Ms. Denise ReedJune 27, 2011Page 3author of the seminal work, Burnham, K. P. and D. R. Anderson,
Model Selection and Multimodel Inference: A Practical Information-Theoretical Approach
(2d Ed. 2002). Springer-Verlag, reviewed the Feyrer work that the Federal Agencies rely upon in the Draft ManagementPlan, and concluded:Based on my review of the available data analyses, the analyses of smelt abiotic habitat inFeyrer (2007), Feyrer (2008) and Feyrer (2010) are fundamentally flawed, and cannotproperly be used to estimate the effect of changes in X2 management on smelt habitat
volume, which was the intended purpose. However, even if Mr. Feyrer’s analyses could
be used to predict changes in the amount of available abiotic habitat for smelt, there is nostatistical evidence that changes in X2 have any effect on smelt abundance. More recentstudies, such as Kimmerer (2009) and Maunder and Deriso (2011) show that X2 is notrelevant to smelt abundance, and that other factors, such as food supply, are most likely
driving changes in the smelt’s population level.
Declaration of Dr. Kenneth P. Burnham in Support of Plaintiffs
Motion for InjunctiveRelief, ¶ 39.The Draft Adaptive
Management Plan’s science summary also does not disclose the Maunder
and Deriso (2011) article (cited by Burnham), that is in press at the Canadian Journal of Fisheriesand Aquatic Sciences. That article describes the state-space multi-stage life cycle model fordelta smelt developed by Drs Maunder and Deriso, which analyzes the impact on abundance of various environmental factors, including the location of Fall X2. (See attached Declaration of Dr.
Richard B. Deriso in Support of Plaintiffs’ Motion for In
junctive Relief, and Ex. A thereto).Using this peer-
reviewed life cycle model, Dr. Deriso concludes that: “there is no statisticalsupport for the proposition that the location of X2 drives changes in smelt abundance.” (Id., ¶
Dr. Charles Hanson recently analyzed delta smelt and zooplankton abundance data collected in
various surveys to test the hypothesis that Fall X2 location will increase the delta smelt’sdistribution, improve its survival, enhance the species’ reproduction, and increase the a
vailabilityof delta smelt food resources. After conducting that analysis, Dr. Hanson concluded:[D]ata from the Fall Midwater Trawl (FMWT) survey, the 20 mm survey, and SummerTownet (STN) survey fail to show a correlation between the location of Fall X2 and deltasmelt distribution, delta smelt survival, delta smelt reproduction or the availability of delta smelt food sources. To the contrary, the best available data show that delta smelt
The Plaintiffs in the Consolidated Delta Smelt Cases are San Luis & Delta-Mendota Water Authority, State Water Contractors,Coalition for a Sustainable Delta, Metropolitan Water District of Southern California, Stewart Jasper Orchards, and Family FarmAlliance.
The Maunder and Deriso life cycle modeling manuscript was made available to the Federal Agencies well before the DraftAdaptive Management Plan materials were submitted to the peer review panel. Drs. Maunder and Deriso presented their modelto the federal agency biologists in August 2010 during the Bay Delta Conservation Plan
(“BDCP”) Theme Team meetings; to thelarger scientific community at the Estuarine Ecology Team (“EET”) meeting in November 2010; and to the state and federalagency biologists at a Department of Water Resources (“DWR”) hosted event for the BDCP in April 2