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vote of the FWS. Neither tlhe states nor any of the other participants have an <br />interest in spending money in ways that provide no benefit. The BO should <br />assume that land acquisitions will be beneficial either by increasing available <br />habitat or preventing habitat loss. <br />2. Pallid Sturgeon conservation measures. <br />The draft BO assumes that "appropriate conservation measures will be defined <br />and implemented during the, first Program increment that either negates or <br />offsets adverse impacts to the pallid sturgeon...." [dB0 p. 318] Under the <br />June 14-15 Agreement, the states documented their questions about the <br />biology of the pallid sturgeon and the role of the lower Platte River in the <br />species' recovery. It was agreed that the IlVIRP is to assess potential impacts to <br />the sturgeon. Appropriate :measures will be addressed only if impacts of the <br />Program are deemed to "aclversely affect" the species. The draft BO assumes <br />that offsetting measures will have to be implemented. <br />Instead of "hardwiring" this assumption, the BO should recognize that a <br />variety of outcomes are possible and acceptable, including: <br />a. No hydrolog;ic impacts are identified under the IMRP <br />investigatioris. No mitigation rneasures are needed or <br />implementeci. <br />b. Hydrologic iimpacts are identified under the IMRP <br />investigations, but no biological impacts are associated with <br />those hydrologic impacts that adversely affect the species. No <br />GC mitigation action is necessary and no measures are <br />implemente(i. <br />c. Biological impacts are identified and measures are implemented <br />to benefit paillid sturgeon. <br />The draft BO also assumes that Program water reaches the lower Platte, minus <br />only normal conveyance losses, that such water will be tracked to and through <br />the lower Platte, and, if shortages are identified, the Program will institute <br />acceptable measures to avoid or offset those shortages. [dB0 p. 193]. In the <br />June 14-15 Governance Committee agreement, the Service dropped this issue, <br />which it had identified in its May 17 handout. The June 14-:15 agreement <br />requires tracking, but does, not require the Program to take steps to guarantee <br />delivery of program water to the lower Platte less normal conveyance losses. <br />This change needs to be re:flected in the BO. <br />3. Primary focus upon "habit:at restoration" <br />99999'900,,,9756, ?.? 6