In a significant development for California’s water management, state and federal agencies have announced a modification to the Fall X2 action for 2024. This decision comes after months of debate and appeals from various stakeholders, including water contractors, environmental groups and fishing organizations.
The Fall X2 action, part of the Summer Fall Habitat Action, is designed to benefit the endangered Delta smelt by increasing outflow from the Sacramento-San Joaquin Delta during September and October in wetter years. However, recent scientific studies have cast doubt on its effectiveness, leading to calls for its suspension.
In response to these concerns and after assessing the latest scientific data, California Department of Water Resources and U.S. Bureau of Reclamation, in coordination with state and federal fisheries agencies, have decided to implement a modified version of the Fall X2 action for 2024.
The decision represents a compromise between competing interests. Water agencies and agricultural stakeholders had requested a full suspension of the Fall X2 action for 2024, citing recent studies showing little to no benefit for Delta smelt populations.
Four quantitative models were used to evaluate alternative management actions, one from the Coalition for a Sustainable Delta and two models contributed by USFWS, none of which demonstrated material benefits to delta smelt from the Fall X2 action, said the Coalition’s William Phillimore in their Oct. 25, 2024 newsletter. “That sequence of activities led to the suspension of the management action for October 2024, after it had been in effect for just one month. The water savings to the (State and federal CVP) Projects are likely to be well in excess of 100,000 acre-feet.”
In a joint letter to Governor Gavin Newsom and Interior Secretary Deb Haaland by the Water Blueprint for the San Joaquin Valley and Southern California Water Coalition, Blueprint chairman Eddie Ocampo said, “Recent evaluations have shown the Fall X2 Action, aimed at increasing Delta outflow in the fall, has not only failed to benefit the delta smelt but has also imposed unnecessary hardships on the agricultural industry, local communities and southern California businesses and residents by significantly reducing water availability. The action, which cost the Projects an estimated 734,000 acre-feet of water in 2023, valued at $557 million on the open market, underscores the need for a reevaluation of its efficacy and impact.
Charley Wilson, executive director of Southern California Water Coalition and co-signer of the letter, commented on the broader implications of the decision. “The ongoing implementation of the Fall X2 Action based on outdated scientific data simply does not make sense, particularly given its detrimental impacts to the economic and environmental wellbeing of the people of the San Joaquin Valley and Southern California. It is critical that water project operations are governed by an adaptive management approach that reflects current scientific understanding and minimizes unnecessary impacts to our communities.”
The controversy surrounding the Fall X2 action underscores the complex challenges facing California’s water management. As the state grapples with ongoing drought conditions, climate change and the needs of a growing population, finding a balance between environmental protection and water supply reliability remains a critical challenge. However, when science shows regulatory actions are ineffective, State and federal agencies must incorporate adaptive management to prevent wasting limited water resources on efforts that are shown to provide no environmental benefits.
Environmental groups have expressed concern about the potential impact on Delta smelt populations. Gary Bobker, senior policy director at Friends of the River, warned, “At this time next year, we may be looking at the extinction of a fish species that was once incredibly abundant when the Bay-Delta Estuary was healthy.”
Yet under the 2008 Delta smelt biological opinion that was based on restricting water supplies to farms and urban communities in favor of higher flows through the Delta, smelt numbers continued to decline to even lower levels, an indication that blindly following outdated policies wastes public resources without a commensurate benefit for the intended species, a failure on both accounts.
The modification of the Fall X2 action for 2024 marks the second consecutive year in which wet-year concessions for fish have been waived or altered. This has raised concerns among environmental advocates about the long-term implications for Delta ecosystems and endangered species.
However, water agencies view the decision as a step toward more adaptive management. Jennifer Pierre, general manager of State Water Contractors, praised the decision, saying, “This adjustment ensures the same protections for fish and water quality as those contemplated in the Incidental Take Permit (ITP) and 2019 Biological Opinion while smartly protecting water supplies.”
The decision to modify the Fall X2 action comes at a time when California is facing significant water management challenges. During the first three months of 2024, an astonishing 10.3 million acre-feet of water flowed through the Delta and out to the ocean. This highlights the need for improved infrastructure to capture and store excess water during wet years for use during dry periods.
The modification of the Fall X2 action represents a significant shift in California’s water management strategy. While it has been met with mixed reactions, it underscores the ongoing need for adaptive management based on the latest scientific data.
“California can ill-afford the ongoing mismanagement of the Delta resulting in ongoing deleterious repercussions for the California economy while at the same time failing to improve the numbers of at-risk fish species,” Phillimore said. “Until recently, we have seen the courts defer to the regulatory agencies; we hope that is now changing. But we still need to make certain the best available science is being utilized, which involves both time and a great deal of hard work.”
