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------------- ---------~-- -, . . United States Department of the Interior BUREAU OF RECL\l'vlATION Upper Color...do RegIOnal Office 125 South Srate Sneer. Room 6107 Salt Lake City, Utah 84138- t 102 I'J REl'lY REFER TO. UC-770 ENV-7.00 APR : 0 i995 MEMORANDUM To: Regional Director, Region 2, U.S. Fish and Wildlife Service, P.O. Box 1306, Albuquerque NM 87103 From: Charles A. Calhoun Regional Director Subject: Response to the Final Biological Opinion on the Operations of Glen Canyon Dam (2-21-93-F-167) We have received and reviewed the subject Biological Opinion (Opinion), dated December 21, 1994. It is our intent to implement the elements of the Reasonable and Prudent Alternative (RPA). However, we still have concerns related to definition of the environmental baseline and the conclusion that the proposed action violates the jeopardy threshold. The construction and operation of Glen Canyon Dam (GCD) is a past Federal action and part of the environmental baseline. This baseline condition has brought about environmental changes which have caused harm to the endangered native fish of Glen and Grand Canyons. Therefore, we understand the difficulty of separating the on-going impacts of dam construction and operation from projected results of the proposed action. This distinction is important in determining whether the proposed action will result in jeopardy. By definition, the elements of an RPA describe an alternative action which will avoid the likelihood of jeopardy, as opposed to actions to achieve recovery. The elements of the RPA seem to be focused on recovery. The opinion points out that to jeopardize the continued existence of a species is to engage in an action that would be expected, directly or indirectly, to reduce appreciably the likelihood of both the survival and recovery of a listed species in the wild by further reducing the reproduction, numbers, or distribution of that species (emphasis added). Page 32 of the opinion concludes that "the 470 km reach of the mainstem Colorado River downstream of Glen Canyon Dam... apparently does not provide for survival of all age classes nor an environment for successful spawning and recruitment of young to adult humpback chub. For razorback sucker, only minimal support for the adult life stage has been identified in the mainstem reach downstream of Glen Canyon Dam." The Opinion further concludes "The proposed action is anticipated to improve conditions over NA [No Action] for the humpback chub ..." The current, baseline conditions do not meet the definition of survival, and the proposed action is expected to improve conditions for the fish. Therefore, we fail to see that the proposed action jeopardizes the continued existence of the humpback chub (HBC) or razorback sucker.