Specific Comments on Platte River Draft EIS

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largely inundated suitable sandbar habitat at the and piping plover. Extended no flow periods oc( Figure 7). The historical tendency of the central is well documented, was not conducive to succf would have reduced, and likely eliminated, adjac Finally, despite regular observations of least tern the century, historical sighting records provide n the Platte River from east of the confluence of the The first record of least tern nesting along the cE perennial flows were established in this reach by plovers in the same area was in 1950. These considerations indicate that regular use of and including the Big Bend reach, by least terr occasioned by the onset of permanent, moder; operation (EA, 1988) and the availability of e construction of I-80 and subsequent sand and gr habitat (please see piping plover data for Lake Mc Water storage has reduced drastic water level c] acted to limit utilization and/or nesting success t] reduction of adjacent food supplies, and exposure existing piping plovers and least terns, water de conditions which allow them to inhabit the Platte ] Prior to flow regulation, extreme flow vari; substantially diminished, and likely eliminated, Platte River channel upstream of the Loup River. ne of arrival and nest selection for the least tern rred during the nesting season prior to 1941 (see latte to go dry during the summer months, which sful nesting. Prolonged dry riverbed conditions nt feeding areas and exposed nests to predation. and piping plovers in Nebraska since the turn of reference to regular occurrence of species along orth and south Platte to the Loup until after 1941. .tral Platte was in 1942 near Lexington, the year iater project operation. The first report of piping he Platte River upstream of the Loup confluence, and piping flow is a more recent phenomenon e flow conditions resulting from water project tensive habitat provided by sand pits from the vel mining as well as the availability of "shore" ;onaughy). nges from floods and droughts that historically ough inundation of potential or active nest sites, f nest sites to predation. Rather than threatening -lopment and land use changes has created the ver upstream of the Loup. ility during the breeding season would have .bitat suitability and reproduction potential in the The habitat far the least tern and piping plover on the central Platte has been enhanced, if not created, as a result of water development activities. The states are now asked to create the near ideal conditions, which may have occurred historically i other areas such as on the Missouri River, but which never existed historically on the Platte Riv r upstream of the Loup. This is an inappropriate use of the powers of the Endangered Species Act. Rather than jeopardizing the species in question, water development activities in the Platte have cre ted the habitat now designated as "critical." 4.0 Questions Regarding Procedures to be Usedl by the Committee The Colorado Water Conservation Board has re provided on the NAS website. We have a number be used by the Committee. These questions are in provided below. ewed the scope of work for the Committee as f questions regarding methods and procedures to -rted into the Committee's scope of work and are We believe that addressing these questions is cri i work. As we review the Committee's draft report, basic questions. However, should the Committee directly to the Board, that would be most appreciat i d to successfully completing the Committee's will be looking forward to the answers to these ?ose to address these questions with a response A- 18