Aspinall EIS - Scoping Report May 2007

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The baseline for the study is important and should only include existing water uses. Target reservoir levels and release schedules need to be re - examined in light of the need to benefit the endangered fish. Modeling of operations is critical to the study and this should be an open process. Dallas Creek and Dolores Project biologi cal opinions and water for the Redlands fish passage need to be considered in the EIS. 2 High Country Citizens Alliance : Reclamation’s obligation to ESA goes beyond avoiding jeopardy, should use operations for endangered fish recovery. Concerning flood control, there are alternatives other than limiting spring peaks — for example the c h annel at Delta could be deepened and banks modified. Filling Blue Mesa should remain an operation goal; recreation at Blue Mesa is very important to the economy of Gunnison . The baseline should include existing uses and agreements; existing hydropower operations can be modified and are not part of the baseline. Commitments in the Dallas Creek and Dolores Project biological opinions should be included in the baseline. Wint er elevation target for Blue Mesa should be revisited. Speculative projects should not be included in the baseline . Living Rivers: The EIS should consider effects on the Black Canyon of the Gunnison National Park and explain how operations should be ma naged to ensure compliance with the non - impairment provision of the NPS Organic Act. Non - native fish need to be addressed in the EIS and alternatives that eliminate predation by non - native fish need to be considered. A programmatic EIS that analyzes the dysfunction of the critical habitat of the Colorado River basin is needed rather than piece - meal approach of separate EIS’s on CRSP Units. Water quality must be addressed including the effect of motorized boating on water quality. Decommissioning the Uni t must be considered as an alternative in the EIS because it meets the definition of reasonable and practical under NEPA. Black Canyon Chapter Audubon: Implementing flow recommendations will benefit other wildlife in addition to endangered fish species. Changes in historical water use patterns may need to be investigated as part of alternatives. Center for Native Ecosystems: Stressed that EIS should seek to recover the endangered fish species and other native species. Recovery should be emphasized o ver “avoiding jeopardy.” Timing of releases and water quality should be carefully considered. The baseline should not include speculative projects. 2 Including Sierra Club, Western Colorado Congress, San Juan Citizens Alliance, We stern Slope Environmental Resource Council, and Colorado Rivers Alliance. 21