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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CREDA
COLORADO RIVER ENERGY DISTRIBUTORS ASSOCIATION

March 18, 1998

Mr. Henry Maddux, Program Director
Upper Colorado River Endangered Fish Recovery Program
U.S. Fish and Wildlife Service
P.O. Box 25486, DFC
Denver, CO 80225

Re: Draft Environmental Assessment for the Proposed Acquisition and Enhancement
of Floodplain Habitats

Dear Mr. Maddux:

Thank you for sending a copy of the draft Environmental Assessment and providing an
opportunity for comment. We have prepared both general and specific comments.

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. The report has provided little
technical support for the action and no clear explanation why existing public lands
are inadequate to meet the needs of the endangered fish. Both these deficiencies
should be corrected in the final version.

2. The alternatives explored for this action are inadequate. According to the
USBR NEP A 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." 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

3. This EA should be a programmatic EA. The proposed action is a program rather
than a site-specific action. The EA attempts to describe the proposed action in
general terms and avoids giving specific details of sites where the action would be
implemented. We suggest a better approach would be to complete this EA as a
programmatic EA then follow with tiering of site-specific EAs for each site
proposed for acquisition.