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174 , ordinarily stressful times for fish populations. The red*ctions in flow, without additional mitigation, will increase stresses on the brook trout, resulting in loss of population. , 22. The snowmaking project will reduce available $pawning habitat for brook trout, who spawn in the fall. The Forest Service found that in an ~verage year, the project would reduce spawning habitat by close to 30%. In a wet year, even!with the mitigation impOSed by the Forest Service, the loss would be substantially more. i 23. In addition, the snowmaking project will reduc!) and degrade over-winter habitat for resident adult and juvenile trout throughout the periodlduring which water withdrawals would occur. Such reductions and degradation will occur bel/ause the North Fork will be more shallow and more narrow. Ice formation detrimental to fish is )ikely to increase, and food production decrease as a result. These adverse effects on habitat ~ay result in significant additional over- winter mortality for the resident brook trout populatiojt. 24. The A Basin snowmaking project received a special use permit from the White River National Forest. As part of the. special use permit process, the Forest Service reviewed whether the habitat loss in the North Fork associated with the snowmaking project would violate the standards in the White River National Forest Manageinent Plan. The Forest Service permitted the'project because the White River National Forest Management Plan allows the Forest Service .4111 to permit activities that will cause up to a 30% loss o:l!habitat. This standard is not based on any . ~ state water quality standard, however, but is simply a 'standard set in the White River Plan. 25. Because Dundee's project will involve dredge and fill activity, it also requires a permit from the U.S. Army Corps of Engineers pursuant to Section 404 of the Clean Water Act. Issuance of such a permit requires compliance with S~' tion 401 of the Clean Water Act. Consequently, the Corps and the Division jointly not fied the public that Dundee had applied for a Section 404 permit and an accompanying Section 4, 1 certification. In comments on the applications, TU and Colorado Wild explained the w~ter quality violations that Dundee's project would cause, and suggested several means of mitigating those water quality impacts. 26. Despite the fact that the Division conceded D,undee's snowmaking project would exacerbate water quality violations in the Snake and ~egrade aquatic habitat in the North Fork, the Division's November 21,2000 certification statep that the project will comply with all applicable Colorado water quality standards. The certification also states the snowmaking project would not violate the antidegradation regula~on. With respect to the exacerbation of water quality standards violations in the Snake, the certification states as follows: , These projected increases in metals concentr~tions do not preclude a Division determination that the project will comply with "all applicable provisions of the Basic Standards for Surface Waters, ... surface... ;water classifications and Water quality standards.,." Because the minor increases qf existing metals concentrations in the l i 6 .