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<br />Comments of the
<br />Colorado Water Conservation Board
<br />on the
<br />February 14, 1996
<br />Animas - La Plata Project
<br />Draft Biological Opinion --
<br />Reasonable and Prudent Alternative
<br />
<br />February IS, 1996
<br />
<br />1. Page I, RPA#I -- We continue to encourage reconsideration of the "not to exceed" language and use of
<br />"average annual" values for monitoring purposes as discussed in our previous comments.
<br />2. Page I, RPA#I, Line II -- Insert "ALP" in front of "deoletion." We want the opinion to be clear that it
<br />is talking about ALP depletions and not San Juan basin depletions.
<br />3. Page I, RPA#I -- We appreciate the clarifications made to the "percentage of the time limitations"
<br />placed on the 300,000 acre-feet stored in Navajo Reservoir for endangered fish purposes. This gives
<br />the San Juan Biology Committee flexibility to respond to the results of research and changing
<br />hydrologic conditions under the RP A.
<br />4. Page I, RPA#2, Line II -- Change to read as follows: "''''I"estell test flows requested by the Biology
<br />Committee and approved by the Coordination Committee ..."
<br />5. Page 2, RPA#2, Last sentence -- "After the preliminary flow recommendations are developed. the
<br />Service and Reclamation will reinitate Section 7 consultation on WHAT?
<br />6. Page 2, RPA#3, Line 4 -- Following 1987 add, "when hydrologic conditions allow, ...'.
<br />7. Page 2, RPA#3, Line 8 -- Add, "Coordination Committee" after the "Biology Committee."
<br />8. Page 2, RPA#3, Line 10 -- Add following "facilities," the words, "dam safety, downstream flooding."
<br />Without reviewing the Corp of Engineers Water Control Manual for Navajo Reservoir. we are not
<br />certain these issues are adequately addressed.
<br />9. Page 2, RPA#3, Line 13 -- Add channel capacities at Bluff and any point along the river which may be
<br />critical to out of bank flooding that could cause significant property damage.
<br />10. Page 2, RPA#4, Line 12 -- Following, "(April through November)" add ''under the oversight of the
<br />Coordination Committee."
<br />II. Page 2, RPA#5, Lines 3-5 -- The exceptions should allow for Committee discretion to address any
<br />number of issues which may not be emergencies. For example, operations could be within accepable
<br />guidelines and yet other hydrologic conditions or events could provide justifable means for deviation.
<br />Suggest adding, "or when there is a justifable reason to deviate as detennined by Reclamation and the
<br />Service" to the end of the last sentence.
<br />12. Page 3, RPA#6, -- Hopefully, the year-round flow recommendations will be flexible enough to address
<br />the wide varation in hydrologic conditions and changing needs of the fish as additional knowledge is
<br />gained. This flexibility should be more clearly indicated here.
<br />13. Page 3, Discussion, line 6 -- Consider removing the word "net."
<br />14. Page 3, Discussion, 1st paragraph, starling at end of line 9 -- Change as follows, "Therefore. Phase I,
<br />Stage A could not exceed 57,100 acre-feet of depletions until all elements of the RPA (?) are fully
<br />implemented. This would require that Reclamation operate Navajo Dam during the research period
<br />to provide flexibility to mimic a natural hydrograph as directed by the the Biology Committee under
<br />the oversight of the Coordination Committee and as demonstrated by model runs that showing an
<br />availability of 300.000 acre feet of water for spring release for endangered fishes 96 % of the
<br />time." Delete the balance of the old sentence. This change maintains consistency with language in
<br />RPA#1.
<br />IS. Page 3, Discussion, 1st Paragraph, Last sentence -- Add. "during the reasearch period" to the end of the
<br />last sentence.
<br />16. Page 3, Discussion. 2nd Paragraph reference to Appendix A -- Hopefully Figures 1-18 have been
<br />better explained in Appendix A. We also observe that there is virtually no difference between "ALP @
<br />57,100 CAP" and ALP @ 57,100 A VG." Given that there are virtually no differences. we urge
<br />Reclamation and the Service to return to utilization of the average annual consumptive use values
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