9417

• UCREFRP Catalog Number: 9417
• Author: U.S. Department of the Interior.
• Title: Final Environmental Assessment
• USFW Year: 1998.
• USFW - Doc Type: Acquisition and Enhancement of Floodplain Habitats along the Upper Colorado, Green, and Gunnison Rivers as part of the Recovery Program for Endangered Colorado River Fishes.
• Copyright Material: NO

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in the EA.

Colorado River Energy Distributors

General Comments
1. The project Purpose and Need section not only
must address the functional reasons for acquiring
these lands but provide the justification for
placing additional lands under public
management.

2. The alternatives explored for this action are
inadequate.

a) According to the USBR NEPA Handbook
(pg.8-9 of latest version), the alternatives section
is unacceptable because it fails to adequately
explore "a realistic range of alternatives that
reasonably could be considered and that will
accomplish the project purpose and need."

b) The need to acquire private lands is given as a
need to achieve a certain type of land management
scheme not currently being done. However, other
ways to achieve this type of land management
should have been explored (e.g., habitat
conservation plan), even if these are not within the
jurisdiction of the USFWS or USBR.

IV -7

consider it to be significant.
.IFlagg (1982) in Minckley et al. (1991)
concluded "that parasites and diseases were
unlikely agents in the decline of native fishes in
the upper basin."

.IIn Chapter II. Alternatives, each alternative is
evaluated based on the criteria for accomplishing
the project's purpose and need, which is to protect
and enhance floodplain habitat to support
recovery of the endangered fishes.

.IIn Chapter II.(C)(3), a variety of methods for
providing this habitat are discussed. This
information was used to craft a proposed action
which will meet the requirements to provide
sufficient quantity and adequate quality of habitat
in a timely manner to achieve and sustain
recovery .
.I All acquisition methods (except condemnation)
can be used, subject to the desires of the land
owner, and subject to meeting the evaluation
criteria. Easements are the preferred type of
acquisition.

.ITo accomplish the project purpose and need,
which is to protect and enhance bottomlands in
perpetuity to achieve and sustain recovery, we
must use methods that provide sufficient quantity
and adequate quality of habitat in a timely
manner.
.I Although "habitat conservation plans" could
potentially provide long-term protection for
bottomlands, no private landowners have applied
for a Section 10 permit since the inception of the
Recovery Program, and it is unlikely that a
sufficient number of landowners would do so in
the future.
.I All methods to provide habitat under the third
alternative, except for condemnation, are
encouraged. Many of these methods are not
sufficient in and of themselves to meet the