WSP01249

• File Number: 8220.106
• Description: Animas-La Plata
• State: CO
• Basin: San Juan/Dolores
• Water Division: 7
• Date: 1/1/1990
• Title: Correspondence regarding the Final Biological Opinion - 1991
• Water Supply Pro - Doc Type: Biological Opinion

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the BIA and the various Indian tribes likely to be affected by the outcome of
the alternative development process have attended meetings of the ALP
alternative development group. We believe the BIA and tribal representatives
are fully aware Of the ongoing process. To facilitate the BIA's request to be
party in the consultation process, their representatives will be requested to
attend future meetings between the respective agencies.

After reviewing the results of the process undertaken by the three teams,
which is presented in their meetin~ summaries and expressed in the development
of the Biology Team's alternative (Appendix 1), Reclamation independently
determined there is a biologically supportable, reasonable and prudent
alternative for the ALP. The development of Reclamation's reasonable and
prudent alternative, which we offer for your full consideration, has taken
into consideration the findings of the Biology Team (Team) and is in keeping
with our responsibilities under Section 7 of the Endangered Species Act to not
take actions which are likely to jeopardize the continued existence of the
endangered fish of the San Juan River and to promote the recovery of the
species and their habitat.

In the development of Reclamation's alternative, consideration was also given
to the States' alternative which was presented at a meeting of the San Juan
River group on November 19, 1990. While certain items of their alternative
have elements that are consistent with Reclamation's alternative, it contains
items that make it unacceptable, These elements were also unacceptable to
the Biology Team. The following Comments on the States' alternative are
offered for your information.

State Alternative

Reclamation agrees with the Team that the States' alternative is unacceptable
for the following reasons:

. ,~~s' 1. The alternative does not call for mimicking of the natural hydrograph~ F(
l'1'j:,\::f in perpetuity or returning the San Juan River to more favorable flow .
~1 f>'+-' conditions for the native and endangered fish. These are essential to ofFset )
~~~~ the impacts of any diversion for the ALP.

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2. The identified amount of water available for the fish in the future is
not based on the biological needs of the fish. Until research is conducted to
identify the flow needs of the fish, which would also include the
quantification of available habitat, the acceptance of a specific quantity of
water to protect the fish is not biologically supportable.

3. The alternative calls for full development of the Animas.la Plata
project. However. hydrologic modeling of depletions associated with full
development of~heALP. (154,OOO~ versus only a depletion of 57,100 acre
feet (AF)~~llartosr9r1'if1carifl'y affect)Reclamation's ability to mimic the
natural hydrogra-ph'under current depletions.

4. The alternative assumes full compact depletion of the San Juan River
by the States of New Mexico and Colorado under the development and
implementation of a Recovery Implementation Program. It in effect
predetermines future Section 7 Consultations, and was, therefore, determined
to be unacceptable.

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