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? <br />Specifically, the Service has become increasingly concerned over sediment issues in the <br />critical habitat. It appears the Service believes that the construction of dams, especially on <br />the North Platte, coupled with the reduction in peak runoff caused by water storage activities <br />on the North and South Platte has reduced sediment transport to and through the Central <br />Platte. The Service seems to be linking sediment transport to the development and <br />sustainability of the "idealized" habitat conditions (wide, braided, open channels with <br />dynamic island formation, erosion, and reformation) in the Central Platte. <br />The EIS team has developed a water banking alternative (leasing of storage water in several <br />Colorado reservoirs) that would have Colorado releasing much of it's water contributions to <br />the Program during spring high flows May and June (pulse flows) to aid in sediment <br />transport and vegetation maintenance in the Central Platte. This type of alternative may also <br />be appealing to the other states and environmental interests because it would involve <br />reducing beneficial use of water in Colorado rather than our current plan which relies on <br />retiming water from periods of excess to periods of shortage. The problem is that this type of <br />alternative is unacceptable to our water users, raises administrative and legal issues (water <br />export and Compact implications), and arguably deprives Colorado water users of full <br />beneficial use of water. <br />With the pending change in federal leadership in Washington and the deadline for the end of <br />the CA approaching there has been a frenzy of activity. The Department of Interior (DOI) <br />very much wants to sign a"Proposed Program" by January 2001. In their haste they seem <br />willing to push many important unknowns into the milestones for the "Proposed Prograzn" <br />and to finalize documents which are incomplete or could be significantly improved with <br />time. We are especially concemed that this could affect the PEIS and Programmatic <br />Biological Opinion. However, at this time all parties are reluctant to push for a more realistic <br />schedule change because they feel they will be viewed as "killing" the "Proposed Program". <br />A final issue is a little difficult to describe, but can generally be characterized by a lack of <br />flexibility, creativity, and cooperation. This seems to be most prevalent among the biologist <br />and technical team members of the Service, and appears to be especially true of the Grand <br />Island office. We believe that Colorado and the other states entered into the CA with the <br />expectation that a more collaborative and unbiased approach to the issues was needed and <br />would be provided via the CA process. During the recent months as difficult issues have <br />been discussed the Service's technical representatives have been extremely resistant to <br />compromise or to seek mutually acceptable solutions. <br />In general there has been remarkable agreement among the state's technical representatives <br />and the state's water users technical representatives. The Service has often been in <br />disagreement with majority views, and has basically taken the position that; they have heard <br />what has been said a.nd have a different opinion and are unwilling to change or modify their <br />opinion. Furthermore, the Service seems to suggest that the states and water users need to <br />just go along with their opinion because the Service does not want to azgue about the issues <br />any more. They also raise the defense that they can not abrogate their regulatory <br />responsibility.