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<br />Enclosure 2 <br /> <br />COMMENTS ON THE DRAFT BIOLOGICAL OPINION (DBO) <br />ON THE MODIFIED LOW FLUCTUATING FLOW ALTERNATIVE OF THE <br />DRAFT GLEN CANYON DAM ENVIRONMENTAL IMPACT STATEMENT <br /> <br />Reclamation and other Cooperating Agencies, including the U.S. Fish and <br />Wildlife Service (Service), have been involved for about four years in the <br />effort leading to a decision for appropriate operation of Glen Canyon Dam. <br />With the Secretary's decision in 1989 to prepare an Environmental Impact <br />Statement (EIS), the focus has been to develop a balanced solution to the <br />resource issues of Glen and Grand Canyons. A great deal of research has been <br />conducted and the body of knowledge has been expanded many fold over these <br />past years. We would, however, note that not all the questions have been <br />answered about the interrelationships of the canyon ecosystems. Many of the <br />questions will take years to answer. <br /> <br />After careful review and study of the Reasonable and Prudent Alternative (RPA) <br />included in the October 13, 1993, DBO, Reclamation respectfully takes the <br />position that parts of this RPA would require modification to be acceptable. <br />We believe that with the proposed changes, we will be able to address <br />endangered species concerns in a manner consistent with the EIS process. <br /> <br />Our principle concern is with Element Ia of the RPA. We have serious <br />reservations that the implementation of the endangered fish research flows <br />contained in Element Ia would provide any measurable benefit to endangered <br />species over and above those resulting from implementation of the Modified Low <br />Fluctuating Flow Alternative (MLFF). We do not believe that the best <br />available scientific information supports the flow regime as suggested in the <br />RPA. <br /> <br />As a cooperating agency for preparation of an Environmental Impact Statement, <br />we believe the Service shares Reclamation's goal of determining the best <br />manner in which to operate Glen Canyon Dam to achieve a balanced approach to <br />resource management in the Glen and Grand Canyons, in keeping with the intent <br />of the Grand Canyon Protection Act. The NEPA process requires the <br />consideration of all resource needs. However, rules governing compliance with <br />the Endangered Species Act are more restrictive. We have analyzed the <br />Endangered Species Act process for determining the effects of the proposed <br />Federal action. We find the logic followed by the Service in determination of <br />jeopardy and in the development of the reasonable and prudent alternative to <br />be unclear and unsupported from a scientific perspective. It is apparent that <br />additional scientific review of the relationships between flows and native <br />fish community assemblage response is needed. Reclamation proposes that this <br />work should be scientifically based with defined experimental process rather <br />than implemented with little scientific control. <br /> <br />In determining the effects of the action under the Endangered Species Act <br />(ESA) , the Service is required to evaluate the status of the species or <br />critical habitat at issue, thereby creating an environmental baseline. This <br />. is accomplished through consideration of the present environment, in which the <br />species or critical habitat exists, as well as the environment that will exist <br />when the action is completed, in terms of the totality of factors affecting <br />the species or critical habitat. An environmental baseline is developed in <br />this manner, <br />