The Platte River Project - Laserfiche WebLink

Home Browse Search

Commentlof the Platte River Project on the Platte Ri r Recovery Implementation Program DEIS NEPA a�d ESA compliance will be conducted prerequisite to establishment of any 2 °a his DEIS, however, analyzes the 1st Increment of the Proposed Program and its Alternat ives under two time periods: The first evaluates conditions at the end of the 1 st Increm t; the second "extends the simulation an additional 48 years, assuming that only the water pl in activities would continue." [DEIS, p. 4 -30]. The purpose of the latter analysis is purportt dly to detect geomorphic trends resulting from flow and sediment conditions and to evaluatc the sustainability of land plan changes occurring in the 1s` Increment. [DEIS, p. 4 -3I]. This is flawed approach. The analysis should be consistent with the length of the federal action under rc view. Moreover, even if an extended analysis were appropriate, it is unrealistic and arbitr, to analyze only water - related conservation activities during subsequent increments. Upon completion of the 0 Increment, either Program -driven or ESA - imposed mechanisms will be in pl ce to address long -term species and habitat conditions in relation to both water and land related ctivities. The effect of these mechanisms must be included should the analysis be extende I the equivalent of four additional increments. We are also concerned that the results of any Sed Veg Modeling are yet more unreliable when this tool is used to project impacts multiple decades into the future. We request that the long term analysis be corrected or that the analysi be consistent with the length of the federal action under review —13 years. The DEIS understates the benefits of the Proposed Program's land component. he land management sections of the DEIS should be rewritten to remove inaccuracies and bia in several respects. First, the effects of GC -1 (purportedly portraying the "minimum" range o outcomes under the Proposed Program) are not reflective of the actions described in the Prograr i. For example, islands and channel banks will be cleared to increase sight distance under the Pro am, yet the DEIS incorrectly portrays its effects as the same as under present conditions. An add tional quantity of sediment will result from island leveling in the monitoring and research prograr k and from vegetation removal; it is not "0" as described in the DEIS. The DEIS also states tl at the channel could narrow to 800 feet and portrays this as an adverse impact, even though his channel width would still constitute suitable habitat and, in fact, reflects the highest use cha el width for the species. econd, the DEIS inappropriately elevates the importance of, and impacts to, wet meado habitat. There is uncertainty regarding nutritional needs and food types ingested during crane rr igration. Whooping crane foraging data suggest extensive use of other land covers for foragin (i.e., irrigated fields). The DEIS describes a 31 % increase in lowland grass from 1982- 1998. his increase adds approximately 7,000 acres of lowland grass, for a total of 28,000- 30,000 cres of this land use type. Yet the DEIS directs its analysis toward projecting hypoth tical processes relating to "impacts" to wet meadows, rather than acknowledging and -10-