2012Page 2April 25, 2012We have read with interest the March 22 letter from the Golden Gate SalmonAssociation (GGSA) on the CVPIA workplan and we generally agree with itscriticisms. Specifically, we support the conclusions in the first full paragraph onpage 2 of the GGSA letter that states in part
the 2012 (CVPIA) Restoration work plans that have been prepared by USFWS and USBR are not really plans. They aresimply a collection of hundreds of projects that have been proposed by field officesof the two agencies. Many of these projects are well conceived by capable anddedicated staffs and will provide some benefits to salmon at some point. What ismissing is management oversight to see that the plans that are proposed andaccepted are focused on the reasons the salmon runs have declined and are focusedon the best investments to begin the early rebuilding process.
” They go on to state
Many of the projects take place in the tributaries but there is no analysis made of whether or not additional enhancements in a tributary will in fact produceadditional smolts to the ocean at an early date and adults to return three years later.On the San Joaquin side, smolt losses in the South Delta are near 100%. Hundreds of thousands of additional smolts would have to be produced in the tributaries to haveany true net impact on an increase in San Joaquin populations. The plan ignores thiskind of analysis in its San Joaquin expenditures. The same kinds of problems exist on the Sacramento side. In some instances, up to 90% of the smolts perish on their
way down the river…
How can the CVPIA or the aggressive San Joaquin River Restoration Programpossibly improve salmon abundance and thus succeed if survival in the lower SanJoaquin River and in the South Delta is nearly zero? As summarized by the SWRCBin their March 2012 science review of the San Joaquin River (see page 3- 39) thisdrop in survival is a recent event. They noted that Independent Science Review of the Vernalis Adaptive Management Program (VAMP) data found that
survivalestimates from Mossdale or Dos Reis to Jersey Point were just greater than 1% in2003 and 2004 and the estimate was only about 12% in the very high flow year of 2006. This compares to survival estimates that ranged between about 30% and80% in the years 1995 and 1997 to 2000.
” The likely
cause for this decrease insurvival is the marked increase in aquatic weeds that provide better habitat forinvasive predatory fish like largemouth bass and black bass. These predatory fishfeed on young salmon and they are now so numerous that catch and releasetournaments are held regularly.
The recent study entitled “Individual
-level andPopulation-level Historical Prey on Demand of San Francisco Estuary Striped Bass
Using a Bioenergetics Model” seems to support the notion that som
e of the non-native predators are an extensive source of mortality and yet, the fish agencies arenot taking any action to rectify this problem.A much more holistic approach to salmon protection, which includes all life stagesand includes ocean conditions and harvest, is needed than that currently providedby the state and federal fishery agencies. Considerable work has been conducted inupstream areas to enhance fish passage, including the construction of state of the art fish screens. Without a holistic approach, these efforts could be squandered bypredation in the Bay-Delta or other stressors that adversely affect fish during their