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<br />r. .. <br /> <br />. <br /> <br />. <br /> <br />.-, <br />~ <br /> <br />'.- <br />.' <br /> <br />Statement or the <br />Colorado Department of Natural Resources <br />on <br />Proposed Designation of Critical Habitat <br />for the Colorado River Endangered Fishes <br /> <br />Thank you for the opportunity to provide these co=ents on the proposed rule to designate <br />critical habitat for the federally endangered Colorado squawfish, razorback sucker, <br />humpback chub, and bonytail chub. . <br /> <br />I am Ron Cattany, Deputy Director of the Colorado Department of Natural Resources. I <br />am here today on behalf of Ken Salazar, Executive Director of the Colorado Department <br />of Natura! Resources. These co=ents are made on behalf of the Department, the <br />Colorado Water Conservation Board and the Colorado Division of Wildlife. Additional <br />co=ents will be provided by the Department in writing prior to the closing of the <br />co=ent period. <br /> <br />The January 29, 1993 Federal Register Notice proposes to designate more than 2000 miles <br />of riverine and reservoir are:lS in the Colorado River Basin :lS critical habitat for these four <br />fish species. We believe that this proposed designation may have significant social, <br />economic and environmental impacts to existing and future water development, hydropower <br />generation and operation of the Colorado River System reservoirs in the Upper and Lower <br />Colorado River basins. <br /> <br />These impacts may have far-reaching effects outside the Basin. Therefore, a full analysis <br />of the potential consequences must be conducted, particularly if management of flows to <br />maintain the designated critical habitat is considered to be a major element of recovery. <br />UnfortUnately, these impacts cannot be adequately evaluated, and meaningful co=entS to <br />the proposed rule cannot be made at this time because the biological analysis, which serves <br />as the basis for the proposed rule, and the economic analysis, which evaluates the economic <br />impacts of the proposed rule are not yet available for public review. However, based on our <br />initial review of the proposed rule, Colorado would like to list some of the issues that are <br />of concern to us: <br /> <br />o Environmental Review Under NEP A. <br /> <br />The U.S. Fish and Wildlife Service has decided not to prepare an environmental <br />review of this action pursuant to the National Environmental Policy Acr. In the <br />absence of an EIS, it is critical that the impacts of the proposed action be fully <br />analyzed under the economic and biological analyses currently being prepared. <br /> <br />o Consultation with Recovery Program Participants. <br /> <br />We are disappointed that the proposed rule was developed without participation or <br />consultation with the San Juan River Basin and the Upper Colorado River Basin <br />Recovery Program participants. The proposed rule does not describe how the <br />