Statement of the Colorado Department of Natural Resources on Proposed Designation of Critical Habitat for the Colorado River Endangerd Fishes

• Description: Statement ofthe Colorado Department of Natural Resources on Proposed Designation of Critical Habitat for the Colorado River Endangerd Fishes. 1993?
• State: CO
• Title: Statement ofthe Colorado Department of Natural Resources on Proposed Designation of Critical Habitat for the Colorado River Endangerd Fishes
• Water Supply Pro - Doc Type: News Article/Press Release

AGENDA ITEM 16d (2)
Statement of the
Colorado Department of Natural Resources
on
Proposed Designation of Critical Habitat
for the Colorado River Endangered Fishes
Thank you for the opportunity to provide these comments on the proposed rule to designate
critical habitat for the federally endangered Colorado squawfish, razorback sucker,
humpback chub, and bonytail chub.
I am Ron Cattany, Deputy Director of the Colorado Department of Natural Resources. I
am here today on behalf of Ken Salazar, Executive Director of the Colorado Department
of Natural Resources. These comments are made on behalf of the Department, the
Colorado Water Conservation Board and the Colorado Division of Wildlife. Additional
comments will be provided by the Department in writing, prior to the closing of the
comment period.
The January 29, 1993 Federal Register Notice proposes to designate more than 2000 miles
of riverine and reservoir areas in the Colorado River Basin as critical habitat for these four
fish species. We believe that this proposed designation may have significant social,
economic and environmental impacts to existing and future water development, hydropower
generation and operation of the Colorado River System reservoirs in the Upper and Lower
Colorado River basins.
These impacts may have far - reaching effects outside the Basin. Therefore, a full analysis
of the potential consequences must be conducted, particularly if management of flows to
maintain the designated critical habitat is considered to be a major element of recovery.
Unfortunately, these impacts cannot be adequately evaluated, and meaningful comments to
the proposed rule cannot be made at this time because the biological analysis, which serves
as the basis for the proposed rule, and the economic analysis, which evaluates the economic
impacts of the proposed rule are not yet available for public review. However, based on our
initial review of the proposed rule, Colorado would like to list some of the issues that are
of concern to us:
Environmental Review Under NEPA.
The U.S. Fish and Wildlife Service has decided not to prepare an environmental
review of this action pursuant to the National Environmental Policy Act.. In the
absence of an EIS, it is critical that the impacts of the proposed action be fully
analyzed under the economic and biological analyses currently being prepared.
o Consultation with Recovery Program Participants.
We are disappointed that the proposed rule was developed without participation or
consultation with the San Juan River Basin and the Upper Colorado River Basin
Recovery Program participants. The proposed rule does not describe how the