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<br />OOlGG2 <br /> <br />management on a species-by-species basis as opposed to an ecosystem basis has <br />been a frequent criticism of ESA implementation. <br /> <br />. We also find that the federal regulatory agencies are eager to recover species <br />by requiring dedication of water supplies for that purpose, rather than taking <br />structural measures which could be less water-intensive. <br /> <br />Conclusions <br /> <br />. Like the Delta, the ESA is broken and needs to be fixed. We support amendments to <br />the ESA similar to those our Administration supported for improving CESA. <br /> <br />. While there is potential for better state-federal coordination and cooperation in <br />administration of the ESA as it is now crafted, changes are needed to broaden the <br />nonfederal role and participation in the process. <br /> <br />. Federal agencies also need to be given explicit authority and funding to cooperate with <br />nonfederal partners in proactive approaches to species management, including prelisting <br />efforts to avoid formal listing. <br /> <br />-or <br />