook salmon distribution
6) Judge Oliver Wanger’s ruling 12-15-10
7) NOAA’s Recovery Plan for the Southern Resident Killer Whale
This review is being generated in the hopes that an alternative perspective will be helpful to anyone interested in determining how the U.S. Department of the Interior can place the existence of a small forage fish over the livelihood of thousands of people, and block water delivery to 500-750K acres of the most arable farmland in the world.
While attempting to “wade through” these voluminous scientific papers and opinions, one thing became abundantly clear. While the biologic needs of Chinook salmon are well known, well documented and relatively simple, the science behind the demise of Oncorhynchus tshawytscha in central California waterways, as it is elsewhere, is convoluted, complex and subject to misinterpretation. The definition of the scientific method is: "a method of procedure that has characterized natural science since the 17th century, consisting in systematic observation, measurement, and experiment, and the formulation, testing, and modification of hypotheses." Science can be made to be as difficult, or as simple as one wants, but while preparing research papers to be published, or used for legal review, one must not be inclined to work backwards from a conclusion and thus bias the study by excluding data and ignoring other researchers’ work that doesn’t support the previously ascertained conclusion. It is my opinion that several important studies were omitted and facts were ignored when the BiOp was written, whether purposely or not, that are crucial to consider in any review of this important subject. Further, the far reaching BiOp of the NOAA made many assumptions based on erroneous, and I believe refutable evidence.
It appears to this observer that data points and findings were “cherry picked” in order to substantiate a pre-formed conclusion linking the demise of the Delta smelt, to the severe decline in Chinook salmon population in central California and to the overall health of the Southern resident Orca pods, while ultimately blaming the SWP and CVP.
First, let’s examine the evidence about the Chinook salmon decline in the Sacramento-San Joaquin River system. I can think of no one fisheries biologist that has devoted as much time and energy into studying the central California Chinook salmon, than Dr. Peter Moyle at UC@Davis.
In reference #5 above, Moyle et al., reviewed historical literature while performing his own research in an attempt to determine the extent of present day spawning habitat in the entire Sacramento-San Joaquin River system. According to Reynolds et al, in a 1993 DFG publication cited in Dr. Moyle’s paper, 95% of the salmon’s spawning habitat has been either destroyed or made inaccessible. Dr. Moyle did not refute those numbers when he wrote: “Thus, the DFG’s most recent assessment that about 95% of the original spawning habitat has been lost is perhaps somewhat high but probably roughly accurate.” The question of whether a wild population of any fish can sustain itself with only 5-10% of spawning beds being available, especially in an environment of increased predation, increased pollution, decreased forage for smolts, etc., has never been fully discussed in any of the studies or opinions I read.
Further, the situation in central California waterways in regards to salmon shortages does not appear to be a unique event. Indeed, the river systems to the north of the Delta are experiencing similar drastic declines in returning adult salmon. “Consider the following facts: in California, Oregon, Idaho, Washington, and southern British Columbia, many runs are reduced to less than 10% of their historical numbers; some have disappeared. Many salmon runs are dominated by hatchery-bred fish. Even for the Columbia River, once the mightiest salmon-producing river south of Canada, over 80% of the total run is now comprised of hatchery-bred fish.”
In regards to the Columbia River salmon population, there is certainly conjecture that lack of access to traditional spawning grounds is the root cause of the salmon population decline, with other factors contributing.
This could mirror what has occurred in California to the Sacramento-San Joaquin River salmon populations, which obviously cannot be traced to Delta smelt population/availability.
The entrainment of the Delta smelt, (along with salmon smolts), appears to be the crux of the federal governments’ argument against running the water pumps delivering water to the aqueduct. The fact that the NOAA included the Chinook salmon as being adversely effected by the decrease in the Delta smelt, (and thus, the Southern resident Killer Whale pods), is an extreme stretch of biologic food chain relationships that might make for tantalizing reading, but negates other salient research while attempting to simplify a fairly complex set of circumstances. Ammonia discharge from the Sacramento Regional Wastewater Treatment Plant has been implicated in converting the Delta from a nitrate to an ammonia dominated waterway.
