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. . 3 SPRING FLOW IlECOIlKENDATION - PROVIDING SEASONAL FLOODING FOR MIGRATION AND SPAWNING CONDITION The spring flow recomaendation wherein we would provide III8X1mum power releases for 6 weeks to coincide with the spring peak flow of the Yampa River, appears to be based on the premise that historic riverine conditions were optimum for the native fish community. While this in time may be determined to be true, the supportive biological information was based primarily on empirical evidence collected during above average flow years and professional judgment. From a biological perspective and recognizing what is known about Colorado squawfish, razorback sucker, and hUlBpback chub; it is logical to hypothesize that seasonal flooding may have been an important requirement for the endemic fish community. However, we believe more information should be collected to specifically address the flow needs of the fish for the spring period before a long-term flow reco..endatio~ is determined and implemented. -..-. At a minimum, we believe more information should be collected to determine: 1) what flows are necessary to produce a desired level of seasonal flooding in critical habitats in the Jensen and Ouray area, and how such flooding might affect backwater habitat formation, 2) what effect seasonal flooding will have on young of the year and age 1 and 2 juvenile fish, and 3) what effect seasonal flooding andspring.peaks ~ght have o~ reproductionof.~dult.fish .and reeruitment>of'larvlil fi!lh. .'.....;. i. . ..c...... ...;. ..... .,. ,- ""': :'.' ...... :..-:..........: ..... The presence and continuinhrOl1feratiOn of intrQJiw:ed fis!!..Jts au a~!titional area of concern that must also be considered before flow reco~endatjpns snou~d be instituted outside of the summer and early a~~u~eriod. Although tne1'low recommendations, for the most part, appear logical, they were developed primarily for the endangered fishes and little information is available to determine effects of recommended flows on the abundance of potential competitor species. We do not believe it prudent to implement any flow recommendation without understanding more about the affects of annual flow events on the proliferation of non-native species. ..tJ!;, . -.. :;;~6T;;~ ~/J"'.oP \ I JJf?" Again, we want to aBBure you that the protection of the Colorado River endangered fishes 1s a high priority and a responsibility we view to be critical to our mission. We recognize that the protection of the endangered fish and the various habitats critical to their survival through modification in project operation is perhaps the most important recovery action that could be undertaken by our agency. We also acknowledge that the completion of a Biological Opinion on the operation of Flaming Gorge Dam with recommendations is a high priority for both of our agencies. However, we believe that the opinion must provide the biological data and basis that will allow us to prepare an adequate National Environmental Policy Act (NEPA) document to implement the recommendations of the opinion. We believe existing data are incomplete especially in the area of non-native fish impacts. We agree with the evidence presented in the Consolidated Reports which suggests that the operation of Flaming Gorge Dam has had an impact on the annual hydrography of the Green River and certain life stages and behavior of the endangered fishes. We also aupport the flow recommendation for the summer and fall where data is available to substantiate a recommendation for operational changes that would have a high probability of realizing a positive effect on the endangered fish community. However, for the other periods of the year, we believe more information needs to be collected in order to make a