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

• Description: Correspondences Concerning Offsetting Reudi Reservoir Releases as a Result of Critical Habitat Designation
• State: CO
• Date: 1/12/1994
• Author: Various
• Title: Correspondences Concerning Offsetting Reudi Reservoir Releases as a Result of Critical Habitat Designation
• Water Supply Pro - Doc Type: Correspondence

2. Flood Plain Management:
We understand the need for flood plain management as it relates to
protection of critical habitat for recovery of the endangered Colorado River
fishes. However, incorporation of these items in the RIPRAP represents a
significant enlargement of the scope of the Recovery Program which should be
carefully considered. Reclamation would be willing to agree to the inclusion
of these items and provide technical support, where appropriate, conditioned
upon the acceptance of affected State and local governments and resolution of
the issues raised by the following specific comments.
As presented the sequence of activities would seem to need further
consideration. We recommend that the inventory of flood plain modifications
(item II.D.1 under the Colorado and Green River Sections) and the evaluation
and plan development activities (item II.D.2 under the Colorado and Green
River Sections) be reversed, i.e. inventories proceed evaluation and plan
development. We also recommend that the existing items II.D.2 under the
Colorado and Green River Sections be modified to read "Inventory the extent of
river channel modifications by structural or other means, including all bank
protection by riprap, diking, or spur dikes." This would provide a
comprehensive inventory of existing features as a basis for evaluation and
plan development.
Development and implementation of zoning regulations will require extensive
coordination with local governments which could prove to be a lengthy and
expensive process. If implementation of the viable options is to begin in
fiscal year 1995, the plan will necessarily require an extreme degree of
certainty and detail, or it will not be able to identify viable options,
emphasizing the impractical nature of the time frames. Implementation of
these actions will require compliance with the National Environmental Policy
Act, again requiring significant time periods to complete.
To most landowners restoration of flood plain impacts resulting from existing
channel modifications on private property will be viewed as intrusive. These
actions may be viewed as a taking of private lands if not implemented on a
voluntary basis. However, we believe an incentive program may be outside of
the scope of this program, and is most likely outside the existing
jurisdiction and authority of the Bureau of Reclamation. The term "incentive"
needs further consideration and definition.
While we support the goals of flood plain protection and restoration, the
target dates for completion of the work are not reasonable. No funding has
been budgeted for this work. Reprogramming of existing funds may result in
missing deadlines in the current RIPRAP and jeopardizing sufficient progress
and the ability of the Recovery Implementation Program (RIP) to serve as the
reasonable and prudent alternative for depletion impacts. No staff has been
identified to perform this work, or the source of funding for staff support.
Who will be responsible for working with the local municipalities? It is
imperative that we address these considerations before endorsing the proposed
flood plain management and restoration activities.