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State Concerns with Draft Biological Opinion
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State Concerns with Draft Biological Opinion
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Last modified
1/26/2010 4:40:23 PM
Creation date
7/10/2009 12:30:41 PM
Metadata
Fields
Template:
Water Supply Protection
File Number
8461.100
Description
Adaptive Management Workgroup
State
CO
Basin
South Platte
Water Division
1
Date
9/30/2004
Author
Unknown
Title
State Concerns with Draft Biological Opinion
Water Supply Pro - Doc Type
Report/Study
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aggressive island leveling plan is the scenario portrayed in the DEIS, as <br />capable of controlling chamnel degradation, increasing open view widths, and <br />building sandbars. [DEIS pp. 5-52 to 5-53; 5-156, etc.) The States believe <br />there is substantial uncertainty in these conclusions, and the Program was <br />written to address that uncertainty about potential outcomes with sediment <br />augmentation and pulse flow activities and about potential undesired impacts <br />on adjoining lands. The Program's IMKP thus embraces a phased, stair- <br />stepped adaptive management approach begirming with data gathering, further <br />investigations of potential rnanagement methods, development of testing <br />approaches, and implementation of small-scale testing of management <br />methods that, if successful :in outcome, would be tested at a progressively <br />larger scale before adopted as a routine management activity for Program <br />lands. [IMRP, at. 3, III.C, Fi. 10]. The Proposed Program does not commit to <br />implement the large-scale in-channel sediment management prescriptions in <br />advance of them "proving up." If they do not prove successful or have <br />unacceptable negative effec;ts, alternative management activities and methods <br />will be explored and implemented. <br />Instead of "hardwiring" this assumption, the BO should recognize that a <br />variety of outcomes are po:>sible and acceptable, including: <br />1) Sediment au;gmentation is feasible and effective on some scale, <br />and is incorTiorated into Program and EA Manager decision- <br />making. <br />2) Sediment au,gmentation is shown to be unnecessary under the <br />IMRP sedim.ent processes investigations. No mitigation <br />measures are: needed or implemented. <br />3) Sediment augmentation is shown by the IMRP investigations to <br />be infeasible:, ineffective, prohibitively expensive or damaging <br />to landowne:rs downstream. To satisfy the Land Plan, the GC <br />then focuses on other means of restoring and maintaining <br />Program lands. <br />b. Restoration of natural riverine functions as a Pro rg am Objective. <br />The draft BO assumes development of a"scientific adaptive management <br />framework" that includes adaptive management objectives of restoring a <br />semblance of natural riverine functions and processes (i.e., sediment supply <br />and transport, a more noririalized flow regime, and floodplain connectivity) as <br />a specific Program objective. [dB0 p. 3171 In addition, the draft BO assumes <br />that mechanical channel widening is not a substitute for "improvement of <br />ecosystem processes responsible for channel maintenance and ecosystem <br />sustainability" [dB0 pp. 219, 2271 <br />rl <br />991)91An000197c6tc z G <br />-
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