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<br />, <br /> <br />Mr. David Getches <br />Page Four <br /> <br />. <br /> <br />We are convinced that the hydrology subcommittee's assign- <br />ments should be designed to assist the Coordinating Committee in <br />the execution of both its short-term and longer-term duties. <br />Thus, we strongly urge that at its next meetinq the Coordinating <br />Comm' subcommittee to assess the im acts on the <br />system's flow regime of the d~letions encom assed by all pen ~ng <br />consultations as well as those already completed. The resu <br />that assessment are ~ndispensable to identification of the "base- <br />line" upon which both future consultations and a recovery plan <br />must be founded. <br /> <br />2. Section 7 Consultation for the Second Round of <br />Water Sales from Ruedi Reservoir-- <br /> <br />What is urgently needed at this time is a pause in the <br />continued issuance of biolgical opinions that sanction further <br />depletions, until a comprehensive conservation plan can be imple- <br />mented. This would permit the agencies' biologists to gather the <br />data that are needed to fully evaluate the effects of specific <br />projects on the endangered fish species and the effectiveness of <br />measures for offsetting those impacts. At the same time, the <br />policymakers would have an unhindered opportunity to deliberately <br />weigh alternative conservation strategies. <br /> <br />. <br /> <br />In our view federal agencies have a special responsibility <br />in this regard, for two reasons. First, federal agencies have a <br />duty to use their statutory authorities to promote the Act's <br />purposes of conserving endangered species. Second, federal <br />agencies such as the Bureau of Reclamation are represented on the <br />Coordinating Committee and should ensure that their actions do <br />not impede the Committee's ability to fashion a conservation <br />plan. <br /> <br />We fear that the Bureau's insistence upon completion of the <br />section 7 consultation for the second round of water sales from <br />Reudi reservoir will have precisely that effect. Commitment of <br />that block of water to a consumptive use, no matter how specula- <br />tive, will limit the Committee's latitude in formulating a conser- <br />vation plan since the sale reduces still farther the small pool <br />of unappropriated water that remains available for ensuring some <br />level of minimum flows. On the other hand, the Bureau has not <br />demonstrated there is any "need" for the immediate sale of this <br />water. We believe the Bureau should have refrained from press- <br />uring the Fish and Wildlife Service into completing the section 7 <br />consultation, to give all of the affected agencies and the Commit- <br />tee a chance to develop a long-range solution to this problem. <br /> <br />Moreover, we are disturbed that the Bureau is insisting <br />that the Fish and wildlife Service complete the section 7 consul- <br />. tation without discussing this issue fully with the Committee. <br />