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Comments of the Platte River Project on the <br />Platte River Recovery Implementation Program DEIS <br />management activities and responds to concerns regarding potential undesired impacts on <br />adjoining lands. The Program's IMRP thus embraces phased stair - stepped adaptive management <br />approach beginning with data gathering, further investigations of potential management methods, <br />development of testing approaches, and implementation of small -scale testing of management <br />methods that, if successful in outcome, would be tested at a progressively larger scale before <br />adopted as a routine management activity for Program lands. [IMRP, Att. 3, III. C., p. 101. The <br />Proposed Program does not commit to implement the large -scale in- channel sediment <br />management prescriptions in advance of them "proving up." If they do not prove successful on a <br />small scale or have unacceptable negative effects, alternative management activities and methods <br />will be explored. The GC -2 island leveling plan is an arbitrary characterization of the Proposed <br />Program and is unacceptable to the PRP to the extent it requires implementation of habitat <br />management approaches that have yet to be tested and approved for implementation through the <br />framework of the IMRP. <br />The same type of concern exists with respect to implementation of the Program land <br />component. The Program I" Increment land objective calls for "protecting, restoring where <br />appropriate, and maintaining" 10,000 acres of habitat between Lexington and Chapman. <br />[Program Document, p.5]. The proposed Land Action Plan affords flexibility in selecting <br />Program lands; parcels are to be evaluated in view of their relative benefits to target species, <br />including consideration of the parcels' locations with a preference toward bridge segments <br />located near the upstream end of the habitat. Flexibility exists to select lands based upon actual <br />habitat availability, willing seller opportunities, budgetary constraints, etc. This flexibility was <br />an important issue during the negotiation of the land component. It remains so. The DEIS GC -2 <br />Alternative, however, focuses on management of lands in the upstream reach of the habitat area. <br />This would likely be at greater cost, as it would require more restoration in areas where little <br />suitable habitat remains. There is also less water available for habitat maintenance as would be <br />the case below Kearney. The EIS and BO should not incorporate into the GC -2 Alternative <br />specific land acquisition and management criteria that may constrain future on -the ground <br />flexibility and opportunities concerning the actual location of and the amount of improvement <br />and restoration work on given parcels. <br />We believe that the framework and resource commitments in the Proposed Program <br />provide a reasonable approach for avoiding jeopardy and addressing species needs in the face of <br />scientific uncertainty. The DEIS fails to reflect that this jointly implemented program is designed <br />to react to trends to the species or habitat using a variety of management tools. The EIS and <br />FWS biological opinion should evaluate the Program as a vehicle equipped to work <br />through future uncertainties and management options on the Platte with respect to flows, <br />sedimentation, habitat lands and other issues; should not unilaterally attempt to <br />predetermine the specific management actions that are today thought "best" by certain <br />biologists; and should recognize that the 1st Increment may embody a range of management <br />strategies and responses. <br />-5- <br />