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- . . Mr. A. Jack Garner 3 Since construction, the reservoir has been operated under a plan which eliminated peak flows (last spring-early summer) and increased flows during the low flow period (winter). The Fryingpan River below Ruedi contains little trout spawning habitat and, due to lack of sufficient scouring flows, the channel bottom is becoming armored. Maintenance of minimum instream flows below Ruedi by the Bureau has not been adequate to maintain this Gold Medal trout water at its potential. Under the Preferred Alternative and Preferred Alternative with Conservation Measures, the PHABSIM analysis indicates adverse impacts to be insignificant due to projected infrequency of dry years, and a balance with habitat increases during various months. However, PHABSIM cannot be directly correlated with fish population parameters. We recommend the Bureau develop a monitoring program to assess long-term impacts to both nongame and game fish habitats. Measures should be developed to mitigate any adverse impacts on fishery resources and their habitats on the Fryingpan River resulting from Round II Water Sales. In summary, it does not appear that the Bureau has taken a realistic approach in attempting to balance competing needs relative to the Round II Water Program. While we are aware of the Bureau's need to recover costs from construction and operation of Ruedi, it is critical that the needs of the local economy which is based on recreation, both boating and fishing, be considered. Considerable funds have been expended in constructing and maintaining recreational developments at Ruedi based on the Bureau's assurances that reservoir levels would be maintained at 86,000 AF from July 1 through Labor Day. Round II water sales, as described in the FSES, are not fully compatible with recreational and fishery needs. We recommend that the Bureau more closely assess its ability to provide the total volume of water available under Round II with protection of fish, wildlife, and recreational values. Selling less water at long-term realistic market values (20-40 year contracts) should be considered. We fully support the release of conservation flows from Ruedi Reservoir for maintenance of downstream endangered fish habitat. However, the Bureau must be flexible when determining what portion of the 46,500 AF of water available can be sold while still maintaining other values at acceptable levels. If you have any questions, please contact Robert Miller at (303)945-2521. Sincerely, ~ fr ~7'--~ " ,THOMAS A. HOOTS ~ Forest Supervisor s Caring lor the Land and Serving People F5-8200'28(T.821