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.- -.\ dO Working for the Nature of Tomorrow. ~'tJ:. NATIONAL WilDLIFE FEDERATION iif!5' Rocky Mountain Natural Resource Center 303/786-8001 ~ 2260 Baseline Rd., Suite 100, Boulder CO 80302 FAX 303/786-8054 October 28, 1994 VIA FACSIMILE TRANSMISSION Perry D. Olson, Director Colorado Division of Wildlife 6060 Broadway Denver, Colorado 80216 -. e::.~- ~ "f !: "":,..... ~f:,j...' ":"~ F ,f~'" ~. ~:.:' ~" '_':~_"" ~'.. c. . ~ ~~ ~~~.--, '.'\:,; ;.,.... ~ _ ,", ,-' '-. 1 r;. . \' " I" 't \,.. v Vi J- ~oJ Attn:Western Colorado LMP D'~'-i""~O':"""'" ,'- ':C.-:- .,:. :~-'lt:V', ..~ ........ ; ~_.i.__ Dear Mr. Olson: The National Wildlife Federation has reviewed the Proposal by the Colorado Division of Wildlife (CDOW) to stock non-native warm water species in McPhee Reservoir on the Dolores River in southwestern Colorado. The National Wildlife Federation is the nation's largest conservation organization. Founded in 1936, the Federation works to educate and assist individuals and organizations to conserve natural resources and to protect the Earth's environment in order to achieve a peaceful, equitable and sustainable future. NWF offers the following comments on your proposed stocking on behalf of its members and supporters. We believe CDOW is overly optimistic in describing the escapement potential from McPhee as unlikely. McPhee has spilled in the past apparently as a consequence of operational inexperience. It would be helpful if CDOW included an analysis from the Bureau of Reclamation regarding the likelihood of spill events from both hydrologic events and operational errors. The Bureau of Reclamation is the operator of McPhee not CDOW and their involvement and analysis are essential to adequately determine escape potential. We suggest CD OW egregiously errs in speculating that escaped largemouth bass will not survive in downstream reaches should escape occur. Documentation exists that largemouth bass already inhabit the confluence of Colorado and the Dolores Rivers. How can CDOW assert that escaped largemouth bass will not survive downstream? Documentation to support this speculation should be provided to assure the interested publics of the most likely Olitcome .of. ~his action. Both largemouth bass and black crappie are documented to prey on endangered fish of the Colorado River System. Several authors have verified even preferential predation by largemouth bass on Colorado Squawfish. We urge CDOW to be very conservative in its stocking proposals and by integrating the various risk factors derive a better estimate of the ultimate risk to the endangered fish rather than the approach used here.