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<br />0024S8 <br /> <br />NON-TECHNICAL ISSUES <br /> <br />A. Modeling water availability and Aspinall operations to meet flow recommendations. <br /> <br />Minority proposal: prior to making the flow recommendations, water availability should be <br />modeled and factored into the flow recommendations, <br /> <br />Service recommendation: The Service believes flow recommendations must reflect the needs <br />of the fishes; however, we also recognize that the existing modified hydrologic regime may <br />preclude us from meeting these recommendations 100% of the time. We expect the Bureau, <br />working with the CWCB, to model Aspinall reoperations to meet these recommendations (as <br />well as other project purposes) and provide the Service with an estimate of their ability to <br />meet the fishes' flow needs. A subsequent biological opinion will determine whether the <br />Service believes this is sufficient to preclude jeopardy. This BO will consider the benefits to <br />be derived from a Gunnison River Recovery Implementation Plan and PBO, and whether the <br />plan can serve as the RP A for Aspinall, <br /> <br />Though the Service does not believe that modeling water availability before finalizing the <br />Gunnison flow recommendations is appropriate, we agree to run a cursory basin hydrologic <br />analysis (like we did on Green River) and include this analysis in the flow recommendations. <br /> <br />Minority Countervroposal: We continue to believe that water availability is an important <br />piece of scientific information to consider. If water availability clearly demonstrates that <br />there is no way to achieve the natural hydro graph under current hydrologic and development <br />conditions, then why shouldn't the USFWS help determine what flow targets are actually <br />achievable that are the most beneficial? For example, useful information can be developed <br />through a number of evaluation techniques such as PHABSIM and the development of <br />habitat preference curves. After 10 years or more of collecting data on these fish, we should <br />be closer to having some of this type of information to utilize to temper judgements and <br />recommend flows that might actually be achievable and benefit the fish under current <br />conditions. Simply evaluating historic conditions and claiming those conditions were always <br />beneficial is not good science, Even under historic conditions the fish had to have good years <br />and bad. Flow recommendations should strive to recommend conditions that might actually <br />be achievable under current development and hydrologic conditions and benefit the fish. <br />This can not be achieved without a water availability analysis. If water availability indicates <br />that the flow recommendations are not achievable a significant portion of the time, what good <br />are the flow recommendations? Such a scenario simply means that everyone becomes <br />frustrated because the recommendations aren't achievable and the only means of achieving <br />such recommendations is through acquiring (some would stay taking) someone's water right. <br />Colorado still has compact apportionment left to develop in the Colorado and Gunnison <br />River Basins, The present flow recommendations clearly reduce if not eliminate that water <br />development potential and in our view will not be achievable a majority of the time. Let's <br />work together to develop flow recommendations that are achievable. <br /> <br />5 <br />