of the reregulating facility. Its cost to taxpayers will be slightly in excess of 

 $2'a million. 



To what extent the Corps of Engineers will attempt to carry out other activities 

 related to the construction of additional generating units and the reregulating facil- 

 ity is speculative at this point. But, the decision to proceed with the haul bridge 

 is an indication that a piecemeal approach may be forthcoming. Such an approach 

 would be in conflict with the intent of the Endangered Species Act and that portion 

 of the Code of Federal Regulations which establishes procedures for good faith inter- 

 agency consultation and a biological opinion befor an irreversible or irretrievable 

 commitment of resources is made. 



Fluctuation Criteria and Discharge Limits 



Presently, operation of the four 105 megawatt generators in Libby Dam is re- 

 stricted by the following discharge limits and maximum fluctuation criteria: 



1. A minimum instantaneous discharge of 2,000 cfs. 



2. Maximum fluctuations of one foot per hour, four feet per day. May 

 through September; two feet per hour, six feet per day, October 

 through April . 



According to representatives of the Corps of Engineers, those fluctuation cri- 

 teria and discharge limits were established following consultations with the Bonne- 

 ville Power Administration, the U.S. Fish and Wildlife Service and the Montana De- 

 partment of Fish and Game. The criteria are admittedly a compromise. 



Originally, the Fish and Wildlife Service, in concurrence with the Department 

 of Fish and Game, recommended the following discharge limits and maximum fluctuation 

 criteria: 



1. A sustained flow in the Kootenai River of not less than 2,500 cfs 

 (as measured at the dam). 



2, A rate of change of water releases should be made as gradually as possible 

 and should not exceed 1 foot per hour as measured at a point just upstream 

 from the confluence of the Fisher River. 



These recommended criteria, according to the Fish and Wildlife Service, were in- 

 tended to minimize the detrimental effects to aquatic organisms, as well as decrease 

 hazards to anglers. 



Streamflow records for the Kootenai River are available from 1911 through the 

 present. The average annual discharge, as measured at Libby before impoundment was 

 12,070 cfs. The maximum recorded discharge was 121,000 cfs on June 21, 1916. The 

 minimum was 895 cfs on January 11, 1930. Regulation of the outflow through Libby 

 Dam has, of course, changed the seasonal flow patterns. In fact, a reversal of the 

 natural flow regime is inherent in peaking hydropower operations and such a reversal 

 has occurred below Libby Dam. With a reregulating dam, it is estimated that down- 

 stream flows during the period of November through March would be about 15,000 cfs 

 higher than historical flows for the same period. The present operation of Libby Dam, 

 which allows for peaking in the absence of a reregulating reservoir, is problematical 

 and may in fact be in violation of earlier agreements. In any case, during the first 

 two years of Libby Dam's operation, numerous violations of the criteria established 

 by the Corps occurred. 



Discharges from the main dam into the proposed reregulating reservoir would be 

 determined largely by power generation schedules. With eight 105 megawatt genera- 

 tors in the main dam operating for peaking power production, those discharges would 

 vary from a low of less than 1,000 cfs--sometimes almost zero flow--to as much as 



