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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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of providing the assumed deliveries within the first increment water <br />objectives, Section E of the Program Document (the water component), and <br />Program budget. <br />Instead of "hardwiring" this assumption, the BO should recognize that a <br />variety of outcomes are possible and acceptable, including: <br />1) Delivery of these quantities of water is feasible and effective <br />and is incorporated into Program and EA Manager decision- <br />making <br />2) Delivery of 5000 cfs of Program water for 3 days at Overton is <br />shown to be unnecessary under the IMRP investigations. No GC <br />action is necessary and no mitigation measures are <br />implemented. <br />3) Delivery of 5000 cfs of Program water for 3 days at Overton is <br />shown to be infeasible, ineffective, prohibitively expensive or <br />damaging to landowners downstream under the feasibility <br />investigation identified above or the INIlZP investigations of <br />pulse propagation. To satisfy the Land Plan, the GC then <br />focuses on other means of restoring and maintaining Program <br />lands. <br />4) Delivery of 800 cfs at the habitat during the irrigation season is <br />shown to be infeasible, ineffective, prohibitively expensive or <br />damaging to landowners downstream under the feasibility <br />investigation identified above. This seems unlikely given the <br />options of the Water Action Plan, but could be used as a reason <br />to choose different WAP water projects in the normal course of <br />GC flexibility in implementing that plan. <br />e. Focus on lands above Kearnv <br />The draft BO assumes that most Program lands will be located above Kearny. <br />[dB0 p. 193] Under the June 14-15 Agreement, this is one of the preferences, <br />along with segments needing restoration, segments with habitat that can be <br />most reasonably improved, those with existing habitat that is not already being <br />protected and is likely to be lost, and those that do not currently have any <br />protected habitat. The draft BO assumptions are more restrictive than the <br />negotiated criteria under the Land Management Plan. <br />Instead of hardwiring the "above Kearny" assumption, the BO should <br />recognize that this preference is based solely on providing an upstream source <br />of sediment based on the untried SEDVEG model and sediment augmentation <br />measures. Depending on the outcome of the sediment augmentation/pulse <br />flow investigations described above, the rationale for this preference may be <br />validated or discounted. No land can be acquired by the Program without the
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