Biological Opinions - Bureau of Reclamation

the confluence with Omogar Creek at approximately river mile (RM) 10.5 from the mouth;
however, critical habitat does not include any tribal lands of the Yurok Tribe or the Resighini
Rancheria. Because the proposed action is not expected to adversely affect the physical,
chemical, and biological resources in the Klamath River estuary, NMFS concurs with
Reclamation that the proposed action may affect, but is not likely to adversely affect critical
habitat designated for the southern DPS of Pacific eulachon.
7 STATUS AND ENVIRONMENTAL BASELINE OF THE LOST RIVER SUCKER
AND THE SHORTNOSE SUCKER
In this section, we assess the range-wide condition of the SNS and the LRS (i.e., its status). We
describe factors, such as life history, distribution, population sizes and trends, and evidence of
resiliency and redundancy, which help determine the likelihood of both survival and recovery.
In doing so, we describe how vulnerable each affected species is to extinction. This information
will inform a population viability baseline against which the effects of the proposed action will
be measured. We also present the Environmental Baseline of the affected species in this section;
we focus on those environmental factors that have led to the species’ current status. It is
important to note that the action area encompasses the entire range of the LRS and the SNS and
their critical habitat (discussed in Section 9 below).
Endangered Species Act regulations define the environmental baseline as “…the past and present
impacts of all Federal, State, or private actions and other human activities in the action area, the
anticipated impacts of all proposed Federal projects in the action area that have already
undergone formal or early section 7 consultation, and the impact of State or private actions
which are contemporaneous with the consultation in process” (50 CFR 402.02). The
environmental baseline is an analysis of the factors that have, are, or will continue to affect listed
species in the action area, not merely a recitation of the actions that have occurred or are
occurring in the action area. The environmental baseline analysis will help us assess the effects
the proposed action will have on listed species.
In Section 7 consultations on continuing actions, such as Reclamation’s Klamath Project
operations, separating baseline effects from the anticipated effects of the proposed action can be
difficult. This is because operations of existing structures, such as dams and associated
infrastructure, are integrally related to the existence of the structures themselves, but effects of
the presence of the structures are not effects of the proposed action, and therefore are part of the
environmental baseline. For example, on the east side of the action area, Clear Lake and Gerber
Reservoir Dams block upstream sucker passage because they lack fish ladders. However,
because that effect would occur even if there was no proposed action, blocked fish passage is not
an effect of the action and instead is part of the environmental baseline.
For the Klamath Project, the non-operational effects of the infrastructure now in place, such as
the blocked passage mentioned above, are part of the environmental baseline, but the effects of
operating those structures to store, deliver, and drain water are effects of the proposed action.
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