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<br /> <br />(F\.IEI <br /> <br />June 24. 1991 <br /> <br />sc <br />lAse <br />, <br />IF <br />/ <br />L <br />E <br /> <br /> <br />In Reply Refer To <br /> <br />United States Department of the Interior <br /> <br />FISH AND WILDLIFE SERVICE l'iR <br />FISH AND WILDLIFE ENHANCEMENT <br />UTAH-COLORADO FIELD OFFICE <br />2060 ADMINISTRATION BUILDING <br />1745 WEST 1700 SOUTH <br />SALT LAKE CITY, UTAH 841M-SIlO <br /> <br />c.J <br />o <br />r7.:> <br />,'.1) <br />~ <br />OJ <br /> <br />CWCB <br />JUN 2619fn <br /> <br />San Juan River Basin Recovery Implementation Program Interested Parties <br /> <br />RE: Review of Revised Sections of Recovery Implementation Program <br /> <br />Comments on the February 15. 1991 Draft of the San Juan River Basin Recovery <br />Implementation Program (RIP) have been incorporated into a second draft of the <br />Purpose. Background, and Organization sections for your review. Tom Pitts, <br />Mike Donahoo and I have decided to move forward on the revisions despite <br />uncertainties regarding completion of the San Juan Basin Memorandum of <br />Understanding, <br /> <br />We are transmitting only 3 of the 5 sections for your review at this time. We <br />will proceed with the other two sections shortly. As expected. some of the <br />review comments were at odds with regard to program organization, goals, and <br />species to be included. We would like to explain our rationale for our <br />proposed approach but are still willing to entertain any additional ideas of <br />critical concern, Therefore, we would like your second review to be "fatal <br />flaw" to help us reach consensus and move forward. <br /> <br />OrQanization <br /> <br />Most commentors believed the Service's role in the RIP was too controlling. <br />We have. therefore. modified language to allow interested parties to appoint <br />their own representatives without Service approval and to include more <br />consultation during the planning and implementation phases of the program. <br /> <br />In the proposed revision the Service retains the staff lead responsibility to <br />ensure that project proposals and plans are prepared. implemented, and <br />completed. We believe this is within Service authority and responsibility <br />yet not an attempt to be dictatorial. Bureau of Reclamation comments would <br />shift this responsibility to the Biology Committee. Colorado Water <br />Conservation Board comments would shift responsibility to a number of <br />technical and management committees for resolution (biology, hydrology, <br />instream flow, reservoir operations. etc.). We believe the former would <br />remove water development interests from any meaningful representation while <br />the latter would overshadow the biological effort and encumber the process <br />with inordinate meetings, delays in accomplishment and high overhead costs. <br /> <br />Concern was expressed that giving "approval" of budgets and research plans to <br />the Oversight Committee appeared to abrogate Service responsibilities. At <br />this point we view this "approval" process to be similar to that of the Upper <br />