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Mr. Robert Williams <br />April 15, 1993 <br />Page 2 <br />0 100 Year Floodplain. The State of Colorado questions whether the designation of the <br />100 -year floodplain, in its entirety, can be justified biologically. Furthermore, potential <br />economic impacts of designating such a large area will require more detailed <br />explanation. Impacts to potential land used will also necessitate substantial analysis <br />and description. If it is the intention of the Service to include only portions of that <br />floodplain which provide critical habitat for specific life stages of the fish, this should <br />be more clearly indicated. <br />0 Flood Pool Elevation. The proposed rule would include the area below the "full pool <br />elevation" of many Colorado River storage reservoirs as critical habitat. The potential <br />consequences of this aspect of the proposed rule will require further explanation, <br />particularly as it might alter the storage and release of water supplies allocated among <br />the states and water users under federal and state laws which pre -date the Endangered <br />Species Act. <br />0 Water Resources. Many aspects of the proposed rule, including those listed above, <br />may have substantial water supply implications. Therefore the relationship between <br />designation of critical habitat and the management of water resources will require <br />greater examination and explanation. If flow constraints are included in the final rule, <br />for example, the direct and indirect impacts to present and future uses of water, land <br />and hydropower should be evaluated and described in detail. <br />0 Impacts to Sport Fishing. The potential exists to significantly affect sportfishing <br />opportunities through the designation of critical habitat, since that designation may <br />result in the imposition of stocking 'restrictions. Furthermore, any associated flow <br />modification may adversely influence reservoir and stream fisheries. Before we can <br />comment in more detail on this issue, we would need to review the supporting <br />economic and biologic evaluations. <br />0 Public Review and Comment. Although we recognize the Service prepared the <br />proposed rule under substantial pressure of a court - imposed deadline, we remain <br />concerned that a meaningful opportunity for full public review has not been afforded. <br />Broad socioeconomic concerns are being raised throughout the United States as the <br />larger consequences of our environmental protection commitments become <br />increasingly apparent. In this context, and with reauthorization of the Endangered <br />Species Act pending in Congress, it is especially important that the full range of <br />alternatives and consequences be presented clearly for public review. After public <br />comments on the proposed rule and the biologic and economic analyses are <br />considered, the merits of publishing a revised proposal (i.e., another draft) for public <br />review should be considered before making a final decision. <br />