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<br />Therefore, I support the recommendation in principle, but the historical baseline used to <br />derive mean monthly flows appears to be incorrect Depletions in the Yampa River currently are <br />ca. 110,000 cfs (Figure 7, Brendecke 1993), not 68,000 cfs. I also do not think it is appropriate to <br />use monthly means in such analyses because daily flow variation is a very important,~omponent of <br />river ecology. The daily flow duration curve for the period of record would more accurately reflect <br />the real baseline. Moreover, if natural seasonal and daily flow variations are vital to the fishes, then <br />the natural diel and daily flow variation observed in the Yampa River should provide a basis for <br />designing more benign flows in the regulated Green River. <br /> <br />Green River <br />Recommendations on the Green River were based on inferences from ecological studies of <br />the endangered fish, which I summarized above (not necessarily in support of the recommended <br />flows) and the backwater area to discharge relationship determined by Pucherelli et al. (1990). The <br />main intent of the peak flow recommendation by the U.S. Fish and Wildlife Service apparently was <br />to add volume to the peak flows derived from the Yampa River to create an annual spring peak <br />sufficient to flood and maintain connectivity of the channel to backwater environments and <br />floodplain wetlands in the alluvial reaches near Jensen and downstream. <br />Rationale for duration and amplitude of the spring peak was not given, except with regard to <br />constraints on releases at Flaming Gorge Dam (Le., only 4,000 cfs can be discharged through the <br />generators plus an additional 4,000 cfs can be passed through bypass or jet tubes without opening <br />flood gates). The fact that the Yampa and Green Rivers historically peaked at different times was <br />not clearly addressed, nor were the proposed ramping rates on the rising and falling limbs of the <br />hydro graph in either the context of the discharge to backwater area relationship of Pucherelli et al. <br />(1990) or the need to establish ecologically functional wetlands on the floodplain (e.g., flooded <br />bottomlands at Escalante Bottom). The 1992 spring flow~ followed the hydro graph recommended <br />in the Biological Opinion (Figure 17). <br /> <br />56 <br /> <br />'. <br /> <br />'. <br />