San Francisco Baykeeper, et al. v. U.S. Bureau of Reclamation, et al.

CourtDistrict Court, E.D. California
DecidedJuly 9, 2026
Docket2:26-cv-00671
StatusUnknown

This text of San Francisco Baykeeper, et al. v. U.S. Bureau of Reclamation, et al. (San Francisco Baykeeper, et al. v. U.S. Bureau of Reclamation, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
San Francisco Baykeeper, et al. v. U.S. Bureau of Reclamation, et al., (E.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 SAN FRANCISCO BAYKEEPER, et al., Case No. 2:26-cv-0671 JLT EPG

12 Plaintiffs, ORDER DENYING WITHOUT PREJUDICE REQUEST FOR TEMPORARY 13 RESTRAINING ORDER v. 14 (Doc. 47) U.S. BUREAU OF RECLAMATION, et 15 al.,

16 Defendants. 17 18 I. INTRODUCTION 19 Plaintiffs, a pair of environmental organizations interested in the health of California’s 20 San Francisco Bay, the Sacramento-San Joaquin Delta, and the species that reside in or transit 21 through the Bay-Delta watershed, bring this lawsuit against the U.S. Bureau of Reclamation 22 (Reclamation) and the National Marine Fisheries Service (NMFS), as well as various official 23 representatives of those agencies. (Doc. 46.) Reclamation operates the federal Central Valley 24 Project (CVP), “one of the largest water infrastructure and conveyance systems in the United 25 States.” (Id., ¶ 1.) 26 On June 24, 2026, Plaintiffs filed a motion for a temporary restraining order and 27 preliminary injunction concerning Reclamation’s planned operations for Shasta Dam and 28 Reservoir for the remainder of this summer and early fall. (Doc. 47.) In very general terms, 1 Plaintiffs contend that Reclamation’s planned operations do not comport with the requirements of 2 a 2024 Endangered Species Act biological opinion (“2024 BiOp”) applicable to the joint 3 operation of the CVP (of which Shasta Dam is one component) and California’s State Water 4 Project (SWP) (Collectively, the “Projects”). (See generally Doc. 47-1 at 21 (describing 5 Reclamation’s conduct as an “open violation”).) Plaintiffs request two forms of immediate relief 6 in the form of a TRO that: (1) requires Reclamation to reduce releases from Shasta and (2) directs 7 the U.S. Bureau of Reclamation to prepare an alternative plan for operation of Shasta through the 8 summer and early fall of this water year. 9 As explained in greater detail below, though Plaintiffs advance a colorable reading the 10 2024 BiOp’s requirements, Reclamation’s own reading is not obviously unreasonable. Because 11 no party presents arguments related to or articulates standards governing how the Court should 12 resolve a dispute about interpretation of the terms of the BiOp under remotely analogous 13 circumstances, the Court concludes that it cannot on this record find that Plaintiffs are likely to 14 succeed or that they have a “fair chance” at success on the merits sufficient to trigger the “serious 15 questions” injunctive relief standard. Thus, the TRO request is DENIED WITHOUT 16 PREJUDICE. 17 II. LEGAL FRAMEWORK 18 A. The Endangered Species Act 19 “Under the ESA, the Secretary of the Interior and the Secretary of Commerce are charged 20 with identifying threatened and endangered species and designating critical habitats for those 21 species.” Nat. Res. Def. Council v. Jewell, 749 F.3d 776, 779 (9th Cir. 2014) (citing 16 U.S.C. 22 § 1533). FWS and NMFS administer the ESA on behalf of the Departments of the Interior and 23 Commerce, respectively. See 50 C.F.R. §§ 17.11, 222.101(a), 223.102, 402.01(b). Most pertinent 24 to this case are Section 7, 16 U.S.C. § 1536, and Section 9, 16 U.S.C. § 1538, of the ESA. Section 25 7(a)(2) imposes a procedural duty on the federal agencies to consult with the U.S. Fish and 26 Wildlife Service (FWS) or NMFS, depending on the protected species,1 to “insure that any action 27 1 Generally, FWS has jurisdiction over species of fish that either (1) spend the major portion of their life in fresh 28 water, or (2) spend part of their lives in estuarine waters, if the remaining time is spent in fresh water. See Cal. State 1 authorized, funded, or carried out by such agency . . . is not likely to jeopardize the continued 2 existence of any endangered species or threatened species or result in the destruction or adverse 3 modification” of critical habitats of listed species. 16 U.S.C. § 1536(a)(2). An agency “action” is 4 defined to mean all activities carried out by federal agencies, including, among other things, the 5 granting of licenses and permits. See 50 C.F.R. § 402.02. “If a contemplated agency action may 6 affect a listed species, then the agency must consult with the Secretary of the Interior, either 7 formally or informally.” Am. Rivers v. NMFS, 126 F.3d 1118, 1122 (9th Cir. 1997). 8 Formal consultation results in the issuance of a BiOp by the relevant wildlife agency 9 (FWS or NMFS). See 16 U.S.C. § 1536(b). If the BiOp concludes that the proposed action would 10 jeopardize the species or destroy or adversely modify critical habitat, see id. § 1536(a)(2), then 11 the action may not go forward unless the wildlife agency can suggest a “reasonable and prudent 12 alternative[]” (RPA) that avoids jeopardy, destruction, or adverse modification. Id. 13 § 1536(b)(3)(A). If a BiOp concludes that the proposed action (or the action implemented in 14 conjunction with actions described in the RPA) will cause incidental taking of protected species, 15 but that despite this taking, the action will not jeopardize the species or threaten critical habitat, 16 the wildlife agency 17 shall provide the Federal agency and the applicant concerned, if any with a written statement that— 18 (i) specifies the impact of such incidental taking on the species, 19 (ii) specifies those reasonable and prudent measures that the 20 Secretary considers necessary or appropriate to minimize such impact, 21 (iii) . . . , and 22 (iv) sets forth the terms and conditions (including, but not limited 23 to, reporting requirements) that must be complied with by the Federal agency or applicant (if any), or both, to implement the 24 measures specified under clauses (ii) and (iii). 25 Id. § 1536(b)(4). This required written statement, with its “reasonable and prudent measures” 26 (RPMs) and associated terms and conditions, is referred to as an “Incidental Take Statement” 27

28 2008). NMFS is granted jurisdiction over fish species that (1) spend the major portion of their life in ocean water, or 1 (ITS), which, if followed, exempts the action agency from the prohibition on takings found in 2 Section 9 of the ESA. Id. § 1536(o); Aluminum Co. of Am. v. Adm’r, Bonneville Power Admin., 3 175 F.3d 1156, 1159 (9th Cir. 1999). 4 B. Injunctive Relief 5 “A preliminary injunction is an extraordinary remedy never awarded as of right.” Winter 6 v. Natural Res. Def. Council, 555 U.S. 7, 24 (2008).2 In general, preliminary injunctions are 7 intended to “merely to preserve the relative positions of the parties until a trial on the merits can 8 be held, and to balance the equities at the litigation moves forward.” Lackey v. Stinnie, 604 U.S. 9 192, 201 (2025) (citations omitted).

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San Francisco Baykeeper, et al. v. U.S. Bureau of Reclamation, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/san-francisco-baykeeper-et-al-v-us-bureau-of-reclamation-et-al-caed-2026.