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Comments of the Platte River Project on the <br />Platte River Recovery Implementation Program DEIS <br />The Proposed Program offers a cooperative basin -wide approach that will bring <br />coordinated resource benefits to the species and regulatory certainty to water users under the <br />ESA. We believe that the Proposed Program is desirable to No Program - where water users <br />would be faced with separate ESA Section 7 consultations and mitigation for individual water <br />projects and where the species would, at best, be addressed through piece -meal permitting <br />actions that only require the offset of impacts instead of the enhancements provided by the <br />Proposed Program. We do not support Action Alternatives that would emphasize Water Leasing <br />in addressing the Program's water goals, or that would focus on acquiring more water with less <br />emphasis on land habitat management in Nebraska for the species. While the PRP is supportive <br />of the Proposed Program, we request that the DEIS portrayal of the "GC Alternatives" be <br />clarified to reflect the flexibility in management approaches and outcomes allowable under the <br />framework of the Proposed Program. This concern is discussed further in Comment 3 below. <br />3. The EIS and Biological Opinion must recognize that the Program embodies a <br />range of permissible land and water management strategies and habitat <br />responses during the 1St Increment. That range of possibilities emanates <br />from and is limited by the use of defined resource contributions by the <br />signatories. <br />The Proposed Platte River Recovery Implementation Program embodies a cooperative <br />approach to benefit the target species in the face of significant scientific uncertainty and <br />disagreement. As recognized in the Program documents, differences of opinion surround many <br />issues related to Platte River basin land and water resources, including the FWS target flows <br />[Program Document, III.A. 3. b.1, fn. 6, p. 51, peak flow recommendations [Program Document, <br />III.E.1.b., p. 12], and proposed short-term channel management "pulses" [Program Document, <br />III.E.1.c., p. 13; IMRPAtt. 3, p. 22]. Uncertainty also exists concerning the role of non - complex <br />habitat areas in meeting species' needs, concerning the role of sediment and vegetation in <br />maintaining channel widths in the central Platte [Program Document, IMRP, Att. 3, p. 10], and <br />concerning the responsibility and role of Missouri River entities to address habitat issues for the <br />pallid sturgeon and the effects, if any, of water - related activities on habitat for the pallid in the <br />lower Platte River [Program Document, III.E.1.d., p. 13]. This is only a partial list. The <br />Proposed Program is remarkable in that it holds promise of moving forward in the face of these <br />uncertainties and despite the disagreements. It does so because, while the signatories may not <br />agree on the science, they can agree to undertake defined contributions aimed at benefitting the <br />species, coupled with procedures to learn as we go and adjust specific management strategies <br />through time. <br />The framework of the Proposed Program is structured with an awareness of these <br />realities. First, "it includes certain activities and contributions from the states and the federal <br />government to be conducted during incremental time periods..." [Program Document, p. 2]. <br />-3- <br />