Dorothy Harvey correspondence, 1975-1977

Page 20

2. problems in implementing the Agreement. Ommitting projections of conflict after 199*1 a when the Strawberry Collection System is to be complete, and demand for water developed. The only guaranteed water supply for instream flows, in this Agreement, is that 22,300 a f to be allocated by the Dis­trict. Ommisslon of graphs or specific documentation of the monthly hydro-logical and biological requirements to retain 50% adult trout habitat. Models of criteria for specific fish habitat is developed at Ft. Collins by U.S.Fish & Wildlife Service. It is applicable to Uinta Rivers, was used by Utah fisheries biologists in their com­putations. To avoid differences in Agency methodologies as well as subjective opinion Jn interpretation of the Agreement, specific in­formation about each and all fish species in each river should be stated. This can be done in graph form, reducing the amount of data. This could clarify the many questions of all water users. Ommission of specific information on consequences of reducing normal stream flows to limitations of 44,400 a f annual flow on~rlparian vegetation, on wetlands, and on floodplains. These all provide wildlife habitat in the National Forests. Interior Department Water Policy Task Force Reports on Instream Flows state that a criteria of the amount of flow is that biological function of the river must be maintained for wildlife habitat. Topographic and hydrologic features of the Uinta Range are such that a variety of riparian vegetation, wetlands and flood-plain types are found at all elevations. And, wetlands are not always associated with floodplains. My inquiry to the Water Resources Council on Guidelines for evaluating these resources brought forth the statement that wetlands features on the Uintas are rare, in this respect. Inasmuch as the Forest Service is responsible for management of wildlife habitat, terms of the Agreement entirely ommit this aspect of the river resources and, in so doing, ignore existing legislation and an Agencyfs obligations relevant to this. This Agency, in pursuit of its mandates, has already carried out extensive research on habitat related to wet and dry meadows which follow alongside the river's flowage in relation to forest cover on adjacent ridges. This Agency is required to locate and evaluate wetlands and floodplains, as habitat conditions, to implement a purpose of the Water Policy - protecting wildlife habitat. Ommission of hydrological requirements for kayaking on Uinta rivers involved in CUP developments. ' Information on Class and Grade evaluations of rivers under consideration in this Agreement, part of the mapping and classifying of all Uinta Rivers by Les Jones, kayaker, Heber, Utah, is attached. Mr. Jones considers many Uinta rivers the equal to many more well known kayaking rivers in the west. While the Forest Service, again, is responsible for recreation resource management of most of these rivers, I see no consideration of their hydrological needs for kayaking in the Agreement. Again, water sports such as kayaking are stated in Task Force Reports on Instream Flows as necessary considerations for uses of rivers. In making an Agreement relative to a public lands area having national significance for its wildlife, wilderness, and recreation resources, limiting concerns of the Agreement to in­stream flows to retain 50$ historic adult trout habitat for four out of nine rivers, is unacceptable. Ommission of any indication what part of the 136,000 a f of water to be transported through the Strawberry Collection System still- belongs to the Ute Indian Tribe and what consequences of the end of the Compact term, the year 2,005, will mean for instream flows. Since no mention is made of this situation in the Agree­ment, the assumption is made that Utah claims clear title to all 136,000 a f of the transbasin diversion water.