4101

• UCREFRP Catalog Number: 4101
• Author: Mobil.
• Title: Summary of Technical and Procedural Concerns.
• USFW Year: 1984.
• USFW - Doc Type: \
• Copyright Material: NO

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**2. IS THE REACH OF THE RIVER TENTATIVELY IDENTIFIED BY
FtlS FOR MITIGATION MEASURES DEEMED "CRITICAL HABITAT?"

The FWS draft Biological Opinion states that "the
Colorado Squawfish currently occupies about 880 river
miles in the Colorado River system...and is preeently
found only in the upper Colorado River basin above
Glen Canyon Dam." Mitigation requirements are
primarily focused on a 15 miles reach of the river
"of immediate impact."

The FWS has not defined "critical habitat" for the
endangered fish (and apparently do not intend to do
so.) While the task may be technically difficult
because of the migratory and opportunistic nature of
the squawfish, a realistic recovery effort must first
identify the habitat essential (i.e., "critical") to'
recovery. Without a technical determination of
critical habitEt, tne BIS mitigation program is
haphazard and therefore, not necessarily apt to
achieve the desired goal. Very few squawfish have
been collected in the fifteen mile stretch selected
by FtlS for conservation measures. But, based on very
limited data, FVlS suspects that this reach of the
river could be a spawning ground. There is no
technical support, however, indicating that mitiga-
tion directed to this fifteen mile stretch of the

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