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<br />. ---- . <br /> <br />- <br /> <br />. <br /> <br />. <br /> <br />7/12/99 <br /> <br />Upper Basin Water Users Comments and Recommendations Regarding: <br /> <br />"Preliminary Draft Programmatic Biological Opinion for Funding and <br />Implementation of Recovery Program Actions and Water Depletions <br />in the Upper Colorado River above the Confluence with the Gunnison River, <br />June 28,1999" <br /> <br />INTRODUCTION <br /> <br />The Upper Basin water users have reviewed the preliminary draft biological opinion (June 28, 1999) <br />and offer the following comments and recommendations for discussion at the July 19, 1999 meeting <br />with the entire Colorado River Biological Opinion discussion group. The comments also address the <br />need for clarification by Bureau of Reclamation regarding actions included in and related to the <br />biological opinion. <br /> <br />COMMENTS AND RECOMMENDATIONS <br /> <br />1. Flow Recommendations. Water users recognize the Service's modification in the biological <br />opinion which states that providing "adequate flows...in combination with other recovery activities" <br />will achieve recovery, rather than providing recommended flows. Water users' main concern is how <br />the flow recommendations will be used in future Section 7 consultations on existing and new projects. <br />This concern is related to I) the flow recommendations will not be met in many years, as <br />acknowledged in the biological opinion; 2) on p.17 of the 6/28/99 draft, the Service asserts that it will <br />continue to work with proponents of new projects to minimize impacts and "look for opportunities <br />to provide hydrologic conditions to benefit the endangered fishes." and 3) in the past there has been <br />a problem with implementation of Section 7 consultations in the field where lack of clarity exists in <br />guidance documents. Water users are concerned that the Service, in the informal consultation <br />process, will attempt to require hydrologic modifications to meet the flow recommendations, despite <br />the fact that the Recovery Program is designed to offset depletion impacts of projects in the basin in <br />development of recovery actions; <br /> <br />As a result of these concerns, water users make the fOl~reCOmmendations:, ~ ~~ <br /> <br />Suggested language changes: ~.:? iu ~,c <br /> <br />Page 17 - first full 'If / <br />..R ~rvice will continue to work w/hproponent fnew water projects to minimize <br />- ~roject impacts and look for.opportunitie to benefit the endangered fishes. It <br />is the intent of the Service to work with project proponents du' design and <br />development of operating criteria to help the project minimize it direc impacts on <br />recovery efforts. <br /> <br /> <br />~ ~ ')icfJ . <br />W ~n\l:;eJ7~i<>Y- <br />