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. . ~:;':;-;';.r~-:;~ ~I Mr. A. Jack Garner ~ ~ 2 July through September 10, while still supplying sufficient water for conservation of endangered fish habitat as recommended in the June 15, 1987 USFWS biological opinion. Under the Preferred Alternative with Conservation Measures, the Bureau would withhold 5,000 AF of water from the volume previously anticipated for sale to industrial users for conservation of endangered fish habitat. As part of this alternative, and additional 5,000'AF would be made available from Ruedi in the months of July through September. With the Green Mountain mitigation scenario described in Section 5.2, Ruedi would "maintain higher reservoir water elevation in nearly all months for all conditions." However, paragraphs depicted in Sections 5.3 and 5.4 do not seem to accurately reflect numbers developed in Table 2.1, which describe changes in elevation and volume at Rued i. With Green Mountain Reservoir prov iding 5,000 AF out of the 10,000 AF required for conservation of endangered fish habitat, it appears that adverse impacts to recreation would be lessened. This measure and its relationship to Ruedi Reservoir is not adequately addressed in the FSES. We believe the most significant impact to recreation at Ruedi Reservoir will occur from the sale of 46,500 AF of water with a peak demand period from July through October. Our primary objection to the FSES is based on the inadequate disclosure of this impact by emphasizing adverse impacts associated with conservation releases which will be partially mitigated through releases from Green Mountain Reservoir. This provides an all or nothing scenario which does not balance the need for marketing water to meet construction/operation costs of the reservoir with the economic value of recreation to the Forest Service and local economy. 2. Fish Habitat a. Ruedi Reservoir Reduction in water elevation during late summer/early fall as described in the FSES will adversely impact aquatic communities and would be the most critical in the shallow bays along the north shore. This area is important as rearing and feeding areas for trout as benthic macroinvertegrates and macrophyte communities are more abundant than in the deeper areas of the reservoir. In a dry year almost one-third of the littoral zone would be eliminated, but in all years there would be a reduction of at least 10 percent. In the long-term, abundance and size of resident fish species would be reduced. No long-term monitoring plan and mitigation measures have been provided in the FSES to offset impacts to fishery resources in Ruedi Reservoir. We recommend that mitigation measures be identified which enhance the dewatered areas through planting of appropriate vegetation to enhance fish and wildlife productivity of this area. b. Fryingpan River The construction of Ruedi Reservoir eliminated approximately seven miles of trout spawning and rearing habitat. We question whether adequate compensation/mitigation has, to date, been provided by the Bureau. Caring for the Land and Serving People FS.6200.2817-621