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in consultation with the states and other appropriate <br />parties. The reaches were prioritized by consideration <br />of the reaches' biological significance and the timing <br />of water development or other activities. The FWS <br />developed a work plan for identifying the habitat <br />needs, and once identified, the FWS is to present the <br />needed flows to the Implementation Committee for its <br />use in implementing the recommendations. (NOTE: Flow <br />needs are not submitted for approval.) <br />b. For flow needs in Colorado, the Implementation <br />Committee is to request recommendations from the <br />Colorado Water Conservation Board on alternative means <br />of providing and protecting the desired instream flows. <br />The Board is to present an array of alternatives along <br />with estimates of costs, methods of implementation, <br />time frames, and procedural requirements. The <br />Implementation Committee is then to review the <br />alternatives and prepare recommendations that it will <br />request the FWS to implement. <br />C. Quantification of flow needs is difficu't due to <br />the scarcity of data and the logistical problems <br />associated with working on large, turbid and <br />inaccessible rivers. Determinations have been <br />partially based on professional judgment, which has not <br />been readily accepted by all participants in the <br />Program. Additionally, Colorado law states that the <br />quantity of an instream flow right is to be that <br />"required for minimum stream flows * * * to preserve <br />the natural environment to a reasonable degree." Such <br />standard results in a higher scrutiny of the quantity <br />of water requested as well as a higher burden of proof <br />than is needed for other Colorado water rights. <br />d. One of the major methods of obtaining sufficient <br />water discussed in Section 4.1.6 was refined operation <br />of existing federal reservoirs. The plan envisions <br />releases for endangered fishes from Ruedi Reservoir on <br />the Fryingpan River, from Blue Mesa Reservoir on the <br />Gunnison River in Colorado and from Flaming Gorge <br />Reservoir on the Green River in Wyoming. These <br />projects may have "significantly and adversely <br />affected" the endangered fishes and are important <br />sources of water for habitat maintenance and <br />improvement. The refined operations will result from <br />Section 7 consultation on the operation of these <br />projects. <br />e. Other potential water sources are original <br />appropriations for instream flows, conversion of <br />conditional or absolute water rights to instream flows, <br />3