Reasonableness from NRDC?


Author:  Damien M. Schiff

Last Friday, Doug Obegi of the Natural Resources Defense Council (NRDC) had this post on NRDC's Switchboard blog giving the environmental group's take on the recently issued NAS-NRC report on the Delta pumps and their effects on the Delta smelt and other ESA-protected species in the Delta (I blogged about the report here).

What I find surprising, but also welcome, is the remarkably measured tone that NRDC takes.  After all, over these last several years one would have thought that NRDC viewed the water projects as the great environmental ogre of California, causing ecological destruction throughout the Delta region.  But in Friday's post, NRDC instead contends that, although water exports are a problem, they're likely not the only cause, and that a "holistic" approach to reversing the Delta's declining ecosystem is essential.

NRDC has never argued that water exports are the sole cause of the species decline.  Indeed, we’ve often argued that measures to address other stressors, like water pollution, should be implemented to complement – but not substitute for – adequate flows in and through the Delta, and effective regulations on exports that harm and kill millions of fish.

At the same time, NRDC is quick to point out that the Report disclaims making any sort of legal judgment.  True enough, but it's hard to maintain (as NRDC undoubtedly would) that, in light of the Report's analysis, the particular water cutback regime prescribed by the smelt and salmon biological opinions is scientifically justified.  After all, the Report specifically questions the values selected for optimizing habitat based on X2 (which is, basically, a salinity mixing zone that is considered a proxy for smelt habitat boundaries), as well as the environmental triggers used for implementing the pumping restrictions.