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Comment of the Platte River Project on the Platte Ri er Recovery Implementation Program DEIS These d fined contributions, consisting of the 1St Increment Land and Water Objectives detailed in the P ogram document [Program Document P Increment Objectives, III.A.3.b., p. 5], are key to Coloi ado water users' ability to quantify their responsibilities under the Program and to secure legislative, public, and funding support for entering into the 1St Increment. Second, the land and water contributions are coupled with a rigorous Integrated Monitoring and Research Program designe to fill in gaps in our baseline information, assess trends in species and habitat conditic ns, bolster our understanding of the species' needs, and test, monitor and evaluate the impacts of activities implemented in the 1St Increment on the associated habitats and target species. [Program Document, III. C. 3. & 4., p. 8; IMRP, Att. 3]. Third, the Program is designed to unfol I in the context of an adaptive management process, whereby mid - course adjustments to activitic 3 may be made based upon new information, practical considerations and experience, provide I such changes are consistent with the 1St Increment Objectives. [Program Document, III. C. 1., a. p. 7]. The duration of the 1 st Increment is relatively short, reflecting a judgment as to the amoint of time needed to implement and assess Program activities and afford a reasonable period c f regulatory certainly for water users under the ESA. is critical that the EIS and the FWS biological opinion on the Proposed Program recognize this cooperative framework - consisting of defined contributions of the signatories, implem ntation of activities as described in the Program documents as the way to work through scientif uncertainty and disagreement during the 1St Increment, and a rigorous monitoring and researcl. plan to facilitate adaptive management responses and establishment of objectives and milestoi es for future Program increments. We are concerned that the DEIS fails to disclose the signific nt areas of scientific uncertainty and dispute regarding how and why the Platte River has changec historically and what needs to be done to fix it. This concern is addressed in detail in the writ en comments of Carter Johnson, which we endorse. We are further concerned that the DEIS portrayal of the GC -I and GC -2 Alternatives and their potential environmental consequ ences not be interpreted to restrict the range of permissible responses under the Prosy 's I"' Increment. he Draft EIS evaluates two GC scenarios in attempts to illustrate a range of possible effects f rom the Proposed Program relating to the locations of Program lands, extent of habitat restorati Dn, and the Program's ability to deliver water to the habitat. [DEIS, p. 3 -38]. Scenario 2 is said t illustrate the upper range of likely outcomes and environmental impacts for the Propose I Program [DEIS, p. 3 -431. Elements of that scenario, however, may or may not result under th o Program's implementation. To use one example - concerning in- channel habitat restorat' in and sediment management - the GC -2 Alternative assumes the conversion of wooded islands I D wetted channel through leveling of islands and moving sand back into the river channel at a rate of 50 acres per year throughout the term of the Is' Increment. This aggressive island leveling plan, incorporated into the GC -2 and other Action Alternatives, is the scenario that the DEIS cc nsidered to best control channel degradation, increase open view widths, and build sandbar . [DE]S pp. 5 -52 to 5 -53; 5 -156, etc.] In fact, the sediment component of the Proposed Progral recognizes that much uncertainty exists about potential outcomes with these sorts of -4-