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Page 2 FEDERAL CANDIDATE SPECIES Flannelmouth sucker Catostomus Iatipinnis Roundtail chub Gila ro6usta Based on your letter and on a telephone conversation with Martin Miller of this office on November 17, 1994, we understand that the subject Technical Revision involves the drilling of a single borehole on the 100-year floodplain of the Yampa River. You stated that drilling of the borehole will require drilling equipment to cross the Yampa River and that the applicant proposes to cross at a riffle area used by a local rancher to move cows across the river. You also stated that a drill pad will be constructed but that no trees will be disturbed. Because it is located within critical habitat for the Colorado squawfish and within wintering habitat for the bald eagle, the project could affect these species. In addition, if it involves a depletion of water, the project would affect all of the listed fish species. The Fish and Wildlife Service believes that major causes for the decline of the Colorado squawfish, humpback chub, razorback sucker and bonytail include the effect of water depletion from the Colorado River and its tributaries. We believe that any action made possible by the project that causes a depletion of water from the Upper Colorado River Basin should prompt a "may affect" finding for the listed fishes and necessitate consultation under the Endangered Species Act. No information concerning water depletion was included in your letter. If the project does not involve a depletion of water, the implementation of appropriate precautionary measures could result in a "not likely to adversely affect" determination. The following are examples of such precautionary measures. 1. All precautions shall be taken to prevent the entry of contaminants into the river. All equipment must be cleaned and all oil leaks must be repaired prior to crossing the river. Fuel tanks and other materials which must be moved across the river must be moved on a truckbed or trailer (not on skids or suspended by cables from equipment). All materials produced by drilling shall be contained and prevented from entering the river. 2. The drilling pad shall not be located in a high flow channel or other area inundated by high spring flows. 3. Disturbance to trees shall be avoided. Disturbance to understory vegetation shall be minimized as much as possible. The Service does not have any site specific wetland information for the project area. We recommend that the area proposed for disturbance be inventoried for wetlands. If wetlands are proposed to be disturbed, the applicant should contact the Corps of Engineers regarding possible permit requirements.