Ammonia and pyrethoid insecticides, largely from residential usage, have been connected to toxicity in plankton and copepod populations.
Lethal effects of pyrethoids are listed, beginning on page 19 of the following research paper.
Urban runoff, (i.e. non-agricultural sources), of pyrethoids has been demonstrated to be the primary source of these contaminants.
Dr. James Hobbs, professor at UC@Davis, has connected loss of zooplankton to the demise of the Delta smelt populations, as he describes at 5:10 in his presentation on March 15, 2010.
Further, Dr. Hobbs’ research indicated that the times of greatest Delta smelt populations, coincide with greater than normal fresh water discharge, and prior population crashes conversely coincide with drought years, as he describes, beginning at 6:22 into his presentation, listed above. While ammonia and pyrethoid discharge into the Sacramento River was probably not contributory to the prior Delta smelt population crashes as noted by Dr. Hobbs’ graph in the mid 1970’s and early 1990’s, one could easily predict that drought conditions combined with increased pollution from a much expanded population since those periods, would have dire consequences.
In Judge Wanger’s 2010 ruling, (ref #6 above, page 61, line 11), he alludes to errors made by the defendants in their inconsistency in reporting smelt salvage numbers vs. population size, when he wrote: “This was arbitrary, capricious, and represents a failure to utilize the best available science in light of universal recognition that salvage data must be normalized. This significant error must be corrected on remand”.
Further, Judge Wanger correctly recognized the BiOp defendants own conclusions that: “when relating salvage data to population-level significance [ ] the total number salvaged at the facilities does not necessarily indicate a negative impact upon the overall delta smelt population.”
Additionally, although the FWS suggests that in constructing the BiOp, the best possible science available was utilized to formulate this opinion, studies that linked ammonia pollution to the demise of the Delta smelt and the food source they utilize were ignored. Dugdale’s findings were available, beginning in 2006:
Wilkerson, F.P. R.C. Dugdale, V.E. Hogue, and A. Marchi. Phytoplankton blooms and nitrogen
productivity in the San Francisco Bay. Estuaries and Coasts 29: 401-416 (2006).
Dugdale, R.C., F.P. Wilkerson, V.E. Hogue, and A. March. 2007. The role of ammonium and nitrate in spring bloom development in San Francisco Bay. Estuar. Coast. Shelf Sci., 73: 17-29.
A more recent study, by Dr. Patricia Glibert from Univ. of Maryland, is fairly conclusive: “The overwhelming conclusion here is the fact that relationships between nutrients and fish are stronger than those of flow and fish…”. Although this statement contradicts some of the previous studies' findings at first read, she may very well have a point about the need for further study on the impact of man's activities on food-chain dynamics in the rivers where these fish live.
Even more striking is her statement beginning on page 25, line 611: “Water restrictions are thought to be required to reduce further loss of these fish by entrainment in export pumps. However, management strategies to date have not reversed fish declines because they have not addressed the ultimate cause of the change at the base of the food web and the complex role of nutrient form and quantity”.
Page 25, line 620: “The present study supports the premise that reduction of the NH4 + effluent into the Bay Delta is essential to restoring historic pelagic fish populations and that until such reductions occur, other measures, including regulation of water pumping or manipulations of salinity, as has been the current strategy, will likely show little beneficial effect”.
Dr. Glibert’s credentials are impeccable, and shortly after releasing this study was asked to step down from her position as committee member on the National Research Council.
Was this a true “conflict of interest” removal of an esteemed colleague on the NRC, or payback from Ken Salazar’s office? Salazar is not only Secretary of the Interior, but a defendant in the lawsuit currently being heard in regards to this matter.
