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At this time, it is not known if the current distribution of the GB and CR lineages is: (1) <br />natural, (2) the result of moving fish across river drainages (i.e. stocking), (3) or as the <br />physical characteristics suggests, the GB and CR lineages are just part of a group of fish <br />that have not been separated long enough to form separate physical characteristics <br />(Rosenlund 2009 pers. com.). The results from the analysis of historical samples and the <br />morphology and meristics analyses should help to resolve this issue. <br />Section 7 Issue <br />The identification of lineage GB fish in western Colorado and eastern Utah has raised <br />concerns regarding whether there is a need for application of the Act (particularly section <br />7 consultation) in these areas. Although the greenback was listed rangewide, its <br />distribution was designated only as Colorado. Thus any greenback lineage fish found in <br />Utah or Wyoming would not currently receive any protections under the Act. However, a <br />question remains as to whether or not cutthroat populations containing lineage GB fish in <br />western Colorado should receive the protections of the Act. In an e-mail provided to the <br />U.S. Forest Service (USFS) (Linner 2007), the Service stated that we are in an interim <br />period where there are a lot of uncertainties. During this period, we believe that <br />management agencies should be cautious with fishery-related activities until a thorough <br />review of the new research findings can occur. In regard to consultation requirements <br />under the Act, we therefore find it appropriate during this interim period to use the best <br />scientific information available to determine if a USFS action may affect greenback <br />cutthroat trout (GBCT), including GBCT that may occur outside its historic range in <br />western Colorado. The USFS should determine the effects of any actions they fund or <br />authorize where GBCT are present. If an action may affect GBCT, including those found <br />on the west slope, initiation of consultation is appropriate. Although this e-mail was <br />specific to USFS actions, the Service believes that all federal agencies should review <br />their activities in a similar manner. <br />Colorado River Cutthroat Trout Conservation <br />The Colorado River cutthroat trout (CRCT) Conservation Team updated the <br />Conservation Strategy and Agreement in March 2006. Signatories to the Agreement <br />include the State wildlife agencies of Colorado, Utah, and Wyoming; the USFS, the <br />Bureau of Land Management (BLM), and the Service (CRCT Conservation Team 2006). <br />The purpose of the strategy is to provide a framework for the long-term conservation of <br />the Colorado River cutthroat, and to reduce or eliminate the threats that warrant its status <br />as a sensitive species or species of concern by federal and state resource agencies. The <br />objectives of the strategy are to identify and characterize all CRCT core and conservation <br />populations, secure and enhance conservation populations, restore populations, secure <br />and enhance watershed conditions, public outreach, data sharing, and coordination. The <br />three States, USFS, BLM, and the Service have committed to implement the strategy. <br />The Service believes that implementation of the CRCT strategy to conserve and protect <br />Colorado River cutthroat trout populations throughout their range will also adequately <br />2