Laserfiche WebLink
<br />002474 <br /> <br />these flow recommendations, especially for wet and moderately wet years, was to inundate <br />substantial floodplain habitat in the reach of the Green River between its confluences with the <br />Yampa and White Rivers, with or without the removal oflevees (pages 3-48, 5-13, and <br />Anticipated Effects in Table 5,5), This report recommends the flows needed for recovery on the <br />Green River below Flaming Gorge Dam, not the EA on breaching levees. <br /> <br />Potential Misinterpretation: All Program participants agreed that no change in the existing flood <br />flow regime would be needed for recovery so long as floodplain levees could be breached on a <br />voluntary basis subiect to other funding priorities, Some Program participants submitted <br />comments on this EA suggesting that the existing flood flow regime would be sufficient for <br />recovery, if floodplain levees were breached as proposed, but clearly all Program participants did <br />not. There is no document explicitly stating an agreement by the other Program participants in <br />such a conclusion about the sufficiency of existing flood flows for recovery. The consensus <br />approval of the final biological report on the flow recommendations for the Green River below <br />Flaming clearly contradicts any such agreement. Indeed, even the water user representative <br />concurred in these flow recommendations for the Green River, Such concurrence precludes any <br />Program consensus that no change in the existing flow regime for the purpose of increasing <br />floodplain inundation is needed for recovery. <br /> <br />Potential Misinterpretation: Flow recommendations that exceed the flood flows needed for <br />channel maintenance or that would increase floodplain inundation beyond what could be <br />inundated bv breaching levees are excessive and uniustified. A large volumetric difference <br />between the flood flows needed for channel maintenance and those needed to increase floodplain <br />habitat does not make them excessive. Another perspective on how much volume may be <br />implicated by a longer duration flow for floodplain inundation is how much longer the flood <br />duration would be for any hydrologic category in comparison to the existing flow regime. Where <br />the hydrologic categories for the recommendation of longer floodplain inundation flows are <br />associated with the wetter hydrologic conditions, the incremental volume in comparison to the <br />existing flow regime may be modest. If the resulting increment of floodplain habitat is thought <br />to be needed for recovery, the flow recommendation is neither excessive nor unjustified. Hard <br />and yet to be answered questions about whether water is available to meet such flow <br />recommendations and about what other impacts and trade-offs must be faced, also do not make <br />such flow recommendations excessive, Moreover, such questions about whether a longer flood <br />flow duration can be implemented are outside the scope of a biological report on what duration <br />of flood flows is needed for recovery. <br /> <br />4 <br />