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<br />it will achieve listing is uncertain. Downlisting of one of the four big flver fishes from <br />endangered to threatened is considered highly unlikely, <br /> <br />Other complications presented by this alternative include the facts that no incidental take is <br />allowed for endangered species under 4(d) , and only the State of California has the necessary <br />enabling legislation (in California's case, the Natural Community Conservation Planning Act) <br />authorizing conservation planning (in the form of the NCCP Act)'- It is considered unlikely <br />that Arizona and Nevada would pass such legislation, or that an MOU could be arranged <br />between the states delegating planning authority to California, Therefore this alternative has <br />been eliminated from further consideration, <br /> <br />2. Section 6 Authorization <br /> <br />Under this alternative, the States of Arizona, California, and Nevada would enter into an MOU <br />with the Service to use Section 6 monies for research, recovery actions, and monitoring. This <br />alternative has been eliminated because Section 6 funding of recovery actions does not inherently <br />provide incidental take authorization or an enhanced permitting process and consequently, would <br />not fully achieve the Steering Committee's goals. However, using Section 6 dollars as part of <br />another ESA compliance action, such as a RlP or an HCP, is a viable strategy, <br /> <br />7 California Fish and Game Code, ~ 2800, el seq" 1991, <br /> <br />FINAL REPORT <br /> <br />December 20, 1994 <br />Page x <br />