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~ I . e e e OU1510 DRAFT May 10. 1995 PLATTE RIVER PROJECT The Platte River Project (Project!. a consortium of major water prOViders and users In the South Platte RIver Basin. supports the development and Implementation of the Platte River Recovery Implementation Program (Program). which will provide effective conservation of federally-listed species and reasonable and prudent alternatives for projects In the South Platte Basin In Colorado which are subject to Section 7 consultation. Durtng the three-state MOA meeting In Denver on April 27. 1995. Colorado. Wyoming. and Nebraska. as well as the Department of Interior reached consensus In deftn1ng four elements that should be considered In a basin-wide recovery program. These elements Include regulatory certainty. adaptive managemenL a land element. and a water element. The PrOject continues to support the development of the Program. and generally supports the l11c1uslon of these four basic elements Into the Program. There will be many questions to be resolved and many concerns to be addressed. We look forward to partiCipating In the resolution process. One of our concerns Is that any implementation of adaptive management must not undercut the need for regulatory certainty. In addition. the concept of adaptive management must Include appropnate peer revlew and a cOIllprehenslve monitoring plan so that decisions concerning habitat management are made on the basis of good data and sound science. and be IIDplemented over a long enough time period so that the SPedes response can be measured. With respect to the land and water elements. the Program must be slnlctured In a manner that , ensures that the numertc "goals" are not transformed Into "mlnJmum levels" or mandatory and enforceable requirements. '!be PrOject supports further progress under the MOA and believes that Colorado can playa significant role in the Program. However. the Program shQuld not contain the following: 1) a determination of each state's "fair share" of the water delivery target flows In Nebraska if that IIDplies that Colorado's obUgations to the Program are other than those established by the South platte RIver Compact; or 2) a I1m1tatlon on existing or a cap on future water use In Colorado. If either of these issues become a condition for further partiCipation in the basin-Wide program. the Project requests that the State of Colorado enter Into negotiations With the United States regarding the development of a Colorado Program. The Colorado Program would: address listed species and designated habitat concerns: serve as the reasonable and prudent alternative for Section 7 consultations for water 'projects,ln Colorado: and allow existing and future uses of water In Colorado made In accordance With the South Platte RIver Compact. 1