WSP08809

• File Number: 8220.106
• Description: Animas-La Plata
• State: CO
• Basin: San Juan/Dolores
• Water Division: 7
• Date: 1/1/1996
• Title: Correspondence regarding the Final Biological Opinion - 1996
• Water Supply Pro - Doc Type: Biological Opinion

U.S. Fish and Wildlife Service
January 30, 1996
Page 3

Another point, Figures 21 and 22, Appendix A, are headed "ALP
depletions at Bluff". It is our understanding that the depletions
plotted are as determined at site of use and are not routed
downstream in the San Juan River. Therefore, the values plotted
must not be construed to determine depletion of the virgin flow of
the Colorado River as set forth in the Upper Colorado River Basin
Compact.

Figure 22 also is misleading in that the chart is intended to
reflect the probability of exceedance of the modeled annual
depletions. However, the chart headings also apply to the plotting
of the average annual depletion of 57,100 acre-feet, which has no
relevance to "probability of exceedance".

Page 7, second paragraph. The last four sentences make
reference to the current level of depletion of the average annual
flow at Bluff being 27%, and that further depletions associated
with the project would raise that figure to 38%. On page 21 the
draft shows that the post-project depletion is 38% of the 1.9 maf
yield of the San Juan River. However, using that same 1.9 maf
yield, the current level of development would deplete that yield at
Bluff by 30%. The 27% apparently was computed using a basin yield
of 2.2 maf. The values on page 7 should be computed for the same
basin yield.

Pages 21 and 22. The description on page 21 indicates that
16,420 acre-feet of depletion, which we assume is an average annual
depletion associated with irrigation, is transferred from the
Hogback and Fruitland Projects to NIIP, and that the Hogback and
Fruitland Projects are now limited to an aggregate depletion of
31,280 acre-feet. This value also is shown in Table 2, in which
the Fruitland and Hogback are combined with a listed depletion of
31,300 acre-feet. The Table 2 itemized list of depletions is
similar to the San Juan Section 7 baseline included in 1991 Final
Biological Opinion for ALP. That baseline (1991) was discussed in
detail during negotiations of the 1991 Memorandum of Understanding
and of the San Juan River Recovery Implementation Program. In
those discussions New Mexico representatives pointed out that the
itemized list of depletions for New Mexico, i.e., Citizen's Ditch,
Industrial Diversion, Municipal and Industrial Diversions, Hogback,
and Additional Depletions, were not depletions for individual