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<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 />I <br />I <br />I <br />I <br />I <br />I <br />I <br /> <br />critical habitat designation would prove to be extremely difficult given the wide latitude <br />delegated to the Service in designating critical habitat. <br /> <br />3. Alternative C: Programmatic Section 7 Consultation Agreements <br /> <br />The Programmatic Section 7 alternative lends itself best to situations with few variables and <br />where individual consultations tend to be repetitive. The diversity of projects and possible <br />actions and the number of species in the Lower Colorado River corridor present a complicated <br />situation. Different programmatic agreements would have to be developed for each class of <br />actions (e.g., dam operations, water diversion, water storage, etc.). Programmatic Section 7 <br />agreements can streamline the Section 7 process, and provide additional assurance as to <br />outcomes, but they still provide a lead role for the Service, little opportunity for effective <br />involvement by the Participants, and they would constitute only a minimal comprehensive <br />conservation strategy. <br /> <br />4. Alternatives D-l and D-2: Recovery Implementation Programs <br /> <br />The RIP alternatives would allow more involvement by the Participants than would No Action; <br />however, based on previous RIPs the Service takes the lead in directing a RIP. This is because <br />a RIP is a federal program implementing a federal recovery plan. While a RIP has numerous <br />advantages in that it can mitigate findings of adverse modification and/or jeopardy opinions and <br />includes a comprehensive conservation strategy, it does not provide a mechanism for incidental <br />take. Participants could still find themselves in violation of Section 9 of the ESA. A RIP has <br />the potential to serve as the RPA for a further Section 7 consultations. The D-2 RIP alternative <br />(for all listed species), would better meet the Participants' compliance needs than the D-l <br />alternative, but would also be more costly and time-consuming to develop and implement. <br /> <br />5. Alternatives E-l and E-2: Habitat Conservation Plans <br /> <br />Advantages of the RCP process include the fact that it would be initiated by the Participants, <br />and would be developed and directed by an RCP steering committee, with circumscribed <br />involvement by the Service (they provide advice during development and approve or disapprove <br />the final document). The HCP alternatives (including the Modified RCP) are the most proactive <br />of the management alternatives. All RCP alternatives would result in comprehensive, <br /> <br />FINAL REPORT <br /> <br />December 20, 1994 <br />Page 13 <br />