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<br />~, <br /> <br />11. Environmental baseline. On p.39, the Service "assumes that the status of the species under <br />baseline conditions (virgin flow conditions) would be healthy self-sustaining populations of all four <br />species of endangered fish is in the action area (Rifle to Lake Powell). The Service assumes this <br />because populations of indigenous animals tend to remain stable under natural habitat conditions <br />where they evolve. However, the result of natural flow conditions with nonnative species in the <br />system is not known." <br /> <br />The Service has identified as one of the factors resulting in the decline of the species the presence of <br />nonnative species. The assumption for the environmental baseline includes the presence of nonnative <br />species, which is not part of the "natural habitat conditions where they evolve.". <br /> <br />The initial assumption stated above ("under baseline conditions. . . would be healthy self-sustaining <br />populations of all four species. . .") appears to contradict the fact that nonnative presence would <br />undoubtedly destabilize and jeopardize the populations of the four endangered species. Water users <br />question that "healthy self-sustaining populations" would exist in the presence of nonnative species, <br />given the documented impact of nonnatives on recruitment. The biological opinion should reflect <br />these impacts, and not leave the impression that return of "virgin flow" conditions, or, in fact, simply <br />improving flow conditions alone, would result in recovery of the endangered fishes. <br /> <br />12. Ap.'Pendix E. ,/' ( <.. .....J:r ~ <br />rV" /. [,..r.M'- It' <br /> <br />On page 62, a statement has been lldd~~ a positive response would require the adult Colorado <br />pikeminnow population to b/l, lOaj individuals in the Colorado River." This sentence should be <br />deleted from the text for the fuuowihg reasons: I) the criteria in Appendix E may change as a result <br />of continuing review of the methodology and a different number may apply, and 2) recently questions <br />have been raised by Service biologists regarding the carrying capacity of the Colorado River for <br />pikeminnow, which raises unresolved questions regarding whether a population of 1,100 can be <br />attained. The point is that the number may change based on changed procedures or new information, <br />and should not be locked in the text of the biological opinion. Also, the definition ofthe "Colorado <br />River" with respect to population goals is unclear, and may be inconsistent with the populations <br />defined in the recently finalized Recovery Program Genetics Management Plan. <br /> <br />Appendix E is still under review. Additional conunents may be submitted on Append E. <br /> <br />13. Description of scope. Water users believe the description of the scope of the biological opinion <br />could use some additional clarification. The scope described on pA of the opinion appears to be more <br />clear than other descriptions. <br /> <br />On page 5, first full paragraph, the statement is made that "The biological opinion does not address <br />direct physical impacts of new or existing projects (such as impacts of a new structure on critical <br />habitat);...." . The Section 7 Agreement (October, 1993) clearly states that RIP actions are intended <br />to provide the RP As for "depletion impacts of new projects and all existing or past impacts related <br />to historic projects with the exception ofthe discharge by historic projects of pollutants...." Historic <br />projects are those in place as of January 22, 1988. Therefore, the direct impacts of existing projects <br />as defined in this opinion (existing as of9/30195) which are also 'historic projects' per the Section <br /> <br />6 <br /> <br />~ ~"''1 <br /> <br />. <br />~,5 <br />r;~? <br />--~O JAr <br />7 <br />~ <br /> <br />. <br /> <br />0)~ <br />~-1 <br /> <br />. <br />