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Comment# of the Platte River Project on the <br />Platte Ri r Recovery Implementation Program DEIS <br />changeslThe mid -1800s were a period of extreme drought followed by a wet period in the early <br />1900s. fhe river channel configuration and land use cover used in the DEIS do not reflect a <br />"baselin condition," as the geomorphology and land cover were reacting to dramatic climatic <br />shifts arid the impact of settlers moving west. <br />he summary of river trend and fluvial processes does not adequately take into account <br />the natu al variability of the system and does not present sufficient data to support its hypotheses <br />and con lusions. For example, there is no description of the presence and configuration of "sand <br />bar habi at." No data is presented describing historic versus current trends in the frequency, <br />distribu 'on, size, and elevation of sand bars. A more qualitative analysis is appropriate where <br />there <br />at 2 -1). <br />have of <br />river an <br />chapter <br />and the <br />the incr <br />Forests, <br />USDA <br />from th <br />time wl <br />year the <br />Impact <br />22,200 <br />previou <br />Troend <br />Forests <br />decreas <br />greater <br />uncertainties, lack of quantitative data, and system variability. <br />The DEIS fails to adequately disclose and analyze the effects of Federal <br />forest and vegetation management actions. <br />A. DEIS Chapter 2: History of Habitat Use and Habitat Trends for the <br />Target Species. <br />iapter 2 of the DEIS describes, among other topics, "how changes in the river and <br />ng area have altered the available habitat" for the four listed species in question (DEIS <br />Special attention is given to describing how settlement and development of the Basin <br />-ted riverflows and sediment transport, which, in turn, have affected the key aspects of <br />riverine habitat used by the target species." (DEIS at 2 -12.) The remainder of the <br />)cuses almost exclusively on the extent of water supply development for human use, <br />Tects of such development upon river flows and, in turn, upon the Central Platte River <br />bsent from the entire chapter is any discussion of the loss of historical water yield from <br />ased density of forests located in the basin, chiefly on lands now reserved as National <br />While the total extent of such water depletions may be a matter of some uncertainty, the <br />orest Service has retained consultants who most recently estimated these depletions <br />North Platte River basin alone at an average of 166,000 acre -feet per year between the <br />en the National Forests tributary to that drainage were created (ca. 1900) and 1997, the <br />Platte Cooperative Agreement was signed. [Charles A. Troendle et al., Final Report, The <br />f Forest Service Activities on the Stream Flow Regime in the Platte River, p. 10 (May <br />(2003 Troendle Report)]. This figure is a slight downward estimate of depletions <br />ly calculated by some of the same consultants while retained by the USBR. [Charles A. <br />et al., Estimating Additional Water Yield from Changes in Management of National <br />n the North Platte Basin at 43 -44 (May 12, 2000) (2000 Troendle Report) (calculating "a <br />of 185,000 acre -feet or more of water from 1. 107,000 acres of NFS land," which "is <br />han that estimated to have occurred using existing stream flow records ")]. <br />-12- <br />