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V Basin states, or their designees. The Steering Committee as a whole Would also make assessments of whether sufficient progress was being made. While the membership of the subcommittee for addressing disputes over sufficient progress was spelled out by the proposed SPA (at minimum one representative each from the FWS and the three states), the membership of the Steering Committee itself was not. As of June 1995, the Steering Committee was self-appointed and consisted of one representative from the DOI and representatives from each of the three states. in September 1995, this Steering Committee agreed to add one representative each from the FWS, BOR, BLM, NPS, Colorado River Indian Tribes, and conservation groups. The Tribes and the conservation groups have so far declined to join the Steering Committee. While the proposed SPA asserts that it is not intended to be a precedent for the long-term program and that the long-term program will be controlled by a separate agreement, the proposed SPA anticipates that the long-term program will be adequate to fulfill the regulatory needs of both federal and non- federal participants. The.expectation seems to be that the long-term program will serve as the reasonable and prudent alternative in all Section 7 consultations and as an HCP for incidental takings without a federal nexus and will otherwise provide the basis for all ESA compliance and recovery planning for all species occurring in the lower Colorado River corridor over a 50 year period. ICMs. In November 1995 the Steering Committee approved a set of ICMs that give priority in the first year of program development to preventing the extinction of the razorback and bonytail and to preserving their genetic diversity, but the Committee has yet to decide how much of the estimated $1.5 million annual budget will go toward such ICMs and how much to program development. The ICM's for subsequent years will be based on a forthcoming assessment of the needs of all listed species in the planning area, not just the razorback and bonytail, and on an annual assessment of ICM effectiveness. For the razorback, the recommended ICMs for the first year include adding more grow-out facilities off the mainstem of the river, on tribal lands, on FWS refuges and in isolated coves of Lakes Mead and Mohave. New hatcheries could be built and old ones renovated, and there may be opportunities to help meet the objectives of re-stocking the, aging Lake Mohave razorback population with 50,000 young adult fish and of introducing 30,000 razorbacks to Lake Havasu. These razorback ICMs should supplement the population augmentation projects on the lower Colorado River that are already funded by the BOR and FWS. For the bonytail, the FWS is already committed to stocking 25,000 in Lake Mohave as a condition of the intra-FWS biological opinion on its stocking of non-native rainbow trout along the lower Colorado River below Hoover Dam. The ICMs will increase the stocking of Lake Havasu with bonytail and expand the grow out and hatchery facilities for this fish. Conservation Group Concerns Three conservation organizations -- American Rivers, the Environmental Defense Fund, and the Defenders of Wildlife, sent letters to the FWS in October 1995 objecting to the MOA. These organizations were all concerned that the MOA did not give first priority to species recovery. They criticized the adequacy of the mileposts for measuring sufficient progress and the lack of federal accountability and oversight by particularly the FWS. They asserted that there had not been meaningful public involvement in the development of the MOA and the interim program. They were especially concerned that the MOA authorized incidental takings without approval of an HCP, and had already "short circuited" the Section 7 consultation on the operation of water and power projects on the lower Colorado River. Two conservation groups -- Defenders of Wildlife and the Southwest Center for Biological Diversity, 21