Key Messages

• A substantial data-collection and analytical effort by multiple agencies, tribes, and other parties has not shown a clear connection between water level in Upper Klamath Lake and conditions that are adverse to the welfare of the suckers.
• All components of the biological opinion issued by the USFWS on the endangered suckers have substantial scientific support except for the recommendations concerning minimum water levels for Upper Klamath Lake.
• Extremes of chemical conditions considered threatening to the welfare of the fish have not coincided with years of low water level, and the highest recorded recruitment of new individuals into the adult populations occurred through reproduction in a year of low water level.
• The USBR proposals also are unjustified, because they would leave open the possibility that water levels in Upper Klamath Lake and minimum flows in the Klamath River main stem could be lower than those occurring over the past 10 years for specific kinds of climatic conditions.
• There is no substantial scientific foundation at this time for changing the operation of the Klamath Project to maintain higher water levels in Upper Klamath Lake for the endangered sucker populations or higher minimum flows in the Klamath River main stem for the threatened coho population.