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downstream native fish in the Animas and San Juan Rivers. The Commission <br />also agrees that the non - native white sucker population should be significantly <br />reduced, if not eradicated, by any reasonable means, including angler <br />harvesting, a no- release policy and electrofishing during spawning. The costs of <br />these measures, as noted above, should be considered mitigation efforts that are <br />the responsibility of the federal government to ensure the full benefits of the ALP <br />Project to its beneficiaries, including the Commission. <br />Page 72, Checks for fish with nets and buckets: While this method was <br />reasonable for testing purposes to determine the effectiveness of the sleeve and <br />to trap surviving fish, the use of nets and buckets at the spillway should not be <br />considered as a possible mitigation measure to ensure no live non - native fish <br />escape during normal operations. The net and bucket process requires frequent <br />net checks and actually shutting down discharges to check the nets or repair <br />them. Shutting down the discharge during normal operations is not an <br />acceptable operational constraint to meet the no -fish goal. <br />Page 80, Entrainment Conclusions: The Commission agrees that periodic <br />monitoring of the discharge for entrainment of small - bodied fish is needed to <br />evaluate any changes in the reservoir fish population and the effectiveness of <br />mitigation measures to prevent live fish escapement. However, the Memo does <br />not answer the question of who will be responsible for the periodic monitoring <br />and how it will be funded. The Commission believes this a mitigation <br />responsibility of the federal government. <br />The Commission appreciates the opportunity to comment on the Memo, <br />and I am available to discuss these comments. We look forward to receiving your <br />response to the issues raised here, so that the ALP Project can provide the full <br />benefits intended for its beneficiaries. <br />Sincerely, <br />X <br />L. Randy Kirkpatrick <br />cc: Russ Howard, ALP OM &R Association <br />