Comments on Draft EIS

• File Number: 8461.100
• Description: Adaptive Management Workgroup
• State: CO
• Basin: South Platte
• Water Division: 1
• Date: 9/17/2004
• Author: CWCB
• Title: Comments on Draft EIS
• Water Supply Pro - Doc Type: Board Memo

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4
5.
The CWCB remains hopeful that we will
Governance Committee Alternative. The
alternatives" due to legal, technical, finan
these alternatives.
The DEIS contains extensive opinions wr
history of habitat use and trends for the ta
objective and unbiased. The DEIS should
alternatives and a factual assessment of th
substantiating the positions or outcomes t
6. The DEIS should be revised to remove
7. Reasonable, appropriate scientific methoc
conditions. The most recent species and I
and sediment investigations conducted du
regarding tern and plover use of non-river
limitations of baseline data are also not di
(see CA Technical Committee comments
though 2003; see also John Nickum comn
Technical Committee minutes) reveled sil
Service to conclude that the information c
above references). Yet the information is
deficiencies include: lack of defined meth
between observations and data collection,
and use of models that have not been upd,
The DEIS also establishes a present condii
ecological variability that has occurred ovf
changes. The mid-1800s were a period of
early 1900s. The river channel configurati
reflect a"baseline condition", as the geom
dramatic climatic shifts and the impact of ;
The summary of river trend and fluvial y
natural variability of the system. Suffici
conclusions. For example, there is no de:
bar habitat". No data is presented descri
distribution, size, and elevation of sand t
where there are uncertainties, lack of qu,
8. The DEIS analysis of impacts and environr
Sediment Vegetation model. There are sigr
promising but unproven tool. The states oi
independent review of the data and model 4
Dynamics Investigation, Parsons, May 200
regarding the definitive conclusions reache
relationships (geomorphic, plant physiolog
Flood Protection • Water Project P1aruling
Water Supply Protection
able to support the Proposed Program and the
VCB does not support any of the "other action
l, and political issues associated with each of
;h should be removed from the document. The
;et species and the impact analysis are not
e a factual summary of the no action and action
outcome of the federal action. In addition, data
Lt are stated must be provided and referenced.
inconsistencies.
are not used in the DEIS to evaluate present
bitat information is not used [i.e., whooping crane
ng the Cooperative Agreement (CA), data
[e habitat, and vegetation studies]. The
losed. A technical review of the baseline data
d October 22, 1999, and subsequent comments
3, United States Fish and Wildlife, Apri12000
cant deficiencies, which previously lead the
l not be used as a quantitative baseline. (see
neously recreated in the DEIS. Examples of
ogies for data collection, changed conditions
of non-peered reviewed models and methods,
with current information.
n which does not reflect environmental and
time. This is especially true in regard to climate
:treme drought followed by a wet period in the
i and land use cover used in the DEIS do not
?gy and land cover were reacting to
moving west.
esses does not adequately take into account the
data is not presented to support hypothesis and
ption of the presence and configuration of "sand
g historic versus current trends in the frequency,
. A more qualitative analysis is appropriate
data, and system variability.
tental consequences relies too heavily on the
ficant unknowns regarding the use of this
Colorado, Nebraska, and Wyoming had an
eveloped by DOI (see Platte River Channel
?). The Parson's review cast serious doubt
l by DOI. Significant issues concerning process
, and the linkage of the two) and calibration and
Zd Finance • Stream and Lake Protection
Conseroation P1amling