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002477 the Service on research proposals that are considered exempt from NEPA. For example, at the September 1997 AMWG meeting, in discussions about the fall 1997 test flow, although Sam Spiller of the FWS said there would be no need to reconsult under Section 7 for those particular flows, Reclamation chose to submit a biological assessment, in the interest of the endangered species resource, and received a biological opinion in return. Also, as mentioned earlier, the 1994 opinion requires that the Service first approve whatever is proposed for the experimental low steady flows. Such flows area component of the EIS altematives common element, Adaptive Management. HOW DO BIOLOGICAL OPINION ISSUESIINFORMA TION NEEDS MESH WITH ONGOING MONITORING AND RESEARCH BEING CONDUCTED THROUGH THE GCMRC? WHAT ARE THE RELATIVE ROLES FOR RECLAMATION AND GCMRC IN MEETING ENDANGERED SPECIES NEEDS UNDER THE BO? Recalling that the purpose of the action leading to the EIS (reevaluation of dam operations) was, "to determine specific options that could be implemented to minimize, consistent with law, adverse impacts on the downstream environmental and cultural resources and Native American interests in Glen and Grand Canyons," and, given the current status of the humpback chub, razorback sucker, and Kanab ambersnail, and the mandate from the Endangered Species Act that, "Each Federal agency shall, in consultation with and with the assistance of the Secretary, insure that any action authorized, funded, or carried out by such agency (hereinafter in this section referred to as an "agency action") is not likely to jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of habitat of such species which is determined by the Secretary, after consultation as appropriate with affected States, to be critical..." it's apparent that there are strong connections between what's been required or suggested for benefit of endangered species and the direction the research and monitoring effort should be going. If the research and monitoring program is not headed in a direction to help accomplish those ends, then it should be reevaluated. It's not being suggested here that endangered species should be the exclusive resource of focus, but they have got to be a very high priority. HOW DO THE TERMS AND CONDITIONS OF THE BIOLOGICAL OPINION FACTOR IN AS FAR AS NEPA? The biological opinion calls for research efforts, including testing of steady flows and evaluation of a selective withdrawal capability. In accordance with earlier statements, NEPA is not required for experimental flows but could be done voluntarily to assist in making the decision on how to do the test. A NEPA process is already underway (draft EA) for the selective withdrawal structure. There may need to be some additional ESA compliance to incorporate results of ongoing research and monitoring and NEPA would be required only if the proposed changes represented permanent changes from the preferred alternative. ARE THERE WAYS TO F ACILITA TE COMPLIANCE WITH NEPA AND ESA FOR DEVELOPMENT AND IMPLEMENTATION OF EXPERIMENTS ON VERY SHORT NOTICE, OR IMPLEMENTATION OF EXPERIMENTS THAT HAVE BEEN DESIGNED AND ARE JUST A WAITING THE RIGHT CONDITIONS? Yes, and the more specific we can be about the proposed action, and the more advance notice there is, then the better we can plan for and assess it under ESA and NEP A, should a decision be made to do NEPA. In general, we could describe the anticipated research needs and set up a process for drafting a CE or EA, and submitting it for necessary review and comment. Depending on the proposal and what the likely impacts are, in most cases the process can proceed quickly to completion. Potential delays would 4