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<br />Agenda Item 18.c. v <br />March 10-11, 1998 Board Meeting <br />Page 2 of3 <br /> <br />. <br /> <br />3). The flow recommendations are applicable to the mainstem of the San Juan River at <br />the Shiprock gaging station and on downstream. <br /> <br />The purpose of this memorandum is to inform the Board of the direction the flow <br />recommendations are going, some concerns staff and others have with the draft <br />preliminary flow recommendations, and solicit input and direction from the Board. <br /> <br />Discussion <br /> <br />The draft preliminary flow recommendations have been developed based on <br />habitat as defined by geomorphology and a statistical analysis of the historic hydrographs <br />defining how often flows occurred that provided the desired habitats and functions. The <br />recommendations subsequently are designed to hopefully maintain those same statistical <br />parameters in the long term. <br /> <br />Staff has tentatively reviewed the draft preliminary flow recommendations and <br />have a number of questions related to how the recommendations would be implemented, <br />used, and enforced. In addition, if the flow recommendations were not satisfied, how <br />would projects be permitted or otherwise allowed to go forward? Also, the shortage issue <br />should be addressed as part of the recommendations. <br /> <br />. <br /> <br />Currently, the biologists are generally pushing for peak flows of 8,000 cfs or more <br />for up to 10 days and in addition working on attaching frequencies to how often the flows <br />should occur. These recommendations are moving forward absent the completed <br />technical reports that are needed to fully support the recommendations. At least some of <br />the technical reports will not be available until June 1998. <br /> <br />Staff is of the opinion that these details need to be addressed and considered along <br />with the completed technical reports and recommendations before any further actions on <br />the recommendations are considered. Furthermore, staff believes that the public should <br />have an opportunity to review and comment on the recommendations, there use and <br />enforcement while the recommendations are still in a preliminary form and prior to any <br />actions to adopt the recommendations by either the Biology or Coordination Committees. <br /> <br />Recommendation <br /> <br />Staff recommends that it be directed to take no actions that would formally adopt <br />the flow recommendations, even in draft form, until a public review of the <br />recommendations has been completed. Such review to include: <br /> <br />. <br /> <br />I. the technical reports supporting the recommendations; <br />2. an agreement on procedures for Section 7 consultations that includes direction <br />on the implementation, use and enforcement of the recommendations and the <br />role of the Recovery Program in providing the reasonable and prudent <br />alternative; and <br />