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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doubts as to the value of the proposed
conservation measure. Instead of channel-
ling mitigation towards the critical
habitat of the species, the FWS effort is
directed to a fifteen mile stretch where
the number of fish captured is very low and
where spawning (if any) is insignificant to
the ,dabi1ity of the species.

c. FWS continues to burden the ESA ~ 7 Consul-
tation process with significant changes in
both administrative policy and frequently
altered decision. For example, an apparent
re-examination has taken place concerning
the feasibility and operating liabilities
of the "basin-wide" direct recovery facili-
ty suggested as part of the Draft Biologi-
cal Opinions. As a result, FWS has
reportedly eliminated consideration of its
earlier identified proposals for screening
an existing river diversion and for
imp1acement of habitat enhancing backwa-
ters. This re-eva1uation has been accom-
plished within the very short period of
time since the original Draft Biological
Opinions were issued. But even this
re-eva1uation, and subsequent changes are

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