Biological Opinions - Bureau of Reclamation

proposed changes to the vegetation and pest management activities as currently practiced. On
February 8, 2013, Reclamation clarified via email that the information on pesticide use as noted
in Section 4.3.3.5 was included in the BA to respond to USFWS's request to provide a complete
Baseline of Project operation, and Reclamation is not requesting consultation on pesticide use as
part of their request for formal consultation.
Additionally, as part of their proposed action in the final BA, Reclamation included a statement
that in dry years when the Project Supply is limited, it may not be possible to maintain the
proposed minimum Tule Lake Sump 1A elevations because of decreased runoff and drainage
from Project land. Reclamation stated in the first paragraph on page 4-38 of the BA
(Reclamation 2012) that this situation is outside of their control, and Tule Lake elevations may
decline to levels less than the proposed minimums and sucker relocation may be necessary.
However, after finalizing the BA, Reclamation conducted further analysis on the likelihood of
not meeting minimum elevations in Tule Lake. On April 9, 2013, Reclamation provided this
analysis to the USFWS via email, concluding that if the Klamath Project received irrigation
deliveries, the likelihood of not maintaining minimum surface elevation in Tule Lake Sump 1A
was very rare. Therefore, Reclamation requested via email on April 25, 2013, that the paragraph
on page 4-38 and associated Appendix 4B be removed from the proposed action and not
analyzed.
On May3, 2013, USFWS received Reclamation’s letter, clarifying and updating the proposed
action with additional Conservation Measures. These measures included providing an additional
$500,000 in FY2013 to support captive propagation; capturing and transporting listed suckers in
Lake Ewauna and releasing them in UKL; and investigating the reduction of flows at Link River
Dam to determine if there are feasible management options to minimize effects of entrainment at
Link River Dam on larvae and juvenile listed suckers at key times when they are present at the
south end of UKL.
On May 7, 2013, Reclamation and NMFS met in Medford, OR to discuss several issues NMFS
needed to be addressed prior to issuance of the anticipated, joint BiOps on Reclamation’s
proposed action. The issues involved the minimum flows during the spring, magnitude and
frequency of high flow events, and the restoration funding.
On May 10, 2013, NMFS received Reclamation’s May 9, 2013, letter documenting the mutual
agreement between NMFS and Reclamation to extend the consultation on the endangered
southern resident killer whale DPS (Orcinus orca) for one year.
On May 29, 2013, NMFS received Reclamation’s letter revising the proposed action to further
minimize adverse effects of the Project on the SONCC coho salmon ESU and its critical habitat.
The revised proposed action consists of: (1) increasing the minimum daily IGD flow targets for
April, May, and June; (2) clarifying flexibility in operations regarding meeting minimum daily
average flows downstream of IGD; (3) clarifying that the proposed action daily modeled IGD
flows during high flow events will be achieved during real-time operations; (4) increasing annual
fisheries habitat restoration funding to $500,000; and (5) using adaptive management for
minimizing fish disease.
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