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-4- The DEIS, however, goes on to assume th t each action alternative will incorporate the key commitments and undertakings by the stat s and resource users under the Proposed Program. These commitments include: (1) contributi n of the three States water projects "as a basic water supply"; (2) state and federal depleti ns plans to address the effects of future water depletions; (3) coordinated water manage ent by the Service's EA manager; (4) legal and institutional protections for Program water in the habitat reach; (5) a land management component assuming willing seller/buyer nd incorporating tracts of land designated for inclusion under the Proposed Program; (6) policies to protect Nebraska landowners; (7) a well-funded IMRP; and (8) a 50150 federal state cost-sharing framework. Colorado continues to support these comi incorporating these elements as a base as incorrect; it understates and materially m and only part of - the Proposed Program. realistic range of action alternatives that c tments for the Proposed Program. However, mption into all action alternatives is not only ?ortrays the substantive benefits that are part of - The DEIS should be rewritten to illustrate a more not embody these key Program benefits. 3. The Proposed Platte River Recovery Imp approach to benefit the target species in t: disagreement. As recognized in the Prog many issues related to Platte River basin remarkable in that it holds promise of mo despite the disagreements. It does so bec science, they can agree to undertake defir with procedures to learn as we go and adj nentation Program embodies a cooperative face of significant scientific uncertainty and n documents, differences of opinion surround d and water resources. The Proposed Program is ig forward in the face of these uncertainties and >e, while the signatories may not agree on the contributions to benefit the species, coupled t specific management strategies through time. It is critical that the DEIS and the United tates Fish and Wildlife Service's (Service) biological opinion on the Proposed Prograrn recognize this cooperative framework - consisting of defined contributions of the s gnatories, implementation of activities as described in the Program documents as the way to work through scientific uncertainty and disagreement during the lst Increment, and a rigorous monitoring and research plan to facilitate adaptive management responses nd establishment of objectives and milestones for future Program increments. We are conce ed that the DEIS portrayal of potential environmental consequences from the acti n alternatives not be taken to restrict the range of permissible coarse of action under the Pro am's lst Increment. We believe that the framework and resoi a reasonable approach for avoiding jeop? scientific uncertainty. The DEIS fails to designed to react to trends in the species DEIS and Service's biological opinion s',? work through future uncertainties and m flows, sedimentation, habitat lands and c predetermine the specific management a request that the Department of Interior a: implementation of the ls` Increment MiIE result in a range of permissible managen c commitments in the Proposed Program provide y and addressing species needs in the face of lect that this jointly implemented program is habitat using a variety of management tools. The ild evaluate the Program as a vehicle equipped to gement options on the Platte with respect to ;r issues, and not unilaterally attempt to )ns that are today thought "acceptable." We yze the Proposed Program as based upon ?nes and with specific recognition that it may t strategies and responses. Flood Protection • Water Project Planning ?nd Finance • Stream and Lake Protection Water Supply Protection I• Conservation Plaiututg