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<br />. <br /> <br />. <br /> <br />2 <br /> <br />lA - A Program of Experimental Flows <br /> <br />Your November 27 letter correctly states that the Reasonable and Prudent Alternative <br />recommended experimental flows to include high steady flows in the spring, which may include <br />habitat building and habitat maintenance flows. The December 1994 Biological Opinion called <br />for a program of experimental flows to include high steady flows in the spring and low steady <br />flows in summer and fall. <br /> <br />The purpose of the beach/habitat building flow as described in the Final Environmental <br />Assessment and Finding of No Significant Impact include ". ..rebuilding eroded sandbars, <br />reforming backwater habitats for native fish and mimicking the natural processes that create a <br />dynamic Grand Canyon ecosystem." Further it states "This test is needed to scientifically verify <br />the predictions stated in the final EIS on Glen Canyon Dam operations. That is, to test the <br />hypothesis that the dynamic nature of fluvial landforms and aquatic and terrestrial habitats can <br />be restored by short-duration releases substantially greater than powerplant capacity." Although <br />the Service supported the beach/habitat maintenance flow as a means of reforming backwater <br />channel habitats which could be used by native fishes, the dismissal of the low steady flows in <br />summer and fall indicates only partial progress toward meeting the intent of this element of the <br />RPA. Your November 27 letter concludes the same (Page 2, first paragraph) referring to the <br />delays associated with the signing of the Record of Decision, which as stated earlier, <br />implemented the Adaptive Management Program and would coordinate experimental flows, <br /> <br />Since the ROD had not been signed before the time designated to conduct the beach/habitat <br />building flow, a separate Environmental Assessment and section 7 pursuant to the Endangered <br />Species Act were conducted. The Service believes that low steady flows in the summer and fall <br />could have been included with the beach/habitat building flow or undergone separate <br />environmental compliance. At a minimum, low steady flows could have been designed for <br />possible implementation following the high flows. <br /> <br />The December 1994 Biological Opinion stated that design of the experimental flows was to begin <br />as soon as possible and be completed by October 1996. The Biological Opinion stated that <br />"Unless the Service determines information provided seriously questions the validity of <br />experimental designs developed or contribution of the resulting data to remove jeopardy to the <br />federally-listed aquatic fauna of the Grand Canyon, experimental flows will be initiated in April <br />1997." The Service is not aware of progress towards designing a program of experimental flows <br />which will include high steady flows in the spring and low steady flows in the summer and fall. <br />Your November 27 letter states that the Grand Canyon Research and Monitoring Center has <br />conducted multiple meetings to formulate research needs. <br /> <br />The December 1994 Biological Opinion also states that "If sufficient progress and good faith <br />effort is occurring towards initiating experimental flows, implementation of experimental flows <br />may occur later in 1997." Your November 27 letter states that due to high water releases <br />predicted' for Glen Canyon Dam, implementation of the preferred alternative is to be <br />implemented over the experimental flows. As high water releases are also expected for the next <br />