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<br />. <br /> <br />e <br /> <br />. <br /> <br />DRAFT San Juan Flow Recommendation Comments <br />May 8, 1998 <br />Page 4 of5 <br /> <br />a concern, and subject to the same criteria, then this should also be clearly stated in <br />the recommendations. If the criteria are applicable to the other gages, what criteria is <br />proposed to determine whether or not the recommendations have been satisfied? <br />13. The flow durations suggested do not appear consistent with durations suggested by <br />test flow operations at other reservoirs. For example, test flows at Glen Canyon <br />found that durations of three to four days were more than adequate to move fine <br />sediments. Furthermore, the test flows showed that fine sediments were deposited <br />along channel banks, not simply washed farther down the river bed. <br />14. What happens if there is a shortage to the flow recommendations? While the latest <br />thinking is to address this project-by-project during individual consultations rather <br />than as part of the flow recommendations, it still remains an issue in the program that <br />must be addressed. <br />15. How can flow recommendations even begin to logically move forward until the <br />technical reports supporting the recommendations are complete? Some of the <br />technical reports will not even be available until June 1998. <br />16. We are still in the process of exchanging irrigated acreage and hydrologic information <br />with Reclamation. Reclamation is still revising some of their irrigated acreage <br />information based on our data. Once they have completed that, we would like the <br />opportunity to run that data, along with data used for New Mexico, through our <br />CRDSS. The purpose ofthis is to make sure that we fully understand all the <br />assumptions. Until this is accomplished, we are not prepared to offer support for any <br />flow recommendations. Given the added time needed for the Biologists to complete <br />their supporting studies, there is clearly time for this further refinement and <br />comparison of the hydrology. We would also like it to be clear that we receive <br />adequate time to make our analysis once Reclamation has finished their revisions and <br />furnished them to us for review, even if that may further delay the final <br />recommendations. <br />17. The Biology Committee indicated that they would have a draft report available by <br />May I, 1998 for discussion at the May 18-19 meeting. As of May 8,1998 no draft <br />report was available. Therefore, public discussion should be rescheduled. <br /> <br />We are of the opinion that these questions need to be addressed and considered <br />along with the completed technical reports before any further actions on the <br />recommendations are taken. Furthermore, we believe that the public should have <br />adequate 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 />We have been directed by the Colorado Water Conservation Board to take no <br />actions that would formally adopt the flow recommendations, even in draft form, until a <br />public review of the recommendations has been completed. Such public review must <br />include: <br /> <br />. the technical reports supporting the recommendations; <br />