Laserfiche WebLink
Comments of the Platte River Project on the <br />Platte River Recovery Implementation Program DEIS <br />emphasizing the positive trends in lowland grass resources. The DEIS also discusses impacts to <br />wet meadow hydrology and river stage without presenting any data for present conditions or <br />historic trends. This misportrays the nature and magnitude of projected environmental <br />consequences to the species. <br />Third, the DEIS disproportionately focuses on riverine processes and underestimates the <br />value of land management in the securing of habitat. For example, the DEIS team offers the <br />false opinion that "over the long - term... habitat is more strongly influenced by the water plan." <br />The period at issue for the DEIS, however, is 13 years; the land management methods under the <br />Action Alternatives will result in the most immediate and dramatic changes in habitat, removing <br />in many cases land covers that are over 40 years old and that have been subject to and not altered <br />by flows far in excess of flow recommendations. <br />Fourth, the DEIS team has a clear bias toward "wider is better" habitat, yet does not <br />discuss the consequences and trade offs involved with such an approach. An example is in the <br />discussion of open areas for terns, where the authors state the need for wide channels <br />"presumably for early predator protection." This is speculation; the authors do not have data on <br />predation and the relationship between sight distance and predator success. Wider channels may <br />in fact be more difficult to manage and river stage changes will be reduced. This is not analyzed <br />in the DEIS. <br />8. The "present condition" portrayed in the DEIS does not reflect use of the <br />best scientific and commercial information currently available and fails to <br />reflect environmental and ecological variability which has occurred over <br />time. <br />Reasonable, appropriate scientific methods are not used in the DEIS to evaluate present <br />conditions. The most recent species and habitat information is not used (i.e., whooping crane <br />and sediment investigations conducted during the Cooperative Agreement, data regarding tern <br />and plover use of non - riverine habitat, and vegetation studies). The limitations of baseline data <br />are also not disclosed. A technical review of the baseline data revealed significant deficiencies <br />which previously lead the Service to conclude that the information could not be used as a <br />quantitative baseline. [See C.A. Technical Committee comments dated October 22, 1999, and <br />subsequent comments through 2003; see also John Nickum comments, U.S. Fish and Wildlife, <br />April 2000 Technical Committee minutes]. Yet the information is erroneously recreated in the <br />DEIS. Examples of deficiencies include: lack of defined methodologies for data collection, <br />changed conditions between observations and data collection, use of non -peer reviewed models <br />and methods, and use of models that have not been updated with current information. <br />The DEIS also establishes a present condition which does not reflect the environmental <br />and ecological variability that has occurred over time. This is especially true in regard to climate <br />-11- <br />