9398

• UCREFRP Catalog Number: 9398
• Author: SWCA, I.
• Title: Feasibility Assessment for a Multi-Species Management Program, Lower Colorado River.
• USFW Year: 1994.
• USFW - Doc Type: Salt Lake City.
• Copyright Material: NO

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the management alternatives for their relative potential to realign the process in ways that would
give them greater opportunity for input and influence.

B. Discussion of Management Alternatives

With the exception of No Action, Litigation, and Programmatic Section 7, all of the alternatives
offer three common elements, albeit to differing degrees. They (1) offer more opportunities
for proactive, effective involvement by Participants; (2) are more cooperative in nature; and
(3) provide a comprehensive conservation strategy.

1. Alternative A: No Action

Relative to the other alternatives, a series of Section 7 consultations provides the least
predictability of future conditions. Participants would have little advance knowledge of ESA
compliance requirements for projects yet to undergo consultation. Participants would have little
opportunity to achieve prelisting agreements with the Service, leaving them susceptible to ESA
compliance problems posed by additional listings of species as endangered or threatened.
Individual Section 7 consultations could result in project-specific incidental take statements;
however, inclusion of such statements is not guaranteed. All these factors would combine to
limit the ability of Participants to plan future projects or existing project operations and
modifications with certainty.

The No Action alternative leaves all parties in a reactive position relative to actions by the
Service in the Lower Colorado River corridor. As described above, Reclamation's decision to
conduct a BA of existing Lower Basin project operation could launch a Section 7 process that
could lead to a federally directed RPA. Failure to take a proactive approach to ESA compliance
could have serious, adverse consequences for the Participants. Such a scenario unfolded in
1993-1994 at Glen Canyon Dam, where a draft RPA was issued that may significantly reduce
peaking power options at the dam.

2. Alternative B: Litigation

For the Lower Colorado River, litigation appears to have limited viability. Legal challenges of
the listings of the four big river fishes would almost certainly not succeed, and challenging

FINAL REPORT

December 20, 1994
Page 12