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.' ,., 170fl8 operational changes should be analyzed and included as a narrative so readers can understand the full impacts of both the recent and proposed future operational changes. . The current draft ofthe No Action Alternative considers future depletions in the Gunnison Basin and suggesls using SWSI figures for expected in-basin depletions through 2030. Future depletions in the Gunnison Basin remain a very contentious issue. In recenl discussions aboul a possible Programmatic Biological Opinion (PBO) for the Gunnison Basin, consensus could not be reached on future depletions. Representatives from the upper Gunnison Basin requested extremely low future depletion numbers, the remainder of the Gunnison Basin requested larger depletion numbers, and consideration of statewide issues and compact entitlement suggesls the full 300 KAF marketable pool should be protected. It was agreed that the PBO should seek ESA protection for existing uses but nol consider ANY future deplelions. The Gunnison PBO effort was then put on hold and will resume after the completion of the Aspinall EIS. . The current draft of the No Action Alternative also includes the April 2003 agreement between the CWCB and the Departrnenl of Interior regarding instream water rights for the Black Canyon of the Gunnison. The USBR wishes to include it because it is an existing agreement affecting operation of the Aspinall Unit. Others have suggested it not be included in the No Action Alternative, but be included as part of ALL Action Alternatives for reasons slated above regarding full impact analysis. Some environmental groups have requested it be removed from consideration pending the outcome ofthe current litigation. 5. Dallas Creek Project and Dolores Project Biolol!ical Opinions: The Dolores Project is depleting approximately 81,800 AF, bul assessed a depletion charge of 131,000 AF in the Biological Opinion, an amount with which we disagree. To offset the depletion, water may be released from either the Dolores Project or from other projects that regulate flows in the Colorado River Basin. Similarly, the Dallas Creek project is estimated to deplete 17,200 AF annually. To offset the depletion, water may be released from either the Dallas Creek Project or from other projects that regulate flows in the Colorado River Basin. As mentioned in Section S.5 ofthe Flaming Gorge Biological Opinion, re-operation of Flaming Gorge to achieve the flow recommendations for the Green River offset language in Central Utah Project Biological Opinions and we would support similar language and concepts be used in the Aspinall EIS to offset the conditions in the Dolores and Dallas Creek Projects. Recommendations . Staff recommends: I. Adhering to a strict interprelation of the Acts 2. Continued support ofposilions in the CWCB's 1994 letter Flood Protection. Water Project Planning and Financing. Stream and Lake Protection Water Supply Protection. Conservation Planning