Biological Opinions - Bureau of Reclamation

elocation effort in Lake Ewauna to be sufficient to minimize adverse effects of entrainment and
additional propagation will contribute to improving baseline conditions.
10.5 Conclusion for LRS and SNS
After reviewing the current status of the LRS and SNS, the effects of the proposed action and the
cumulative effects, it is the USFWS’ BiOp that the continued operation of the Project for a 10-
year term is not likely to jeopardize the continued existence of the LRS and SNS or result in the
destruction or adverse modification of their critical habitat. This BiOp does not rely on the
regulatory definition of “destruction or adverse modification” of critical habitat at 50 CFR
402.02. Instead, we have relied upon the statutory provisions of the ESA to complete the
following analysis with respect to critical habitat. The USFWS reached this conclusion based on
the following finding, the basis for which is presented in the preceding Status of the Species
(section 7), Environmental Baseline (sections 7 and 9), Effects of the Action (sections 0 and 9),
and Cumulative Effects (sections 8.6 and 9.4) of this BiOp.
10.6 Basis for the Conclusion Regarding Jeopardy for LRS and SNS
The USFWS’ non-jeopardy determination for the effects of the proposed action on the LRS and
SNS is based on the following. Going into the consultation, it was clear that the status and
environmental baseline of the LRS and SNS was highly degraded, so that even small adverse
effects to the species were likely to reduce their viability. Therefore, extensive coordination
between Reclamation, NMFS, USFWS, and stakeholders occurred during the 2 years leading up
to development of the proposed action. That effort resulted in a proposed action that includes
higher seasonal UKL elevations and greater certainty that elevation goals would be met
compared to previous proposed actions. However, substantial adverse effects would remain that
could not be further minimized by modifying water management, such as entrainment at the Link
River Dam. Consequently, we worked closely with Reclamation to propose specific
conservation measures that would likely be most successful in further minimizing adverse
effects. The goal of the conservation measures was to minimize the remaining adverse effects of
the proposed action on population viability, thus making the action compatible with the survival
and recovery needs of the species. The two most important conservation measures, relocation of
adult suckers from Lake Ewauna to UKL and controlled propagation, would provide both an
immediate increase in the reproducing adult sucker populations in UKL and also provide longer
term production of large juvenile suckers that would likely survive and recruit into the adult
populations during the term of the BiOp. Thus the adverse effects of the action on LRS and SNS
could be minimized initially as well as over the term of the BiOp.
The USFWS anticipates that the controlled-propagation program and relocation program will
minimize the effects of the proposed action such that appreciable reductions in the likelihood of
both survival and recovery of LRS and SNS will not occur. This is based on the proposed
funding levels coming from Reclamation, our expertise in fish culture and health, experience we
have gained in rearing LRS and SNS, and knowledge we can use from other similar efforts that
have successfully raised imperiled suckers similar to the LRS and SNS. Reclamation and the
USFWS have also had experience salvaging and relocating fish with a high survival rate so we
expect the relocation of suckers from Keno Reservoir to UKL to be successful and this will be
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