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t:' ~I Mr. Lee J. McQui vey April J.J., J.994 Page 6 " <: ~ ,. variable for the humpback chub and its possible expansion in the main stem of the Colorado River. We do not intend to outline the detail of our comments on the draft biological opinion here. We would merely incorporate them by reference and attach them for the record (Attachment 2). Suffice it to say that the inalterable conclusion has to be that the temperature of the water in the main stem of the Colorado River is ~ environmental factor which prevents the humpback chub from expanding its range so as to establish a second breeding population within the Grand Canyon. Since that is the goal of the Fish & Wildlife Service and the sine qua non for removal of jeopardy to this species, the existence of the Dam itself, which causes the water temperature phenomenon, is the source of jeopardy, and not the operation of the Dam. ~. ." ~~., ~. " .> Under these circumstances, Section 7 consultation concerning the operating criteria alternatives is reduced to suggestions related to various alternatives and not a potential jeopardy opinion related to any of them. This is also consistent with the finding on page 304 of the draft environmental impact statement that the only unavoidable adverse impact for the preferred alternative is the loss of hydropower generation. " .'1 , The final environmental impact statement should recognize that the problems of the humpback chub are beyond the scope of this environmental impact statement and its defined focus upon operating criteria alternatives. THE DRAFT EIS FAIlS '1'0 PROPERLY DISCLOSE A NUKBER OF SIGHIFICAH'l' DlPACTS i ..:~ ~. .. ~ .~. ~!:. :"j " t ~,~ f ~ ?~ We are greatly concerned that the potential adverse impacts of the habitat modification flow and the habitat building flow are not adequately described in the draft environmental impact statement. The building of Glen Canyon Dam and the operation of fluctuating flows has created a richer riparian environment in the Grand Canyon than it has ever previously experienced. Because extremely high volume annual floods are no longer possible, large areas of marshland and associated wildlife have sprung up in the Canyon. The endangered peregrine falcon is recovering dramatically. The endangered bald eagle is now wintering in the Canyon. Other endangered and threatened species have been beneficially impacted. All of these species stand to lose ground when faced with these artificial floods. The extent and duration of those losses has not been described in the EIS. The same is true for the proposed endangered species flows, which would be radical departures from anything approaching the current interim operating criteria. . ~:.