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<br />..~~ <br /> <br />MRYNES,BRRDFORD&SHPS <br /> <br />ID:303-247-8827 <br /> <br />RPR 07'94 <br /> <br />14:35 No.016 P.20 <br /> <br />3 <br /> <br />. When the research flow requirements of the preferred alternative are <br />eX"lned, It becomes clear that the effect of the preferred alterna- <br />ttve would be very st.ilar to that of the Seasonally Adjusted Steady <br />Flow alternative. Thts should be presented In the [IS. <br /> <br />. Th. new preferred alternative does not meet the balance of resources <br />requirement contained In the draft EIS statement of purpose and need. <br />Western supports operational changes which science has determined to <br />have poslttve benefits to resources. Ve do not believe that the <br />preferred alternative provides sufftclent benefit to endangered fish <br />In exchange for the Impacts tt has on other resources, <br /> <br />. Western requests that Reclamation reconsider Its selection of the <br />preferred alternattve. The preferred alternative should be based on <br />sctentlfic knowledge and a balance among the vartous resources. <br />Tradeoffs among resources should not be made unless tdentlflable <br />positive beneftts clearly outweigh the negattve Impacts. <br /> <br />4. Some avenues of study which promise to yield significant Information <br />dtrectly appltcable to resource management goals have not bee~ pursued. <br />Vestern belteves that these studies would yield important sctentlflc <br />tnformatton, and should be intttated. <br /> <br />. Sandy beaches. are a resource of critical concern. Considerable <br />effort has been expended to study the effects of daily fluctuating <br />flows on beaches, but other questtons remain unanswered. What Is the <br />relative effect of wind and rain on exposed beaches compared with <br />fluctuating flow effects? How lIuch Impact does human use have In <br />moving sand towards the river? How significant Is beach erosion from <br />MOored rafts changing the nearshore currents over several consecuttve <br />hours? <br /> <br />. A critical question which must be answered Is whether or not high <br />flows define the ecosystell. . The effect occasional high flows will <br />have on the systea .ust b. detennin.d, regardless of whether they are <br />natural, beach building, or habitat maintenance flows. If high flows <br />do define the ecosystell, -resetting" It after each event, there Is a <br />very real possibility that management based on daily operations of <br />the dam is misdirected and Ineffective over the long term. At the <br />very least, the tradeoffs among resource costs and benefits must be <br />reddined. <br /> <br />5. Endangered fish Issues have recently come to drive the EIS process. <br />Western hiS Slveral concerns regarding endangered fish species. <br /> <br />. A risk assessment need. to be conducted Immediately on the anticipat- <br />ed r.sponse to chang.s In operattons by both native and non-native <br />splcles. If a scientific risk assessment Indicates that non-natives <br />would respond more favorably than native fish, then changing flows <br />would likely result in a net detriment to the endangered fish. <br /> <br />. Vestern believes that It Is too early to Implement the steady flow <br />'research called for in the preferred alternative. It is not yet <br />known how flshe. are responding to interim flow conditionsi WI <br />