Correspondences Concerning Offsetting Reudi Reservoir Releases as a Result of Critical Habitat Designation

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IN Rf PLY REFER TO; UC -770 ENV -4.00 United States Department of the Interior BUREAU OF RECLAMATIO\ Upper Colorado Regwn, l C laic: I_5 Souch Seise >crcm R,• m + +i Salc Lake Cin. Ur.ch ,1 •1 ;.ti- I PO MAY 2 6 19 To: Management Committee Members Upper Colorado Recovery Implementation Program (Enclosed Mailing List) Subject: Proposed Modifications to Recovery Implementation Program Recovery Action Plan Addressing Critical Habitat This letter is in response to your request for comments on the draft modifications presented in the April 29, 1994, version of the Recovery Implementation Program Recovery Action Plan ( RIPRAP) as a result of critical habitat designation. The comments-provided represent the consolidated position of the Bureau of Reclamation. The comments are organized by general categories of proposed activities with reference to specific RIPRAP items as necessary. 1. General: The U.S. Fish and Wildlife Service's (Service) letter to the Management Committee dated May 3, 1994, states in part, "These changes would allow (emphasis added) the RIPRAP to provide the reasonable and prudent alternative for adverse modification or likely destruction of critical habitat resulting from depletion impacts of new projects and all existing or past impacts to historic water projects to the same extent that it does to avoid the likelihood of jeopardy." This implies that without these changes and implementation of the objectives the RIPRAP does not provide the reasonable and prudent alternative for depletion impacts to critical habitat. Modifications to the RIPRAP must be agreed to and adopted by the program participants. The Service should clarify that these are recommendations that the Service believes would be useful in addressing critical habitat during the preparation of biological opinions, and that would aid in the recovery of the fish, presented for the consideration of the Management Committee. There appears to be a certain amount of discomfort among the program participants with respect to the critical habitat designation and effects on existing operations. Therefore, it is paramount that all program participants fully understand the implications and feasibility of adopting the Service's proposed modifications. Setting unreasonable time frames to accomplish work for which no funding has been programmed will impact the previously scheduled work and may impact the program's ability to achieve sufficient progress. We request the proposed modifications to the RIPRAP be reviewed by the biology committee and that biology committee comments be considered along with any public comments resulting from the Federal Register notice.