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2 from which effects of the proposed action are compared. Added to the environmental baseline are the direct, indirect, interrelated, and interdependent effects of the Federal action undergoing consultation. This analysis is then measured against the definition of jeopardy which is an action that reasonably 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 reducing the reproduction, numbers, or distribution of that species. A jeopardy finding must be based upon detrimental impacts to both the survival and recovery of a listed species. Reclamation's perspective is that the call of jeopardy should be defensible with specific data and more importantly, the proposed resolution of jeopardy should be based on specific quantitative goals and a scientifically based evaluation process. In our estimation the present document falls short of doing this. The following is a discussion which examines each step in the ESA process, and describes Reclamation's assessment. Definino the Environmental Baseline This environmental baseline must include past and present impacts of all Federal, State, or private actions and other human activities in the action area (CFR 402.02). The status of the endangered species below Glen Canyon Dam must distinguish between those effects associated with the initial construction of the dam and those associated with the operations of the dam. . We believe that effects of the construction and past operations of Glen Canyon Dam on endangered fish should be included in the environmental baseline as they provide the basis for comparison of what has happened to the environment and the resources. Direct Effects In the discussion of direct effects, page 21 of the DBa identified cold water temperatures as the central issue limiting reproductive success and. recruitment of humpback chub in themainstem. The DBO's stated goal of low steady summer flows is suggested to provide improved habitat in the mainstem Colorado River for larval and juvenile fish. However, scientific experts on native fishes in the Colorado River system who were convened to discuss the merits and detriments of flow alternatives on March 2, 1994, were not totally supportive that the DBO flow scenario will provide Quantifiable benefit to native fish without additional temperature modification. We agree some additional benefits to endangered fish may result from implementation of the flow scenario described in element 1a of the DBa. However, until temperature modification is operational these benefits may not improve survival and recovery of endangered fish. Page 26 of the DBO states: "Flows that provide optimal Quantity and Quality of physical habitat for spawning, nursery, juvenile, and adult life stages also need suitable temperature regimes to make those habitats viable." This statement reinforces the conclusion that without temperature modification, the flow recommendations contained in the DBO are questionable as to their effectiveness, and are therefore not justified. Furthermore, it is the presence of Glen Canyon Dam, a past Federal action which should be contained in the baseline, which accounts for the cold water temperatures, not the operations.