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t . Flow Recommendations Most participants had questioned the way the FWS treated its 1995 flow recommendations for the 15-Mile Reach. Those recommendations can be interpreted as an indication that recovery of the endangered fish will require more water (quantity and timing) than is typically available today in the 15-Mile Reach. Since the basic premise of the proposed PBO is that implementation of the Recovery Program's Recovery Action Plan ("RIPRAP") provides the basis 'for both recovery of the endangered fish species and development of existing and future water supplies, FWS acknowledged the need for a very clear explanation of its analysis. Fundamentally, the FWS continues to suggest that, assuming other habitat improvement aspects of the RIPRAP are successfully implemented, "recovery" can be achieved even if instream flows protected for the 15-Mile Reach don't match the 1995 recommendations. Biolol!ical Criteria for Reinitiation Many participants also had questions concerning biological criteria that the FWS proposes to use in the future to determine if the implementation of RIPRAP actions is having the desired effect, or if it should reinitiate this Section 7 consultation. The FWS indicates it is satisfied with the peer review that has occurred as part of the Recovery Program development of the current database and acknowledges that strong peer review, including statistical analysis, will continue to be an important part of maintaining this evaluation tool. In essence, the FWS expects endangered fish populations to increase and that annual monitoring will document that increase. This requirement (that endangered fish population data demonstrate that the species are at least holding their own, if not improving) is essential, according to the FWS, in reconciling habitat improvement with continued development opportunity. New Proiect Imoacts There continues to be concern among water users that FWS will seek limitations on new project configuration or operation that could prevent or limit the development of new water supplies. The FWS regulations require that any such limitations must be technically and economically "reasonable" and that it would be irresponsible to ignore opportunities to work with project proponents to minimize impacts where possible. The FWS may be willing to agree that such limitations will not impair project yield, but the relationship between those limitations and construction cost or operating cost have been more difficult to address. Incidental Take The FWS indicates that, while the RIPRAP is implemented to improve habitat and water supply needs are met, up to I % mortality (adults only) among endangered fish populations may occur without posing a significant risk that the recovery goals cannot be met. This allowance is essential as an acknowledgment of normal population response to environmental variations and to satisfy ESA regulatory requirements. The size of this allowance and the basis for its justification are still debated among Recovery Program participants while the FWS seems to be relatively settled on this point. Existinl! Deoletions All Recovery Program participants appear to be in agreement that there should not be an appendix to this PBO listing all existing depletions (or even rriost of them) because this cannot be done with sufficient accuracy. Instead, Randy Seaholm is working with FWS staff to describe a means of accounting for existing . . .