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<br />. Ms. Terry Terrell <br />January 12, 1998 <br />Page 20f3 <br /> <br />,~ <br /> <br />4. Page 3, Basis for Biological Opinion, 1 Sl paragraph -- Given the ALP BO, the dates <br />used here are not appropriate in our opinion. Historic depletions should be anything <br />in existence prior to October 25, 1991. <br />5. Page 4, 2nd paragraph -- The sentence stating that water depletions have "caused such <br />a decline in Colorado Squawfish and razorback sucker that small additional <br />depletions are considered jeopardy," we believe overstates the case and fails to <br />acknowledge the full impact of other factors discussed in the BO that also have <br />contributed to the species decline. This paragraph should be revised to portray a <br />more fair and complete picture of the reasons for the species decline. <br />6. Page 6, Water Quality -- We believe that while it is fair to discuss the impacts of <br />irrigation on water quality, the BO should focus on the impacts of Durango's <br />proposed project. The City of Durango's uses should be identified and the impacts of <br />those uses discussed. We are of the opinion that lawn irrigation will occur, bu1 not <br />farm irrigation as discussed in this section. <br />7. Page 7, Colorado Squawfish -- It would be helpful to have a map showing San Juan <br />River critical habitat, river miles, capture locations, nursery habitat and spawning <br />locations as appropriate included in this section. <br />8. Page 11, razorback sucker -- It would be helpful to have a map showing San Juan <br />River critical habitat, river miles, capture locations, nursery habitat and spawning <br />locations as appropriate included in this section. <br />9. Page 16, Environmental Baseline -- This section should note that historic depletions <br />are part of the environmental baseline and do not need to be consulted on. <br />10. Page 17, last 2 sentences -- These sentences are confusing, if depletions are included <br />in the baseline already why are they removed and ALP yield reduced? Either one or <br />the other is appropriate, but not both. <br />11. Page 19, San Juan Baseline Section 7 Baseline Table -- ALP project should be 57,100 <br />AF if Durango Project is treated as a new project and new depletions by Durango of <br />1,051 AF shown in the table. Also, return flows from the Dolores Project are a credit <br />and should be subtracted in the table making the bottomline 627,500 AF rather than <br />671,500 AF. <br />12. Page 22, RP A Alternatives -- A brief description of the Agreement between the <br />National Fish and Wildlife Foundation, USF&WS and Recovery Program should be <br />included that includes some discussion of any overhead charges the foundation may <br />charge and how the money is invested\escrowed until used. <br />13. Page 23, Conclusion, 2nd Paragraph -- Need to acknowledge that if the BO and RP A <br />treat Durango's Project as a new project; that even though the RP A funds Hatchery <br />activities in the State of Utah pursuant to Recovery Program the RP A provides <br />specific benefits to the City of Durango in the event the Recovery Program is <br />discontinued for any reason. <br />14. Page 24 -- The retained jurisdiction language should be more specific. It should also <br />state that so long as the San Juan Recovery Program for Colorado Squawfish and <br />razorback sucker is in-place or these fish are recovered there will be no reason to <br />reinitiate consultation. The BO should provide the applicant as much certainty as the <br />law allows in this respect. <br /> <br />. <br /> <br />. <br /> <br />. <br /> <br />~ <br />