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<br />3. This EA should be a programmatic EA. <br />We suggest a better approach would be to <br />complete this EA as a programmatic EA then <br />follow with tiering of site-specific EAs for each <br />site proposed for acquisition. <br /> <br />4. a) The principal concern we have with creating <br />more flooded bottomlands lies in its possible <br />enhancement of non-native fish species to the <br />detriment of the endangered fish. <br /> <br />b) The report utterly fails to raise this issue or <br />address the possible negative impacts by the <br />proposed action. <br /> <br />5. Describing a doomsday condition in the No <br />Action Alternative is unsupported by facts in the <br />EA. The EA fails to provide any documentation <br />of events that would cause the retention of land in <br />private hands to precipitate such a set of <br />conditions (e.g., decline of wildlife resources). <br /> <br />6. We are disturbed by the statement (page III-3, <br />column 2, paragraph 3) that implies rejection of <br /> <br />project's purpose and need. <br /> <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />J <br />I <br />I <br />I <br />I <br />I <br />J <br /> <br />IThis EA is programmatic, as stated on page I-I <br />Section B paragraph 3. <br />.I If there is any significant new information or <br />unforseen issue relevant to a specific acquisition <br />and/or habitat enhancement, it will be addressed <br />through NEP A. <br />.IOn sites where levees are breached and/or <br />habitats are altered, additional NEP A will be <br />conducted as necessary. <br /> <br />.IHabitat restoration will proceed concurrently <br />with nonnative fish control and stocking of <br />endangered fishes. <br />.IBottomland habitat provides food, shelter, and <br />resting areas for the razorback sucker during the <br />beginning of its life cycle. If razorbacks cannot <br />survive the first months of their life cycle because <br />this habitat is not available, predation and <br />competition from nonnative fish is a mute issue. <br /> <br />.IThe abundance of food and shelter in the <br />bottomlands that benefits endangered fish will <br />also benefit other native and nonnative fish <br />species. Research is being conducted to <br />determine how to provide bottomland habitat that <br />will benefit all types of native fish while limiting <br />benefits for nonnative fish. <br /> <br />.lIt is well-documented that razorback suckers are <br />endangered and have continued to decline. It is <br />reasonable to assume that the same factors that <br />have contributed to habitat degradation in the past <br />would continue in the future. <br />.IThe preferred alternative, acquisition of <br />easements, would keep lands in private <br />ownership. <br />.IIn the arid West, a disproportionate number of <br />wildlife species depend upon riparian habitat. <br />Protection and enhancement of these habitats is <br />expected to benefit wildlife resources. <br /> <br />.IThe goal of the Recovery Program is to recover <br />the endangered fishes while allowing water <br /> <br />IV - 8 <br />