Laserfiche WebLink
prepared, de- listing criteria should be formally added as data becomes available. Without these . <br />requirements, "recovery" cannot be adequately defined. An additional issue also needs to be <br />addressed: how much of "recovery" is a state prerogative outside the ESA's regulatory <br />processes? <br />States should emphasize that "take" should not be used as an "operational tool" (i.e., by the <br />USFWS or NMFS implementing or requiring "take limits ") through the manipulation or control <br />of a project or river - system. "Take" is a policy issue, not an operational issue. <br />Some consideration should be given to the idea of merging the USFWS and NMFS into one <br />uniform, consistent agency. The "mess" in the Columbia River Basin illustrates this need quite <br />nicely. <br />The cost in gathering primary data for ESA biological assessments could be substantial. Unless <br />new federal funding is provided. the states could have a problem in absorbing this new cost. <br />States need to discuss what to do if the funding and coordination, etc., needed to make the ESA <br />"work" are not forthcoming (which is the more likely scenario than the additional funding and <br />cooperation requested). <br />The ESA discussion should be expanded to encompass the many existing conflicts with other <br />entities, federal, state, local and private. These kinds of conflicts and competition are the major <br />driving force behind the implementation of the ESA in the Columbia/Snake basins. <br />The summary paper should be revised to address concerns about needing an opportunity to <br />balance interests, such as public interest considerations, under the ESA. <br />F AUSERMICKYTSAREPO.RT <br />• <br />