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.. .....0...... -.........- federal listing in the basin. The question is, how does a municipality or irrigation company recognize a need to voluntarily offer up water to maintain darter instream flows, or justify such "losses" of its yield to its shareholders? No entity believes that the management of their water rights will be the "final straw" that might bring down the roof on the rest of the basin. Only through a broader and shared concern by all water entities will proactive measures be considered. With that would have to also be shared economic/yield participation so that no one entity is burdened with the responsibility of preserving a biologically functioning (with no federal listings) basin. The idea you presented to the Ark basin group this week of considering the environmental (or recreational) water needs as a voluntary act by water entities to reduce the costs, delays and social/economic impacts of storage facility NEPA licensing and construction is one way to help address the environmental/recreational gap. Although it does not portray a true concern for the environment - it does help bring competing groups together with a common goal. There is no need to beat a drum for, or against, environmental needs if there is an acceptance that the act of preventing federal listing (and maintaining that species) is in the best interests of both sides. One of the most visible projects currently underway in the Arkansas - the SDS project - is in the NEPA process. One of the considerations likely to come out of the draft EIS will be assessment of the impacts to Arkansas darter habitat (in Jimmy Camp, Williams and Fountain creeks). That project holds potential to actually improve darter habitat (as well as standing water recreation), but it also has the potential to detrimentally impact darter habitat as well. The principles that were presented this week via the powerpoint slides on the environmental and recreational alternatives (pages 25-28 in our handouts) are a good beginning towards developing a wider perspective of water management. As the process moves forward on SDS your suggestions may help bridge the debate over NEPA issues. I believe that the a proactive approach, rather than a mitigation-based requirement, or worse yet - litigation, can be a useful and cost saving blueprint. CSU has a great track record with DOW with their willingness to allow us to manage the entire South Slope Collection System for greenback cutthroat trout recovery. Those project facilities provide some of the best lake and stream habitat for greenbacks found in the basin. I believe that CSU recognizes the benefits of willing cooperation to help secure this species and accelerate the process of federal delisting. A similar consideration might produce tangible benefits as the SDS project moves forward. \ - I would ensure that the message to the legislature includes some of the concepts you are developing for the environmental alternatives and strategies. More than one project in Colorado has failed or been abandoned because of environmental concerns (Two Forks, Homestake II, Elephant Rock, etc). Perhaps those crossed the line of acceptability for environmental impacts. But there will likely be future projects that could be more acceptable with a wider consideration for other needs - even if they had to be included as built-in, up-front cosVyield expenditures. Other considerations for strategies towards environmental/recreational options might include use of the Species Conservation Trust Fund (HB1006), and Fishing Is Fun grants through DOW and the Federal Aid for Sport Fish Restoration. Thanks for the chance to provide comment. Doug Doug Krieger Senior Aquatic Biologist Arkansas & Rio Grande Basins Colorado Division of Wildlife 4255 Sinton Road Colorado Spring, CO 80907 719-227 -5202 9J16J2004