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

designation of critical habitat will interface with these programs. These programs are
a cooperative effort between the Upper Basin states, federal agencies including the
Fish and Wildlife Service, the Bureau of Reclamation and the Western Area Power
Administration, and representatives of the environmental and water communities. The
Secretary of the Interior and the Governors of the Upper Basin States have approved
these cooperative agreements to recover the species, and we believe the proposed rule
should have been coordinated with these programs and the program participants.
Impacts on Other Water Systems.
The proposed rule may impact the operation of the Colorado River System reservoirs,
State and federal water projects and the Colorado River and Upper Colorado Basin
Compacts, as well as various federal laws and court decrees collectively known as the
Law of the River. None of the seven basin states directly impacted by the proposed
rule have been consulted on these issues.
C Floodplain and Pool Levels.
We do not believe that the 100 year floodplain of the designed streams and the full
pool elevation of designated reservoirs is based on sound biological data and studies.
We also question the hydrological basis for such designations.
In conclusion, the State of Colorado believes that the public should be given adequate time
to review and comment on the biological and economic analyses before making this
designation. Additionally, prior to any decision on the final rule, the Service should
adequately address the comments it will receive on the proposed rule as well as those
received following the review of the biological and economic analyses. The final rule should
not be developed until all the issues have been adequately addressed by the Service, and
there has been consultation with the interested parties.
Thank you again for the opportunity to make these comments.