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<br />Development of an action plan to help ensure continued existence of <br />the few, if any, razorback suckers in Grand Canyon is unrealistic <br />and unnecessary for tbeir continued survival. <br /> <br />* Razorback suckers are typically found in slower river <br />reaches, flooded backwaters and bottomlands. The Grand Canyon <br />is the antithesis of the ideal Razorback habitat and probably <br />was only used historically as a migration route. <br /> <br />* An action plan risks diverting activity and resources from <br />ongoing and more productive recovery efforts elsewhere. <br /> <br />* An action plan may be conceived involving changes to dam <br />operations which may conflict with operations believed needed <br />to benefit other resources. Such potential for conflict is <br />unnecessary and unwarranted. <br /> <br />,. <br /> <br />Further Studv of Selective Withdrawal <br /> <br />Further study of a Selective withdrawal structure for Lake Powell <br />has been incorporated as a Common Element. We question its <br />inclusion here because: <br /> <br />; <br />y. <br /> <br />'f <br /> <br />- The proposal would require legislation; <br />It has nothing to do with water release patterns; and <br />- It is a study of a proposed response to a dam existence <br />impact. <br /> <br />,. <br /> <br />'. <br /> <br />We do not question the need for the study; however, we believe it <br />is a separate inquiry. <br /> <br />Due to the extreme high costs, every effort should be made to <br />establish the efficacy of a selective withdrawal program for Lake <br />Powell waters before implementing a project for selective <br />withdrawal. <br /> <br />,~ <br /> <br />:~, <br />(. <br /> <br />t: <br /> <br />* The benefits to native and nonnative fish predators as well <br />as the risks to endangered fish must be assessed <br />simultaneously. <br /> <br />* Warm water releases from the dam as part of an endangered <br />fish mitigation program should be assessed witl1 other critical <br />elements as part of the Adaptive Management Program to be <br />implemented after the Record of Decision. Doing otherwise by <br />approaching this as an independent habitat component would <br />have no relevancy to reality and could not be combined later <br />with other components. <br /> <br />* Presently, no models exist to help the Bureau determine <br />incremental relationships between temperature and other river <br /> <br />:~ <br /> <br />.;.: <br />.1.. <br /> <br />15 <br />