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<br />the programs for recovery implementation and regula- <br />tory compliance. Leaving such range-wide planning <br />unattended invites overlap or at worse counter-produc- <br />tive competition between these programs. <br /> <br />HABITAT PRESCRIPTION <br /> <br />Updated recovery planning for these fishes should <br />more clearly address how the habitats needed for <br />recovery throughout their geographic ranges will be <br />specified. For the most part, the official designation of <br />critical habitat failed to provide workable habitat pre- <br />scriptions. It did not add any specificity to the quantity, <br />timing, and location of the flows or reservoir levels <br />needed for recovery, or identify those areas within the <br />100 year floodplain that needed to be protected or how <br />they should be protected. This generalization obscures <br />rather than clarifies the regulatory questions of what <br />constitutes an adverse modification of critical habitat <br />and whether federal permitting or project operations <br />will appreciably reduce the likelihood of recovery. Nor <br />does this habitat designation provide much insight into <br />the relative importance and function of the habitat that <br />should be protected across the ranges of these fishes. Is <br />all of the designated critical habitat really essential to <br />recovery? To what extent does naturally functioning <br />habitat have to be protected or restored? How should <br />naturally functioning habitat be defined? Can it be <br />defined quite differently for different basins? <br /> <br />The broad brush nature of the critical habitat designa- <br />tion also confuses the rationale for re-stocking the list- <br />ed fishes and augmenting existing populations. If the <br />habitat needs of these fishes cannot be prescribed and <br />met, then such re-stocking and augmentation will not <br />lead to self-sustaining populations. Without the requi- <br />site habitat, some form of intervention will be needed <br />to sustain fish populations and may only serve to bank <br />the fishes genetically. <br /> <br />68 <br /> <br />,. <br /> <br />REFORM OF THE ENDANGERED <br />SPECIES ACT (ESA) <br /> <br />The compartmentalization of the recovery of the <br />Colorado River's listed fishes is rooted to some extent <br />in the ESA which does not clearly integrate recovery <br />planning with critical habitat designation, with consul- <br />tation by federal agencies, or with habitat conservation <br />planning by private and state entities, and which does <br />not give recovery planning enough force. While sound <br />range-wide recovery planning, customized recovery <br />implementation, and tailored regulatory compliance <br />for the Colorado's listed fishes could be instituted <br />under the current ESA, this law could be amended to <br />provide a more forceful and timely path for recovery <br />planning that is directly tied to specific designations of <br />critical habitat, that guides cost effective recovery <br />implementation across the geographic range of any <br />listed species, and that is the basis for consistent and <br />reasonably certain regulatory compliance. <br /> <br />ACKNOWLEDGMENTS <br /> <br />This paper benefited greatly from comments on earlier <br />drafts by Marty Meisler, Barry Saunders, John Shields, <br />W.L. Minckley, Harold Tyus, James Deacon, Lori Potter, <br />and John Hamill. At the Colorado River Workshop <br />itself, we appreciated the comments from the panelists <br />- Dan Luecke, Chris Harris, and George Arthur, from <br />those who spoke at the break-out sessions, and from all <br />the others at the workshop who offered their thoughts <br />about the paper to us. We also thank the Grand <br />Canyon Trust and U.S. Bureau of Reclamation for <br />sponsoring an outstanding workshop and giving us the <br />opportunity to present this paper, but remain solely <br />responsible for contents. <br />