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I I' I 1, Page 4 July 30. 1990 have not undergone Section 7 Consultation when no consultation was required. This emphasis on the fact that other projects on the San Juan River have not undergone Section 7 Consultation is repeated at page 8 of the Draft: The San Juan River has continued to be developed through several projects including Navajo Reservoir, Navajo Indian Irrigation Project and the San Juan-Chama Project. None of these three projects have undergone Section 7 consultation under the Endangered Species Act. Further, the Service saw fit in 1990 to allow Region 6 to control the Section 7 consultation process for the Animas-La Plata Project rather than allowing the process to be reinitiated under Region 2. In 1979, Region 2 of the Service issued a non-jeopardy biological opinion regarding the Animas-La Plata Project. The reversal of the 1979 non-jeopardy opinion in the 1990 Draft Opinion is based on the same information available in 1979 that a small isolated population of endan- gered Colorado squawfish exists in the San Juan River. The in- volvement of two regions of the Service, Albuquerque in the issuance of the Draft Opinion and Region 6, Denver, in the reinitiation of consultation represents inconsistencies in administration and perhaps policy. The Districts also find the Service's concern with the San Juan River as "critical habitat" for the Colorado squawfish to have political overtones. There has been no official designation of the San Juan River as "critical habitat" for. the Colorado squawfish. As late as 1989, the Draft Recovery Plan for the Colorado squawfish did not include the maintenance of a self-sustaining population in the San Juan as necessary for the down listing or delisting of the species. It was not until April 16, 1990, just shortly before issuance of the Draft Opinion, that the Recovery Team proposed including the San Juan River population as one of the requirements for changing the status of the species. It is the Districts' understanding that in reaching its decision regarding the San Juan River the Recovery Team received only a short oral briefing on the issue and no written documentation for advance study. III. Unsubstantiated Conclusions. The introductory paragraph quoted in Section II above, states that the flows in the San Juan are already critical to the endangered fish. This is not documented in the Draft Opinion. In numerous places throughout the Draft, other factors are seen as endangering the Colorado squawfish in the San Juan River. At page 6 the Draft Opinion admits that depletions "along with a number of other factors. have resulted in the endangerment of the Colorado squawfish. At