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BOARD02443
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Last modified
8/16/2009 3:15:31 PM
Creation date
10/4/2006 7:15:16 AM
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Board Meetings
Board Meeting Date
5/11/1998
Description
WSP Section - Colorado River Basin Issues - Endangered Species Issues - San Juan Recovery Implementation Program - Proposed Letter Regarding Proposed Draft Flow Recommendations
Board Meetings - Doc Type
Memo
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<br />. <br /> <br />- <br /> <br />e <br /> <br />DRAFT San Juan Flow Recommendation Comments <br />May 8, 1998 <br />Page 2 of 5 <br /> <br />preliminary flow recommendations and an operating rule decision. The flow <br />recommendations are applicable to the mainstem of the San Juan River at the Shiprock <br />gaging station and on downstream. <br /> <br />The purpose of this memorandum is to inform the Coordination and Biology <br />Committees of concerns the Colorado Water Conservation Board and others have with <br />the draft preliminary flow recommendations. <br /> <br />Discussion <br /> <br />The draft preliminary flow recommendations were developed based on habitat as <br />defined by geomorphology and a statistical analysis of the historic hydro graphs defining <br />how often flows occurred that provided the desired habitats and functions. The <br />recommendations subsequently are designed to maintain those same statistical parameters <br />in the long term. <br /> <br />Concerns <br /> <br />Based on our review of the draft preliminary flow recommendations, we have a <br />number of questions and concerns. <br /> <br />I. How will the flow recommendations be implemented? Once flow recommendations <br />are adopted by the Coordination Committee, what public process will be followed to <br />determine which recommendations are a priority in a given year. The decision tree <br />proposed offers a good start for reservoir operations, but how does that fit with the <br />actual flow recommendations themselves. What opportunities exist for modification <br />of those decisions should hydrologic conditions change dramatically? <br />2. How will the flow recommendations be used? It appears that a Section 7 Agreement <br />similar to that developed for the Upper Colorado River Basin Program is in order. <br />3. How will the flow recommendations be administered or enforced? While an <br />enforcement agreement is already in-place, attaching frequencies and conditions that <br />would require a certain condition to be met at least "once in every some many years" <br />is impossible to administer on a real time basis. Frequencies can not be attached to <br />flow recommendations in a meaningful manner on a real time basis. Frequencies can <br />be useful in deciding how you will operate Navajo Dam in any given year. These <br />conditions can be evaluated either by looking back in time or by projecting <br />hydrologic conditions forward in time. In either case, as a practical matter there has <br />to be some difference given to existing hydrologic conditions. From our perspective, <br />the flow recommendations should not include either frequencies or a "once in every <br />some may years" condition. Rather they should consider current hydrologic <br />conditions and seek to accomplish certain priorities under various hydrologic <br />conditions. The decision tree provided for Navajo operations is a start, but it does not <br />provide priorities for the many parts of the flow recommendations and it is not clear <br />how hydrologic conditions that are occurring in the basin are considered. <br />4. How will you determine whether or not the flow recommendations are satisfied? If <br />the flow recommendations are not satisfied, how will projects be permitted or <br />
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