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0025~, 9 are very clear in their direction to Federal agencies to fully consider and mandate that certain actions be taken to avoid or alleviate impacts to threatened and endangered species and cultural resources, beyond that provided for in the 1970 National Environmental Policy Act and other laws. With perhaps somewhat less emphasis, the 1968 Colorado River Basin Project Act (43 U.S.c. 1501 et seq.) includes provisions for Oimproving conditions for fish and wildlifeO and that the annual operating plan for the Colorado River reservoirs Oshall reflect appropriate consideration of the uses of the reservoirs for all purposes, incIuding.....enhancement of fish and wildlife and other environmental factors.O The 1992 Grand Canyon Protection Act reiterates the need to comply with the 1968 Act and other applicable laws in the operations of Glen Canyon Dam. If it is agreed that legal issues spearhead the criteria development process, then perhaps the logical path to follow is to begin with those resources that are most closely related in a biological and physical context to endangered species and cultural properties. The rationale being that to do no harm to these priority resources, one must also determine the impacts to those resources utilized by endangered species or cultural properties. The sequence in which resources are considered in this resource criteria for a sediment conservation flow at discharges of 45,000 cfs are: I. Legalllegislative compliance II. Resources integral to the health of endangered and cultural properties III. Resources that are secondarily associated with the former two categories I. Legal Compliance Issues Endangered Species Act Compliance The Colorado River and its riparian environments in Marble and Grand Canyon serve as habitat for federally listed endangered species including the humpback chub, razorback sucker, bald eagle, peregrine falcon, southwestern willow flycatcher, and the Kanab ambersnail. In addition, the flannelmouth sucker is a candidate species being considered for listing. Other Arizona species of concern in Grand Canyon are the southwestern river otter, osprey, and belted kingfisher. Each of these species has needs associated with habitat or life stage that must be considered before a BHBF can be implemented. Table 1. COMPARISON OF BHBF AND HMF (from the GCDEIS) BEACHlHABITAT BUILDING FLOW HABITAT MAINTENANCE FLOW PURPOSE ..Reform backwaters ..Deposit sediment at high elevations --Maintain sandbars (important for camping beaches and fish habitat) ..Re-form backwater channels --Deposit nutrients