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~ --...., MAYNES,BRADFORD&SHPS ID:303-247-8827 APR 07'94 14:34 No.016 P.19 2 co.petition and predation by introduced species. All of these pro.ising .easures are outside the present scope of this draft EIS. Vestern encourages Recla.ation to investigate the potential effectiveness of these measures to help recover endangered fish. . Flow modification can assist in beach maintlnance, at least in the short tenl. Long-tenl maintenance w;ll require mar. than changes in daily operations. Vestern believes that non-operational options such as vegetation .anage..nt, human use restrictions, raft mooring r.strictions, protection with native materials, and selectivl sedi.ent augmentation Rerit serious consideration. Combined with operational controls, thlY offer the most effective means for beach stabilization and maintenance. Such options have significant flexibility advantages; beaches could be placed or maintained where they are most needed. 3. Because of its creation late in the process, the preferred alternative and its effects have not been studied with the same level of intensity as the other alternatives. Unifo~ treatment of alternatives is essential for .ffective comparison of alternatives, and is reqUired by compliance with section 1502.14(a) and (b) of the Council on Environmental Quality regulat.ions. . Vestern is troubled by the process which lead to the selection of the preferred alt.rnative. After near total consensus on a preferred alternative was reached by the cooperating agencies, a new preferred alternative was created based on the draft Biological Opinion without input fro. ihe other cooperating aglncies. . lhe nlw preferred alternative is designed to postpone a jeopardy opinion with regard to endangered fish. However, since most of the factors limiting endangered fish are not related to flows, the alternatives have very similar effects on endangered fish. The new preferred alternative calls for test flows very different than thosl we have slln tn the past, and we are concerned that the possibll advlrse impacts to endangered ftsh are not known. Absent signtficant offsetting beneftts to endangered fish, the increased risk of impact is not Justifi.d. . Available scientific evidence does not demonstrate that the new preferred alternative wtll provide better conditions for endangered ftshes than the consensus alternative deftned by the NEPA process. Solid scientific information demonstrating definite benefits for endangered fish at least equal to the negative impacts to other resources should be available before this alternative is selected as the preferred alternative. . Much of the emphasis behind the development of the present alterna- ttves was on sediment, as it WIS agreed that sediment was the key resourcl tn the system, and that measures to conserve sediment generally benefitted other resources. We are concerned that the lat. shift tn emphasis to endangered fish may have rendered some provi- sions or assumptions of the alternatives obsolete.