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<br />0024G6 <br /> <br />We believe the Program has already supported the premise that suitable spawning habitat is <br />present through its previous decisions. In 1996 the Biology Committee approved the <br />biological merits of fish passage at Hartland Diversion. They did this because they believed <br />spawning RBS would use the habitat that exists above the diversion. <br />For 2002, the Program guidance requested a scope of work to evaluate the spawning success <br />of RES in the Gunnison river. The Service does not believe we need to wait until this work <br />is conducted prior to implementing the flow recommendations. However, this information <br />will be available prior to completion of the EIS for Aspinall re-operation. <br /> <br />3) Overbank flows primarily to provide floodplain habitat for razorback sucker (issues <br />principally related to Gunnison River, rather than the Colorado River). <br /> <br />Minority proposal: overbank flooding should be considered only in the wettest 10% of the <br />years. <br /> <br />Service recommendation: Overbank flows occur now under 30% of hydrologic conditions <br />(wet and moderately wet), The flow recommendations were intended to improve conditions <br />for razorback sucker. Rolling back to 10% frequency is a step in the wrong direction. The <br />Service's recommendations call for these flows for a longer duration, but we recognize that <br />the duration may not be achievable in all years in these categories. <br /> <br />4) Peak-flow recommendations for driest hydrologic categories. <br /> <br />Minority proposal: no peak flow recommendations should be made for dry, moderately dry, <br />or average dry years. <br /> <br />Service recommendation: The Service has reviewed its justification for peak flow <br />recommendations in all hydrologic categories and believes these recommendations are <br />justified to provide at least some scouring of spawning bars and spawning cues in all years, <br /> <br />Minority counter proposal: We continue to believe that the peak flow recommendations for <br />dry, moderately dry and average dry years are s~~essive, One need only to look at what <br />happened during runoff in 2001, 2001 wanrfi~Herately dry year under which a 2-day peak <br />of at least 7000 cfs and a 2-day shoulder of 6300 cfs would have been required. Blue Mesa <br />did ~t fill this year and in fact was approximately 18 feet short of full or about 155,000 acre- <br />feet. During the Aspinall operations meeting, the only entity that publicly stated a peak flow <br />was desirable ~h~~r was the U~~'1 Reclj.lJl1ation made a small bypass of storage, <br />approximately , acre-feeF,d~ I)~'~at generated a I-day peak at Delta of 3900 <br />cfs and near Grand Junction of 5050 cfs. The 2-day peaks were 3860 and 4975 cfs, <br />respectively, The 2-day shoulder flows were approximately 3595 and 4555 cfs, respectively, <br />These peak flows were significantly less than the flow recommendations sought~This <br />demonstrates the excessive nature of the moderately dry year peak flow recommendations <br />and the need to at least reevaluate the dry, moderately dry, and average dry peak flow <br />recommendations if not eliminate them. <br /> <br />3 <br />