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<br />e <br /> <br />- <br /> <br />e <br /> <br />8. Instream flow demands: <br /> <br />A. The Recovery Program needs to accept that development of compact entitlements will <br />take place. Recovery actions must incorporate compact development, and recognize that <br />USFWS' flow recommendations have a limited role in recovery relative to other actions <br />such as stocking and nonnative control measures. <br /> <br />Rationale: U.S. Fish and Wildlife Service biologists have developed flow recommendations for I) <br />practically all of the developable water that is remaining in the rivers, or 2) more water than is <br />presently in the rivers. In conducting Section 7 consultations, USFWS asserts that the <br />recommendations are requirements, even though there has been no demonstration that the <br />recommended flows are necessary for recovery of the fish. Such flow recommendations have <br />been developed for the IS-mile reach, the Yampa River, and the Duchesene River. Assertions <br />that the fish need all the remaining water or more than the remaining water available, would mean <br />the Recovery Program cannot succeed, and contradict the goals of the Program. The Recovery <br />Program is designed to recover the fish while the states develop their full compact entitlements. <br />The flow recommendations should be recognized as recommendations, not requirements for <br />recovery . <br /> <br />USFWS should acknowledge the uncertainty in these "flow recommendations," and their <br />limitations relating to other factors affecting recovery. At best, the USFWS flow <br />recommendations represent a first cut based on descriptive analyses, rather than documented <br />cause and effect relationships. The razorback sucker is endangered because of nonnative <br />predation oflarvae and young fish, not lack of flows. The reasons for the bonytail chub's demise <br />in the upper and lower basins are unknown. Humpback chub populations are stable. <br /> <br />In developing the high flow recommendations for the I S-mile reach, no consideration was given <br />to the impact of flows on depressing temperatures, and the subsequent inability of Colorado <br />squawfish to spawn at low temperatures. In this respect, and without justification, the 1995 flow <br />recommendations reverse the rationale of the 1989 flow recommendations. Backwaters and <br />ponds have very low flow rates and can be designed to function under low flow conditions. <br />Inherent in the flow recommendations is the assumption that if the flow recommendations are <br />achieved, recovery will also be achieved, and without the flows, recovery cannot be achieved. <br />There is IlQ evidence that this will be the case. On the contrary, given the abundance of nonnative <br />fishes in the system, this hypotheses may never be tested. The Program should concentrate on <br />removing nonnative fish, the most obvious limitation, begin stocking endangered fish, and only <br />after that, identifYing and protecting more flows. <br /> <br />The proper use offlow recommendations at this time is by the Colorado Water Conservation <br />Board and Utah officials to consider in determining how much water may be allocated to <br />endangered fish, while still allowing each state's compact entitlement to be developed. <br /> <br />B. The Recovery Program must focus on recovering the endangered fish, not the IS-mile <br />reach. <br /> <br />6 <br />