Biological Opinions - Bureau of Reclamation

progresses and EWA volumes are updated between March and June, the Manager and FASTA
Team will track distribution of EWA in conjunction with UKL elevations and Project Supply use
in accordance with the operational procedures described in Section 4.2.3.
Under certain circumstances, deviating from the EWA formulaic distribution may be desirable or
necessary. Although expected to be rare, there may be circumstances, such as high disease rates
or dangerously high water temperatures in the Klamath River below IGD, or flooding from rainon-snow
events causing emergency situations for UKL infrastructure, where it is desirable or
necessary to deviate from the formulaic EWA distribution approach. In addition, there may be
specific ecological objectives that water resource managers need to address that can only be
achieved by deviating from the EWA distribution methodology. Deviations are most likely to be
alterations in the magnitude or duration of flow to address urgent ecological concerns, such as
mitigating fish disease, die off, entrainment, dispersal, or migration. Water quality concerns or
other ecological issues that arise during spring/summer may also prompt deviation from the
formulaic EWA distribution system.
Any time a deviation from the formulaic approach is proposed, the process detailed in Section
4.3.4 (Implementing Environmental Water Account Management) of Reclamation’s BA will be
followed. Any recommended deviation from the EWA distribution methodology must be shown
to result in improved ecological conditions for listed species, and cannot cause an adverse effect
to listed species or critical habitat that was not considered by the USFWS and the NMFS for this
proposed action. There are many factors to be considered when developing EWA distribution
regimes that deviate from the formulaic approach. Reclamation is coordinating with
stakeholders to develop Flow Scheduling Guidelines that will provide guidance for
implementing EWA Management to optimize the ecological benefits to aquatic species.
Reclamation proposes to develop and adopt the Flow Scheduling Guidelines and formal structure
for EWA management in coordination with the NMFS, the USFWS, and appropriate
stakeholders within 1 year of implementing the proposed action.
Meanwhile, Reclamation proposes the following process for deviating from the formulaic
distribution of the EWA for the evaluation of near real-time data on disease risks to coho salmon.
The process will be included as a key objective in the Flow Scheduling Guidelines document for
consideration by the Flow Account Scheduling Technical Advisory (FASTA) Team, described in
Section 4.3.4 of Reclamation’s BA. In the event that disease risks are at or above threshold
levels and EWA volumes indicate surplus water is available, Reclamation will deviate from the
formulaic distribution of EWA and increase Link River releases to reduce actinospore
concentrations downstream of IGD.
Specifically, Reclamation will:
(1) Continue the ongoing water quality program collecting mainstem Klamath River
water samples of actinospore concentrations and laboratory analyses will continue
through the action period. Reclamation, in coordination with NMFS and disease
researchers, will evaluate the program efficiency and determine if there are opportunities
to accelerate the timeline to evaluate water quality samples such that Reclamation and
NMFS will receive as near as real-time results on actinospore concentration as feasible.
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