WSP09462

• File Number: 8240.300.03
• Description: San Juan River - Recovery Implementation Program - General Info
• Basin: San Juan/Dolores
• Water Division: 7
• Date: 8/11/1992
• Title: Issue Paper - Endangered Fish
• Water Supply Pro - Doc Type: Report/Study

AUG 11 '92 06: S7 TOl1 PITTS & ASSOC,

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QO Animas-La Plata Project: Unresolved issues regarding development
of the San Juan Basin Recovery Implementation Program.

1.0 INTRODUCTION

On October 25, 1991 U. s. Fish and wildlife Service Reglon 6,
Denver issued a final biological opinion on the Animas-La Plata
Project. That opinion calls for development of a recovery
implementation program for endangered fishes in the San Juan Basin
within one year. This was supported by a Memorandum of
Understanding signed by the Secretary of Interior and other
parties. The MOU laid the groundwork for development of the San
Juan Implementation Program.

2,0 UNRESOLVED ISSUES

1. U.S. Fish and Wildlife Service Region 2 unilaterally caused a
five month delay in development of the San Juan Basin Recovery
Program. Region 2's failure to resolve Program issues guarantees
further delays in the compliance with the Biological Opinion on the
Animas-La Plata Project, and possible non-compliance.

2. Elements of the Recovery Program proposed by Region 2 directly
contradict the Memorandum of Understanding signed by the Secretary
of Interior (attached).

3. There are substantial policy differences in implementation of
an existing Recovery Program by Region 6 and that proposed by
Region 2.

4. Region 2 is failing to implement the second purpose of the MOU
regarding to "proceed with water development in the Basin..."

5. Region 2 is attempting to exclude participation hI' the
Southwestern District on the ~oordination Committee, even though
the Southwestern District is a project sponsor of the Animas-La
Plata Project, and the Program that is being implemented to offset
the impacts of that project.

6. Region 2 adamantly refuses to consider water development or
Southwestern District participation on the Biology Committee of the
Recovery Program, for no valid reason whatsoever.

Details regarding these issues are provided below.

3.0 TIME DELAYS CAUSED BY U.S. FISH AND WILDLIFE SERVICE,
REGION 2

In anticipation of the biological opinion, numerous parties,
including u.s. Fish and wildlife Service Regions 2 and 6, Bureau of
Reclamation, states of Colorado, New Mexico, and Utah, Indian