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Comments ff the Platte River Project on the Platte Rive4 Recovery Implementation Program DEIS adaptive management tools, and decisionmaking structure. We believe that this should be the Preferred Alternative, if a cooperative approach is to succeed. Our itemized comments follow. GENERAL COMMENTS The DEIS understates the benefits of the Proposed Program and overstates the potential viability of the Action Alternatives. he DEIS materially understates the benefits of the Proposed Program. Elements of the Propose Program are the result of negotiations toward a basin -wide cooperative approach spannin a decade (since the 1994 framework agreement) and addressing a spectrum of issues on the Platte ranging from the needs of the species and habitat, to the needs of water users in the basin, to financial, institutional and legal constraints. Many features of the Proposed Program are acceptat le to the PRP only as part of the specific package negotiated among the three states, federal vernment, water users and environmental community. he DEIS portrays several "Action Alternatives" to the Proposed Program "empha iz[ing] a different focus or approach" [DEIS, p. 3 -6]. The DEIS points out that 4cagreerr ent of all parties to a cooperative approach in other contexts should not be inferred." [DEIS, I 1. 3 -71. That statement is correct. The DEIS, however, continues by incorrectly assumir g that the key commitments and undertakings by the states and resource users under the Propose Program can and will be incorporated into each Action Alternative. These commit nents include: (1) contribution of the three States water projects "as a basic water supply" (2) state and federal depletions plans to address the effects of future water depletions; (3) cooi dinated water management in conjunction with the Service's EA manager; (4) legal and institute )nal protections for Program water through the habitat reach; (5) a land management compor ent assuming willing seller/buyer and incorporating tracts of land designated for inclusic n under the Proposed Program; (6) policies to protect Nebraska landowners; (7) a well - funded MRP; and (8) a 50/50 federal /state cost - sharing framework. [DEIS, pp. 3 -18 to 3 -211. 17hat is simply not realistic from the PRP water users' perspective. Each of the above core el ments reflects a negotiated accommodation as part of the overall Program that is proposed. Incorporating these elements as a base assumption into all Action Alternatives is not on ] y incorrect; it understates and materially misportrays the substantive benefits that we viet as part of - and only part of - the Proposed Program. The EIS should make clear that t Action Alternatives would likely not include or embody these key elements. The PRP supports the Proposed Program as framed by the 1997 Cooperative Agreement. -2-