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United States Department of the Interior <br /> <br />BUREAU OF LAND MANAGEMENT <br />White River Resource Area <br />73544 Highway 64 <br />Meeker, Colorado 81641 <br />Ls Reply Refer To: <br />3598 <br />COC 0118(329) <br />COC 0118(328) <br />May 31, 1999 <br />Ms. Sue Moyer <br />U.S. Fish and Wildlife Service <br />Ecological Services <br />Western Colorado Office <br />764 Horizon Drive, South Annex A <br />Grand Junction, CO 81506-3946 <br />Dear Sue, <br />. The BLM's White River Field Office would like to respond to questions and issues raised by <br />your office during review of our Biological Assessment for the Yankee Gulch Sodium <br />Minerals Project (i.e., American Soda) of 29 April 1999. Though this letter, we wish to <br />amend our previous Biological Assessment requesting an overall "no affect" concurrence to <br />one that initiates formal consultation. This need is based on a reversal of our previous fmding <br />of "no affect" for the Colorado River fishes to one of "may affect"; our fmdings for other <br />species considered in the original Biological Assessment remain unchanged. <br />BLM's previous assumption that the Unocal water rights purchased by American Soda and <br />their effect on endangered fishes were adequately considered in past Section 7 Consultation <br />(1985) was inconsistent with complete evaluation of potential impacts to the more recently <br />listed razorback sucker and influences on critical habitat designated on the Colorado River in <br />1994. This amendment also allows us to integrate refined project-related water handling and <br />use information as a means for more thoroughly exploring the potential for direct impacts to <br />endangered fish and future recovery activities. <br />This amendment will also serve to address topics that Terry Ireland had raised eazlier in this <br />process, namely: clarifying our position and analyses for 1) listed plant survey and protection <br />(attachment), and 2) water use and depletion calculations. <br />In the following text, the "Proposed Action" section provides details or material not included <br />in the original Biological Assessment. This new information forms the basis for a revised <br />Biological Assessment for the Colorado River fishes. The later `Biological Assessment" <br />section and its fmding of affect is intended to supersede that provided in the original <br />Biological Assessment. <br />