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o C) l';l. .. r.:~". CO. W DRAFT San Juan flow Recommendation Comments May 8, 1998 Page 4 of5 a concern, and subject to the same criteria, then this should also be clearly stated in the recommendations, If the criteria are applicable to the other gages, what criteria is proposed to determine whether or not the recommendations have been satisfied~ 13, The flow durations suggested do not appear consistent with durations suggested by test flow operations at other reservoirs, For example. test flows at Glen Canyon found that durations of three to four days were more than adequate to move fine sediments. Furthermore, the test flows showed that fine sediments were deposited along channel banks, not simply washed farther down the river bed. 14, What happens if there is a shortage to the flow recommendations? While the latest thinking is to address this project-by-project during individual consultations rather than as part of the flow recommendations, it still remains an issue in the program that must be addressed, 15, How can flow recommendations even begin to logically move forward until the technical reports supporting the recommendations are complete? Some of the technical reports will not even be available until June 1998. 16, Weare still in the process of exchanging irrigated acreage and hydrologic information with Reclamation. Reclamation is still revising some of their irrigated acreage information based on our data. Once they have completed that, we would like the opportunity to run that data, along with data used for New Mexico, through our CRDSS, The purpose of this is to make sure that we fully understand all the assumptions. Until this is accomplished, we are not prepared to offer support for any flow recommendations. Given the added time needed for the Biologists to complete their supporting studies, there is clearly time for this further refinement and comparison of the hydrology. We would also like it to be clear that we receive adequate time to make our analysis once Reclamation has finished their revisions and furnished them to us for review, even ifthat may further delay the final reconunendations, 17. The Biology Conunittee indicated that they would have a draft report available by May 1, 1998 for discussion at the May 18-19 meeting. As of May 8, 1998 no draft report was available, Therefore, public discussion should be rescheduled. We are of the opinion that these questions need to be addressed and considered along with the completed technical reports before any further actions on the recommendations are taken. Furthermore, we believe that the public should have adequate opportunity to review and comment on the recommendations, there use and enforcement while the recommendations are still in a preliminary form and prior to any actions to adopt the recommendations by either the Biology or Coordination Committees. We have been directed by the Colorado Water Conservation Board to take no actions that would formally adopt the flow recommendations, even in draft form, until a public review of the recommendations has been completed. Such public review must include: . 1he technical reports supporting the recommendations;