Finally, I would like to address the National Marine Fisheries Service’s lengthy, detailed, but in my opinion, flawed assessment of the Southern Resident Orca pods population collapse as written in reference #7 listed above.
In this 250+ page paper, the NMFS does a very good job of describing the Orca natural history, including details of species range, genetics, morphology, diet, life cycles and behavior. The NMFS paper attempts to describe the possibility of sub-species existence, but acknowledges that more study is required. The article describes the Northern and Southern resident Orca populations dietary preferences, (II-20), although the data is recent. While definitive data on dietary preferences is difficult to obtain on any aquatic predator, the Orca is even more so, due to the limited numbers of individuals and difficulty obtaining fresh specimens. Even Orca fecal samples are not easily obtained. Most studies on the Resident Orca diet are recent publications because historical data is almost non-existent. Both the Northern and Southern resident orca populations, by all recent accounts, “prefer” salmon as their main dietary source. Considering the once prodigious salmon populations that existed along the Northeast Pacific coastline from Alaska to Central California, it is not difficult to imagine that salmon would make up a great percentage of the diet of any Orca pod residing in these waters.
However, Orcas in the Pacific Northeast waters are also known as marine mammal predators, and have historically hunted baleen whales in well coordinated attacks on Blue and Grey whales. A recent article describes a very plausible explanation for the possible dietary shift of Orcas from large marine mammals to salmon.
Considering that Orcas have incredibly large teeth, 40-56 conical teeth that are used for tearing and slashing, it is difficult to imagine that these types of formidable weapons would evolve if salmon were the primary hunted species. The article above describes the teeth as analogous to T. rex’s dentition, and rightly so.
The Orca, being the very highest predator in the sea, doesn’t need these teeth for self-defense against any other species, or against each other. The Orca has no natural enemies and is not aggressive towards other members of its own species. Those teeth have evolved and are designed to hunt large game species, not fish. It is highly plausible that man’s whaling activities has caused a shift of resident Orcas away from marine mammals to salmon to fulfill their prodigious dietary requirements.
Another factor that needs to be considered in the demise of the Orca pod populations in Puget Sound is again a result of man’s activities. Pollution of the waterways from lumber and pulp mills has increased PCB contamination to exceedingly high levels. The following article indicates that salmon can concentrate these toxins to 159,000 times of that from the surrounding water.
The shift from a baleen whale diet to salmon, which concentrate PCB’s at an exceedingly high rate, could be the reason for the demise of the Southern resident Orca pods.
The following study from the NOAA themselves in 2000, indicates that even transient Orcas residing in the waters of the northeast Pacific ocean have high PCB levels that, although may be sub-toxic, are potentially endocrine disrupting and immunotoxic.
http://www.nwfsc.noaa.gov/research/divisions/cbd/marine_mammal/kwworkshops/preypubs/pcbpacifickw.pdf
Although the NOAA reference #7 above, discusses the organochloride contamination levels and toxicity extensively, it offers no clear cut solution in the difficult task of eliminating these persistent chemicals from the waters inhabited by the three pods of resident orcas. It appears to this reader that it’s simply easier, and far cheaper to turn off the federal pumps of the CWP in the delta of California, than it is to clean up the mess in Puget Sound and correct the demise of the salmon in the Columbia River system which may be the real culprits. And it’s much easier and cheaper to blame the farmers in central California for the demise of a three inch fish, than to retrofit the Sacramento Waste Treatment Facility to remove NH4+ from the human sewage discharge.
Something certainly smells fishy with the entire NOAA “Delta smelt” BiOp, and it’s not the smell of these fish being sucked through the federal pumps that I’m detecting. Cherry picked research, exclusion of vital and current contrarian studies, bad data presentation, inclusion of the Southern Resident pods of Orcas and suspect treatment of scientists with alternative views…it all adds up to a biologic opinion that was generated to support a conclusion, not to test a hypothesis.
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