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<br />the long-tenn integrity of the KAS population.
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<br />The lowest KAS population observed during 1995 by Stevens, et al., occurred in
<br />March, 1995. Thus, natural winter mortality from November, 1995 to March,
<br />1996 may reduce the percentage of take on KAS considerably. This would reduce
<br />the potential number of individuals lost during the test flow, and the impact
<br />to the Vaseys Paradise KAS population.
<br />
<br />Test flows are scheduled to begin on or about 22 March, 1996. Stevens, et al.
<br />found 6.3t of KAS examined on March 30, 1995, retained mucosal plugs,
<br />indicating that the population was just completin9 emergence from winter
<br />dormancy at that time. It is reasonable to assume similar conditions will
<br />exist in March, 1996 if weather patterns are' similar, although early wanning
<br />may affect the emergence of the KAS.
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<br />The following analysis is based on the data collected by Stevens, et al. If
<br />KAS distribution in March, 1996, is equivalent with March, 1995, only 3.3 t of
<br />the KAS population will be affected by the test flow. If primary habitat in
<br />March 1996 is equivalent to primary habitat in March, 1995, 14.6t of the
<br />habitat will be assumed lost due to scour during the test flow, which exceeds
<br />the level of incidental take.
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<br />In the Stevens, et al. report, potential loss of habitat and KAS was estimated
<br />to be as much as 16.1t of the primary KAS habitat and 11.4 to 16.4t of the
<br />estimated population. This estimate was based on the summer, 1995 data. This
<br />data is displayed in a table in the report as having been collected in June,
<br />1995. The actual amount of habitat and KAS affected by the test flow would
<br />most accurately be compared to the March, 1995 survey data considering that
<br />once the test flow begins, vegetation and KAS numbers below the 45,000 cfs
<br />stage will not increase. Appendix A indicated that 16.2 Mf of the primary
<br />habitat in March consisted of mixed patches of ~, Polvaonl~ and other
<br />species, which is defined as secondary habitat, which rarely contains KAS.
<br />This portion of the habitat should not be defined as occupied habitat in
<br />calculating the incidental take level. If these patches of vegetation were
<br />eliminated fonn the calculation of primary habitat, only 12.8t of the primary
<br />habitat is lost.
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<br />Considering that: 1) Stevens, et al concluded the Vaseys Paradise population
<br />of KAS appears to be relatively large and self-sustaining; 2) more than 40t of
<br />the present primary KAS habitat at Vaseys Paradise lies below the pre-dam 10-
<br />year flood stage of 3540 m'ls, most of which is new, post-dam habitat; 3) KAS
<br />have survived numerous flood events; 4) estimated loss KAS habitat contains
<br />only 3.3 t of the KAS population; 5) estimated habitat loss is 12.8 to 14.6t
<br />of primary habitat; and, 6) vegetation will have the opportunity to re-
<br />colonize the scoured area prior to and during the expansion of the population
<br />due to reproduction; we request the Service reconsider the allowable
<br />incidental take in tenns of a percentage of the population of KAS, as opposed
<br />to a per cent of KAS habitat. We acknowledge that take of any amount of an
<br />endangered species a matter of serious concern. Reclamation will monitor the
<br />population and its habitat both pre- and post-test flow, as required by the
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