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THE PLATTE RIVER PROJECT September 20, 2004 Platte River EIS Office (PL -100) P.O. Box 25007 Denver, Colorado 80225 -0007 Re: Comments of the Platte River Project on the Platte River Program Draft EIS. The Platte River Project of the Colorado Water Congress (PRP) represents over 25 water use entities within the South Platte River basin in Colorado. Collectively, the PRP membership reflects a diverse array of private and governmental organizations which supply water for municipal, agricultural, industrial, and other beneficial purposes. Many PRP members hold federal permits for their water diversion and distribution facilities or may need to secure federal agency authorizations related to their facilities in the future. These entities have worked since the mid -1990s to support development of a cooperative basin -wide program that will afford regulatory certainty to water users under the ESA and bring coordinated resource benefits to the Platte River target species. The PRP has been supportive of the Proposed Program as framed by the 1997 Cooperative Agreement (CA). Our comments on the Draft Programmatic Environmental Impact Statement (DEIS) are offered from that perspective, in efforts to promote issuance of a final EIS that analyzes the Proposed Program and its alternatives in an accurate and legally defensible manner. Unfortunately, we read the DEIS analysis as potentially inconsistent with the framework of the Program that is proposed. From the PRP's perspective, that framework was constructed as a means to move forward on a joint cooperative basis in the face of acknowledged scientific uncertainty and/or disagreement on a host of complex biological, hydrological, and technical issues concerning Platte River basin resources. As discussed in the itemized comments that follow, we are concerned that the Draft EIS mischaracterizes the Program by assuming implementation of specific management actions potentially inconsistent with or beyond those described in the Proposed Program. The Draft EIS also utilizes results -based performance standards or benchmarks that are not part of the deliverables agreed to by the signatories, and employs contested methodologies to measure the Proposed Program and its alternatives against such standards. The PRP asks that the EIS be revised to portray the Program as a vehicle equipped to work through future uncertainties and react to developing knowledge and trends to the species and habitat on the Platte using a range of strategies and responses during the 1" Increment, pursuant to its defined resource and funding contributions, management protocols, integrated monitoring and research plan (IMRP), Program