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. e e Rationale: The Recovery Program recently installed a fish passage at Redlands to open up 50 miles of the Gunnison River as squawfish and razorback sucker habitat. Passages on the Colorado River to provide habitat to Rifle are being planned. Presently, there are about 800 miles of habitat for Colorado squawfish and razorback sucker in the upper basin. Expansions via fish passages will bring this close to 900-950 miles. There is no scientific or legal basis for asserting that if flow recommendations cannot be achieved in the IS-mile reach, that recovery cannot be achieved. The IS-mile reach is less than 2% of the available habitat, yet it has been and is absorbing an enormous amount of Recovery Program resources. The Colorado Squawfish Recovery Plan (USFWS, 1991) does not require "recovery" in the 15- mile reach. Down listing should occur when naturally self-sustaining populations are maintained from "the Colorado River from Palisade, Colorado to Lake PoweIl," together with the Green River subbasin. The Colorado River populations of squawfish extends from Lake Powell to Palisade, and are not the IS-mile reach population of Colorado squawfish. C. A realistic role in recovery should be assigned to the IS-mile reach that recognizes existing and future depletions, and realistic recovery actions for the IS-mile reach. Rationale: The IS-mile reach presents a significant conflict between the USFWS flow recommen- dations and reality. Flow recommendations for the IS-mile reach (Osmundson, 1995) recom- mends 400,000 acre-feet/year more water than is presently available. In recent filings on the 15- mile reach, the Colorado Water Conservation Board set aside a 100,000 acre-feet carve out for new depletions, with as much as 300,000 acre-feet of modifiable flow to accommodate compact development, based on the potential for compact development depletions on the main stem of the Colorado River. At the suggestion of the USFWS Regional Director, a discussion is ongoing regarding how to deal with the great discrepancies between the flow recommendations and present and future reality, and how the Recovery Program will be maintained as the reasonable and prudent alternative for existing and future depletions upstream of the IS-mile reach on the Colorado River. These depletions are inevitable as Colorado develops its compact entitlement. As agreed, existing depletions are to be fully mitigated by the Recovery Program (USFWS, 1987). USFWS has suggested that recovery must take place in the IS-mile reach of the Colorado River. This is unjustified. This position is a lose-lose position for the Fish and Wildlife Service and the Recovery Program. It is abundantly clear that 1) the flow recommendations cannot be met now, and 2) future depletions will further reduce flows in the IS-mile reach. A realistic role for the 15- mile reach needs to be identified, relative to overall recovery of the species, and based on feasible recovery measures for the IS-mile reach, including habitat development and nonnative control. The role of the IS-mile reach should be determined in cooperation with all RIP participants. 7