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r Agreement (SPA) for the program development period. The proposed SPA indicates that the MOA will serve as the reasonable prudent alternative for any Section 7 consultation on any included species during the three year program development period as long as sufficient progress is being made and habitat conditions on the lower Colorado River did not have to be re-evaluated. The included species list attached to the proposed SPA now numbers 102, although some may be dropped later. As proposed, sufficient progress was to be mea- sured by timely completion of specific program devel- opment and ICM mileposts. Any dispute between the FWS and the other members of the Steering Committee about sufficient progress was to be first addressed by a subcommittee of the Steering Committee and ultimate- ly to be resolved by the Secretary of the Interior in con- sultation the Governors of the three Lower 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 representa- tive each from the FWS and the three states), the mem- bership of the Steering Committee itself was not. As of June 1995, the Steering Committee was self-appointed and consisted of one representative from the DOl 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 pro- gram will serve as the reasonable and prudent alterna- tive in all Section 7 consultations and as an HCP for incidental takings without a federal nexus and will oth- erwise 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. leMs In November 1995 the Steering Committee approved a set of ICMs that give priority in the first year of pro- gram 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 razor- back 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 popu- lation 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 committed to stocking 25,000 in Lake Mohave 65