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~ ", -) STATE OF COLORADO Roy Romer, Governor DEPARTMENT OF NATURAL RESOURCES DIVISION OF WILDLIFE -'J AN EQUAL OPPORTUNITY EMPlOYER for OV Perry D. Olson, Director 6060 Broadway Denver, Colorado 802t6 Telephone: (303) 297-1192 For Wildlife- For People March 24, 1993 Mr. Robert Williams Utah state Supervisor Ecological services U.S. Fish and Wildlife service 2060 Administration Building 1745 West 1700 South Salt Lake city, Utah 84104 Dear Mr. Williams: The Colorado Division of Wildlife supports the designation of for Colorado squawfish, razorback sucker and humpback chub. ot:l..oA.....uL ,t:.'.Lv.1'6...a.l the Division feels as. _ 1 revisions need to c/"'.s"7""/C'D ~ A'1#7"" ~,. . q ""'7...,h.~ ...~jy~ _issue is the proposed 100-year floodplain for all critical habitat (dL~as. This would impact not only the Division of Wildlife but also agencies such as the BLM, Highway Department, sanitation districts, water districts, and irrigation districts who might conduct activities within the 100-year floodplain and use any federal monies. We do not support the lOO-year floodplain designation for defining critical habitat. Further, we do not support the floodplain approach described in the Federal Register as an appropriate or realistic method of defining critical habitat. critical habitat To support the be made. Critical habitat designation should be based on a defined quantity of habitat needed for a given species to survive as a self-sustaining population. With respect to these fishes, critical habitat is habitat available for recurring use by the species at a reasonable frequency during the average life span of a year class. This is based on the wide annual variability characterizing the riverine environments of the Colorado River Basin and the fishes' adaptation to varying annual flow regimes and associated availability of floodplain habitats in each river. We believe that Colorado squawfiah and razorback sucker require a Buccessful year class production.once every five years based on their probable life span of 20-30 years. W~'6elieve that critical habitat for the Colorado squawfish and razorback suckel should include floodplain habitat available as needed for all life stages that is inundated by a spring flood event occurring once every five years based on flow records from 1955 to the~sent. This should not be confused with a 5-year floodplain as defined in I maps. The challenge of recovery of these fishes is to accomplish our bI. ogical goals within the present realities of Compact water rights, not to restore the Colorado River fishes' habitat to historic. pre-settlement conditions. Habitat development should proceed within the lateral boundaries of the five-year flood event to ensure availability of habitat types for all life stages of the native fishes. tv,..!'" -:1"0,,1- With regard to the reaches designated as critical habitat by species: Razorback sucker: We agree with the Colorado and Gunnison river reach designations. Nothing should be designated for the White River in Colorado. Due to present capture information, floodplain habitat availability, and apparent use of spawning habitat, no critical habitat should be designated in the Yampa river above the lower few miles .containing the presumed spawning habitat. V I /"Tr )-. '"y "." c:... DEPARTMENT OF' NATURAL RESOURCES, Kennclh Salazar, Executive Director " WILDLIFE CO~ISSIqN. "Eldon W. Cooper-Larry At: 'Yri:eht, V.ice Chair:maneLou!. F. Swift~ SecretaI")' F~ljx Ch8VCZ; McmbereThol1\ll.M. Evc~'McmbcreRcb"~ Frank, MC(DbcteWilliIm R. lkgberJ~ Member-George VanDenBerg, Mciilbc"r'"