HA HA HA HA HA! Suck it up you brown spot on the carpet.

This 440+ pages of lousy prose describe the crash of the delta smelt from the 1960’s to near present-day in crushing detail. They looked at everything from shifts in zooplankton to the overbite calm, however, they left out a major source of predation that changed dramatically over this time period: fish-eating birds.

As anyone who knows anything about data analysis knows, leaving out a relevant parameter in an analysis is an excellent method of creating an incorrect or truly fraudulent analysis. You can’t correctly describe a 3 Dimensional problem in 2 Dimensions (think conic sections <https://en.wikipedia.org/wiki/Conic_sections where you get all sorts of 2D results from one 3D object ).

In the 60's through the late 90's, the delta was awash in DDT and its relatives and this resulted in almost no fish-eating birds (bald eagles weren't the only fish-eating bird species to be impacted). DDT stays around in the ecology for decades so even after it was banned ( 70's except for the Forest Service's massive use), it would take decades for the impact to disappear.

The FWS did a correlation analysis between the flows and the delta smelt with R^2 down in 0.4 range after massaging the data with zero offsets and non-linear fitting equations and other statistical games. However, by leaving out the dramatic increase in the populations of birds like cormorants, which are a very effective consumer of mid-water fish a few inches long, their analysis are scientifically meaningless. It would take about 50 delta smelt per day to feed one cormorant and we now have power lines dripping with them drying their wings. Given that the number of delta smelt at the pumping plants are in the few thousands/yr range, one cormorant can eat as much delta smelt as a major pumping plants per year.

Just observe the graphs with the crash of the population and the flow rates from the biological opinion and the missing cormorant data from the Audubon annual survey (the fish and wildlife should have even better bird data somewhere in the bureaucracy). You know which one correlates with the delta smelt crash.

They do note that the delta smelt doesn’t do well when the water becomes cleaner (less turbidity) but just use that information to selectively eliminate data points from the pumping plant data, when low turbidity ( < 12 NTU ) resulted in no delta smelt.

It seems that they would do anything to avoid having threatened birds eating endangered or threatened fish. The same goes for most of the "biological opinions" on salmon that also exclude birds even when data show otherwise.

Whether "environmental experts" actually read the documents the regulations are based upon appears questionable. When someone claims to want Science, he had better know what he is talking about or he may get answers that have birds eating fish as the real problem and DDT creating an abnormally high delta smelt population being used as a baseline.