State Concerns with Draft Biological Opinion

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The states have never agreed to a program that calls for maintaining or sustaining the entire 90-mile reach of the central Platte River. The Program's objectives clearly state that we will provide "defined benefits" for the target species and their associated habitats, and that we will do so by providing land and water. The June 14-15 Agreement specifically retained language that the creation, protection and improvement of peak, pulse and other flows (aside from annual pulse flows) are not part of the ls` Increment water objective. It recognized that the Program would integrate its land and water management activities with the IMRP, Program Adaptive Management, and system constraints to enable evaluation of these issues, and that FWS could use Program water subject to its discretion to attempt to achieve a more normalized flow regime given system constraints. This is not a Program objective. The states believe that even the so-called sustainable ecosystem methods are untried, poorly supported, and may not provide the benefits anticipated by FWS. Even if widely adopted, they will need significant financial and artificial assistance over the years and thus are not truly sustainable. The states did not agree to nor does the program include assumptions that the program should be all natural or self-sustaining. Rejecting mechanical methods for habitat restoration and maintenance at this point in time prejudges the outcomes of the first increment before the actions can be properly evaluated under Program Adaptive Management and the IMRP. Instead of "hardwiring" this assumption, the BO should recognize that a variety of outcomes are possible and acceptable, including: 1) Sediment augmentation/pulse flow measures are feasible and effective on some scale and are incorporated into Program and EA Manager decision-making 2) Sediment augmentation/pulse flow measures are shown to be unnecessary under the IMRP sediment processes investigations. No mitigation measures are needed or implemented. 3) Sediment augmentation/pulse flow measures are shown by the IMRP investigations to be infeasible, ineffective, prohibitively expensive or damaging to landowners downstream. To satisfy the Land Plan and, therefore, provide habitat benefits for the species, the GC then focuses on other means of maintaining Program lands including using Program water in their managennent. c. Channel incision processes The draft BO states that there is a"larger recovery goal of stopping channel incision processes. [dB0 p. 232]. 99999Wnn"75053 3