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.it ..,1" . . Mr. Robert Williams April 15, 1993 Page 2 o 100 Year Floodplain. The State of Colorado questions whether the designation of the 100-year floodplain, in its entirety, can be justified biologically. Furthermore, potential economic impacts of designating such a large area will require more detailed explanation. Impacts to potential land used will also necessitate substantial analysis and description. If it is the intention of the Service to include only portions of that floodplain which provide critical habitat for specific life stages of the fish, this should be more clearly indicated. o Flood Pool Elevation. The proposed rule would include the area below the "full pool elevation" of many Colorado River storage reservoirs as critical habitat. The potential consequences of this aspect of the proposed rule will require further explanation, particularly as it might alter the storage and release of water supplies allocated among the states and water users under federal and state laws which pre-date the Endangered Species Act. o Water Resources. Many aspects of the proposed rule, including those listed above, may have substantial water supply implications. Therefore the relationship between designation of critical habitat and the management of water resources will require greater examination and explanation. If flow constraints are included in the final rule, for example, the direct and indirect impacts to present and future uses of water, land and hydropower should be evaluated and described in detail. o Impacts to Sport Fishing. The potential exists to significantly affect sportfishing opportunities through the designation of critical habitat, since that designation may result in the imposition of stocking restrictions. Furthermore, any associated flow modification may adversely influence reservoir and stream fisheries. Before we can comment in more detail on this issue, we would need to review the supporting economic and biologic evaluations. o Public Review and Comment. Although we recognize the Service prepared the proposed rule under substantial pressure of a court-imposed deadline, we remain concerned that a meaningful opportUnity for full public review has not been afforded. Broad socioeconomic concerns are being raised throughout the United States as the larger consequences of our environmental protection commitments become increasingly apparent. In this context, and with reauthorization of the Endangered Species Act pending in Congress, it is especially important that the full range of alternatives and consequences be presented clearly for public review. After public comments on the proposed rule and the biologic and economic analyses are considered, the merits of publishing a revised proposal (Le., another draft) for public review should be considered before making a final decision.