CDOW review and comments of the PRRIP Draft Environmental Impact Statement

• Description: related to the Platte River Endangered Species Partnership ‎(aka Platte River Cooperative Agreement [CA]; aka Platte River Recovery Implementation Program [PRRIP])‎
• State: CO
• Basin: South Platte
• Water Division: 1
• Date: 9/20/2004
• Author: Bruce McCloskey, Director DOW
• Title: Platte River EIS Office
• Water Supply Pro - Doc Type: EIS

STATE OF COLORADO
Bill Owens, Governor
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF WILDLIFE
AN EQUAL OPPORTUNITY EMPLOYER
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Bruce McCloskey, Director
For 4Viddlife-
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Denver, Colorado 80216
For People
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Telephone: [phone]
September 20, 2004
Platte River EIS Office
PO Box 25007
Denver, Colorado 80225 -0007
To Whom It May Concern:
The Colorado Division of Wildlife (CDOW) has received and reviewed the Platte River Recovery Implementation
Program Draft Environmental Impact Statement (DEIS) and this letter constitutes the comments of this agency.
In reviewing the DEIS, the CDOW has identified several issues particular to Colorado which need specific points
of addressing or clarification.
1. No Preferred Alternative selected. The DEIS describes and analyzes four (4) possible action alternatives:
Governance Committee Alternative; Water Leasing Alternative; Wet Meadow Alternative; and Water
Emphasis Alternative. However, the DEIS fails to identify a preferred alternative. The CDOW
recommends the DEIS identify the Governance Committee Alternative as the preferred alternative. Future
modification of this alternative should be consistent with the adaptive management concept.
2. Fish and Wildlife Coordination Act (FWCA). The DEIS indicates on page 6 -6 that "Discussions of the
alternatives and possible impacts to States' wildlife resources have been held with each States' wildlife
agency." The only action alternative described in the DEIS that the Colorado Division of Wildlife has
reviewed is the Proposed Program referred to as Governance Committee Alternative (GCA). Formal
FWCA coordination has not occurred with CDOW. The CDOW has not been consulted on the other three
alternatives by the Service as mentioned. We are concerned about the potential impacts the other three
alternatives may cause to fish and wildlife resources in Colorado. The CDOW request the appropriate
Service representatives meet with its staff to discuss more fully these other three alternatives.
3. The GCA appears to adequately address migratory birds in Colorado. If GCA)t is not selected, issues
associated with the MBTA may require future analysis. The water leasing and water emphasis alternative
could have significant impacts on migratory birds as they pass through Colorado.
a. Substantial impacts to waterfowl, passerines and other migratory birds are likely to occur through
the water leasing and water emphasis alternatives. These impacts need to be further analyzed.
b. The water leasing and water emphasis alternatives would result in negative impacts to wetlands in
the South Platte Basin in Colorado. This issue was not addressed, and impacts to wetlands and
waters of the United States as well as the associated mitigation strategies need to be developed and
described.
DEPARTMENT OF NATURAL RESOURCES, Russell George, Executive Director
WILDLIFE COMMISSION, Philip James, Chair • Jeffrey Crawford, Vice -Chair • Brad Phelps, Secretary
Members, Bernard Black • Tom Burke • Rick Enstrom • Claire O'Neal • Robert Shoemaker • Ken Tones
Ex Officio Members, Russell George and Don Ament