BO Assumptions and Disputed Issues

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The BO assumes the Program includes "substantial clearing and leveling of river islands." [BO p. 317]. Specifically, the GC-2 Alternative assumes the conversion of wooded islands to wetted channel through leveling of islands and moving sand back into the river channel at a rate of 50 acres per year throughout the term of the ls` Increment. This aggressive island leveling plan is the scenario portrayed in the DEIS that is considered to control channel degradation, increase open view widths, and build sandbars. [DEIS pp. 5- 52 to 5-53; 5-156, etc.] In fact, the sediment component of the Proposed Program recognizes that much uncertainty exists about potential outcomes with these sorts of management activities and responds to concerns regarding potential undesired impacts on adjoining lands. The Program's IlVIRP thus embraces phased stair-stepped adaptive management approach beginning with data gathering, further investigations of potential management methods, development of testing approaches, and implementation of small- scale testing of management methods that, if successful in outcome, would be tested at a progressively larger scale before adopted as a routine management activity for Program lands. [IMRP, Att. 3, III.C., p. 141. The Proposed Program does not commit to implement the large-scale in-channel sediment management prescriptions in advance of them "proving up." If they do not prove successful or have unacceptable negative effects, alternative management activities and methods will be explored. Restoration of natural riverine functions as a Program Objective. The BO assumes development of a"scientific adaptive management framework" that includes restoration of a semblance of natural riverine functions and processes (i.e., sediment supply and transport, a more normalized flow regime, and floodplain connectivity) as a specific Program objective. [BO p. 3171 The June 14-15 Agreement specifically retained language that the creation, protection and improvement of peak, pulse and other flows (aside from annual pulse flows) are not part of the 1S` Increment water objective. It recognized that the Program would integrate its land and water management activities with the IMRP, Program Adaptive Manangement, and system constraints to enable evaluation of these issues, and that FWS could use Program water subject to its discretion to attempt to achieve a more normalized flow regime given system constraints. 6. No consideration of hydrocycling. [BO p. 193] 7. No consideration of impacts to peaks under Future Depletions Plans. [BO p. 193] 8. Habitat "surrogates" for incidental take (discussed at the meeting between Colo/FWS on August 26). BO contains unacceptable findings of take exceedance coupled with reinitiation criteria for increased frequency of inundating flows, reduced frequency of 3-day high flows, net -2-