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<br />r","'... <br />'-'.'. <br />~~)l. <br />.~.: . . <br /> <br />3464 <br /> <br />Maryanne C. Bach <br />Brian Person <br />October 6, :2000 <br />Page 8 <br /> <br />maerwise authorized diversions ;.f necessary to meet tae needs of the endangered <br />species, <br /> <br />In this case, however, no alteration is necessary to previously entered <br />eontracts in order to allow Reclamation co comply with its ESA obligations The <br />discontinuance of the non-eharge program and the required utilization of the CBT <br />East Slope storage decrees do not eontravene any of Reclamation's contractual <br />obligations and, in fact, are required by its Senate Document 80 contract and its <br />Section 7 duties. As demonstrated above and through the attached materials, these <br />results ean be aehieved and native water allowed to remain in the Colorado River <br />Basin for the benefit of the endangered fish without impairing CBT Project supplies <br />for contract allottees, <br /> <br />If Reclamation does :tot cause the CBT Project to contribute meaningfully [Q <br />the PBO spring peak enhancement requirements, there is a very real risk that the <br />endangered speeies recovery will be seriously delayed or defeated, resulting in failure <br />of the December 1999 PBO, Because Reclamation has a vested interest in the <br />suecess of the Recovery Program (including th,e attainment of the flow eomponents <br />of the Recovery Aetion Plan), as well as an obligation under Section 7 of the ESA to <br />participate in it, eonsideration of the Senate Document 80 requirements for operation <br />of the CBT Projeet as deseribed above should be given the highest priority, <br /> <br />The River District is panieularly eoncerned at thiS point in time with the <br />continuation of unauthorized spring peak diversions from the West Slope in the <br />absence of demonstrated need for supplemental irrIgation or domestie water by CBT <br />Proj ect eontract allottees. Unused non-eharge water is now contributing substantial <br />amounts to the South Platte River flows, In addition, the failure to utilize the Big <br />Thompson native water for filling Horsetooth Reservoir and Carter Lake results in <br />more unused South Platte River water during the spring peak period, further <br />eontributing to the Plane River flows, Both of these aetions are contributing [Q <br />artificially high flows lower down on the Platte River at a time when FWS, <br />Reclamation, and the three affected states are establishing baseline conditions which <br />will b'~ used to identify, implement, and evaluate reeovery measures for listed Platte <br />River'species <br /> <br />The River Distriet has expressed its very serious concerns about the operation <br />ot' the CBT Projeet, and doeumented them in writing, on several occasions in the <br />