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Comments on Draft EIS
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Last modified
1/26/2010 4:38:43 PM
Creation date
6/16/2009 1:06:31 PM
Metadata
Fields
Template:
Water Supply Protection
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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7- <br />29,000 acres of habitat for the species is c <br />Platte River is not limiting recovery (see ] <br />Governance Committee Alternative ensur <br />Simply put the Governance Committee al <br />necessary to ensure that the action can sei <br />y more than enough to ensure that the <br />Joint Study and References). The <br />the protection and management of this habitat. <br />native provides the requisite habitat that is <br />as a reasonable and prudent alternative. <br />10. The land management sections of the <br />should be rewritten to remove inaccuracies and <br />bias. The portrayal of Governance Commi tee 1 versus 2, as described in the DEIS, is to <br />"display a range of outcomes." The range f outcomes from Governance Committee 1 are <br />portrayed as a"minimum"; this is not refle tive of the actions described in the Program. For <br />example, islands and channel banks will b cleared to increase sight distance yet the DEIS <br />says that it is the same as present condition . An additional quantity of sediment will result <br />from island leveling in the monitoring and esearch program and due to vegetation removal; <br />it certainly is not 0 as described in the DEI . The DEIS states that the channel could narrow <br />to 800 feet which is suitable habitat for the species and in fact reflects the highest use channel <br />width by the species. <br />The DEIS inappropriately elevates the imp rtance of, and impacts to, wet meadow habitat. <br />Whooping crane foraging data suggests ex ensive use of other land covers for foraging (i.e., <br />irrigated fields) and there is reasonable uncertainty regarding nutritional needs and food types <br />ingested during migration. The DEIS des ribes a 31 percent increase in lowland grass (note <br />- the definition of wet meadow appears to e a term of art used in the Platte that is arbitrarily <br />defined but generally fits within this land use cover type) from 1982-1998. This increase <br />adds approximately 7000 acres of lowland ass increase for a total of 28,000-30,000 acres of <br />this land use type. Yet the DEIS directs its analysis on projecting hypothetical processes <br />relating to "impacts" to wet meadows rath r than acknowledging and emphasizing the <br />positive trends in lowland grass. The DEIS discusses impacts to wet meadow hydrology and <br />river stage without presenting any data eith r for present conditions or historic trends. This <br />misportrays the nature and magnitude of pr jected environmental consequences to the <br />species. <br />The DEIS disproportionately focuses on ri, <br />land management in the securing of habital <br />that "over the long-term ... habitat is more <br />period of analysis for the DEIS, however, i <br />the action alternatives will result in the mo <br />removing in many cases land covers that ar <br />and not altered by flows far in excess of flc <br />crine processes and underestimates the value of <br />For example, the DEIS team offers the opinion <br />strongly influence by the water plan." The <br />13 years; the land management methods under <br />; immediate and dramatic changes in habitat, <br />; over 40 years old and that have been subject to <br />recommendations <br />The DEIS team has a clear bias toward "wi <br />tradeoffs involved with such an approach. <br />terns, where the authors state the need for ` <br />protection." This is an opinion; the author; <br />relationship between sight distance and pre <br />disclose the consequences and trade offs oj <br />wider channels may in fact be more difficu <br />reduced. This is not analyzed in the DEIS. <br />ier is better" habitat, yet does not discuss the <br />A,n example is in the discussion of open areas for <br />-ide channels "presumably far early predator <br />do not have data on predation and the <br />iator success. The DEIS should carefully <br />managing for wider channels. For example, <br />t to manage and river stage changes will be <br />Flood Protection • Water Project Planning ?nd Finance • Stream and Lake Protection <br />Water Supply Protection ?? Conservation P1aruling
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