BOARD02476

• Board Meeting Date: 9/13/2004
• Description: CWCB Director's Report
• Board Meetings - Doc Type: Memo

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THE SOUTHWESTERN WATER CONSERVATION DISTRICT

A Municipal D.strict OrSanized Under Stale La,,' For Devclopmem And Con!>ervation Of The Waler5 In The
SA.~ JUAN Al"D DOLORES RIVERS AND THEIR TRIBUTARIES
I !'I SOUTHWESTERI, COLORADO

West Building - 841 Second A venue
Post Office Box 475
DURANGO, COLORADO 81302
[phone]' Fax [phone]

RECEWEO
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AuguSl 23, 2004

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Rod Kuharich, Director
Colorado Water Conservation Board
1313 Sherman Street, Room 721
Denver CO 80203

Re: "Riverine Fish Flow Investigations" Report by Richard Anderson

Dear Rod:

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The Southwestern Water Conservation District (SWCD) has reviewed the "Riverine Fish
Flow Investigations" (Report) prepared by Richard Anderson for the Colorado Division
of Wildlife (CDOW) in June of 2003. SWCD understands that the primary purpose of
the Report is to provide technical guidance to the CDOW and the Colorado Water
Conservation Board in the evaluation of stream flows for the recovery and maintenance
of endangered fish and evaluation of other native species. The SWCD has concerns
about the use of the Report for other purposes, as explained below.

1. Although the original concept for the Report was to provide a better method for
determining flow recommendations for the recovery of endangered fish, SWCD is
concerned with the use of the Report methodology until there is a proven connection
berween high flows and the recovery of endangered fish. Tll dare, mimicking oL,atur"l
flow has NOT resulted in any improvement of endangered fish numbers and, in fact,
may, at best, be neutral to recovery. SWCD believes that a methodology that
recommends high spring flows be considered, but not implemented, until actual fish data
conclusively connects mimicking natural flow with the recovery of endangered fish.

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2. The Report methodology has the potential to be used by CD OW to evaluate flows
for CWCB Instream Flow ("ISF")Water Rights filings. This methodology will result in
much larger ISF water rights filings than the current R2 Cross methodology, which will
significantly impact opportunities for water use in Colorado. For instance, the
methodology could be used on the Animas River to recommend a very large ISF which
could change a free, underappropriated river into a water critical basin.