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2 I I I I I I I I I I I I I I I I I I I 4. The principal concern we have with creating more flooded bottomlands lies in its possible enhancement of non-native fish species to the detriment of the endangered fish. Already non-native fish dominant the fish community that invade flooded bottom lands, constituting over 95% in most river reaches according to work in the Recovery Implementation Program (RIP). If the belief exists that the acquisition will significantly add to the amount of flooded bottomland, then we should anticipate the impact this may have to endangered fish by the addition of significant amounts of non-native fish predators and competitors. We should first detennine the effectiveness of methods to reduce the numbers of non-native fish, isolate them from endangered fish or otherwise reduce their impact (i.e., complete research initiated on these subjects) before we commit to creating more habitats like those already shown to be heavily invaded by non-native fish. The report utterly fails to raise this issue or address the possible negative impacts by the proposed action. 5. Describing a doomsday condition in the No Action Alternative is unsupported by facts in the EA. No facts are provided to demonstrate the possibility of extinction for razorback sucker and a declaration that the bonytail is unrecoverable without the project. Also, no facts are provided to support the contention that wildlife resources would be expected to decline under the No Action alternative. The EA fails to provide any documentation of events that would cause the retention of land in private hands to precipitate such a set of conditions. It also ignores the efforts by many people and agencies to prevent extinction and recover fish species in the Upper Colorado River Basin and through efforts in other regions (e.g., Lake Mojave razorback). 6. We are disturbed by the statement (page 111-3, column 2, paragraph 3) that implies rejection of this project would precipitate implementation of more flow-related alternatives We understand and appreciate your concerns and continue to work with you to achieve recovery of the endangered fish. We trust the RIP is taking all action believed necessary to achieve recovery and doing so in accordance with needs of the fish (i.e., we are already taking all flow-related actions demanded in the RIP and others have not been justified). The not-so- subtle message in this paragraph is 'support the floodplain acquisition program or else face the consequences of more flow-related mandates' even if anything beyond what is being done now has not been seen by the RIP as necessary. The paragraph's purpose appears an attempt to quash any opposition to the project and therefore should be deleted. Specific Comments 1. Page 1-1, A The Program proposed is to restore floodplain habitats to recover all four endangered fishes. Where has it been shown in the EA that floodplains would be directly beneficial to Colorado squawftsh, bonytail, and humpback