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<br />'-. <br /> <br />... <br /> <br />e <br /> <br />2. NPS peak flow recommendations should account for the above average (i.e" wetter than normal) <br />conditions that existed in the Gunnison Basin from the late 1800's through the early 1930's. As <br />currently structured the frequency of extreme peak spring flows may be over-represented. hence <br />achieving near-I 933 conditions may be unrealistic. <br /> <br />3. 300 cfs minimum is inadequate to protect Black Canyon resources, 600-800 cfs minimum is more <br />appropriate (reasons = sediment movement following flash floods. fishing, rafting). Flows should be <br />sufficient to support rafting in the Gunnison Gorge. <br /> <br />4, NPS needs to provide more specificity and justification for the proposed flow regime. What are the <br />implications for not achieving the desired flow conditions? <br /> <br />5, Does 300 cfs mimic the natural minimum? Is the 301 cfs number accurate as pre-dam minimum? <br /> <br />6, Is NPS trying to mimic 1933 conditions or pre-tunnel conditions? <br /> <br />7. Why is the NPS intent on remo,ing vegetation? NPS photographs suggest that vegetated banks and <br />bars are, and have been, a flow-related condition at different times in the past. Maintaining 1933 <br />conditions does not m:1ke sense, and is unrealistic. <br /> <br />FISH <br /> <br />1. NPS proposed flow-needs ignore fish (incl. non-native fish). Why? Didn't '78 court ruling prO'.ide <br />for this? <br /> <br />e <br /> <br />2, NPS flow recommendations should also be sufficient to protect the fishery in the Gunnison Gorge <br />and beyond, to Austin. <br /> <br />3. What is basis for the 300-as minimum? Has NPS collected sufficient dati to justify that 300 cfs is <br />adequate to sustain the trout fishery? NPS should seek baseflows in excess of 300 (at least 400 cfs) <br />... this baseflow should be secured via the 1933 right. <br /> <br />4. NPS should incorporate endangered fish flow needs into the water right filing - '78 court awarded <br />flows to NPS for native and introduced fish. <br /> <br />5, 300 cfs should be considered the absolute minimum for "preservation of the trout fishery through the <br />Gunnison Gorge." Long tena flows of 300 cfs Or less may have harmfuI effects on aquatic <br />invertebmtes, trout bioIrulSS and age structure, reduce sediment transport, elevate water temperatures, <br />and exacerbate whirling disease, <br /> <br />6, Annual channel maintenance flows timed to coincide "ith native fish flow requirements are <br />desiJable, provided dam safety is not compromised. <br /> <br />7. Volume of water associated with "shoulder flows" may significantly deplete Blue Mesa storage <br />resulting in decreased recreational use and damage to the fishery (especially the kokanee fishery) and <br />hence CDOW revenue stream, <br /> <br />8. NPS proposal prescribes flows for protecting macroinvertebrates but not fish. TItis is inconsistent. <br />please "''<Plain. How do the peak flows affect the fishery? <br /> <br />e <br /> <br />2 <br />