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<br />Ifi,'- <br />r <br />r:' <br /> <br />~ <br /> <br />Page 4 <br /> <br />5,B, Critical habitat should not be designated in an area if it will have a significant <br />adverse impact on the future exercise ofIndian water rights unless failure to do so will <br />cause extinction of the species. <br /> <br />RECOMMENDATION TO CWCB <br /> <br />I recommend tbat the CWCB submit written comments to the Working Group by the October 15, <br />1999 deadline. I would include the following points: <br /> <br />1. The draft report should be disseminated to interested parties other than Indian tribes and <br />states. The report raises significant issues, particularly relating to the environmental baseline, <br />affecting non-lrIdian water users and (as the report itself acknowledges) they should be given <br />adequate notice and opportunity to comment. ' <br /> <br />2. The draft report is too abstract and academic. It should be revised to address a number of <br />significant practical issues; such as the effect, if any, that implementing the recommendations <br />would have on existLng recovery programs and interstate compact water aIIoc<ltions. Without <br />more information about the recommendations' real world effects, it is not possible to comment <br />intelligently. <br /> <br />3. The recommendations appear to add neW layers of process to 9 7 consllltations. The <br />report should be revised to address how the additional process would affect the timing and cost <br />of consultations. <br /> <br />4. The Case Study recognizes that many factors have contributed to the decline of the listed <br />fish. The report should include a recommendation that the FWS explore and, to the maximum <br />extent possible, rely on non-flow measures to avoid jeopardy to and recover the fish. <br /> <br />5. To the extent tribal water marketing is recommended, it must comply with state laws and <br />interstate compacts. <br /> <br />6. The recommendation that the FWS consider reservations as individual economic units <br />when proposing to designate critical habitat should be extended to individual communities, <br />states, or politic<ll subdivisions that function as economic units. . <br />