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Commenf of the Platte River Project on the <br />Platte Ri er Recovery Implementation Program DEIS <br />A. <br />The DEIS should be revised to clarify its description of the Tamarack <br />Project. <br />Colorado's Future Depletions Plan. <br />Since the EIS team began drafting the DEIS document, the Governance Committee <br />continu d to negotiate refinements to the Proposed Program documents. One of those <br />refinem nts provided further definition to the Colorado Future Depletions Plan. The most <br />current version of the Colorado Plan is submitted as Attachment A to these written comments. <br />while <br />on the <br />may n <br />fact tl <br />net in <br />to ad( <br />FWS <br />neces <br />Plan: <br />Che DEIS at page 1 -23 states: "Growth in agricultural, municipal, and industrial use — <br />e State and Federal Depletion Management Plans are designed to offset adverse effects <br />trget species and annual pulse flows, the possibility [is] that some increases in water use <br />be addressed, and they may diminish habitat value or other Program benefits." This <br />it is not valid for Colorado's Future Depletions Plan. The Final EIS should reflect the <br />the Colorado Future Depletions Plan assumes that new population growth will cause a <br />-ased water supply on an average annual basis to the South Platte River and is designed <br />ss all impacts from new water related activities. While Colorado does not agree that the <br />get flow, peak flow and pulse flow recommendations are biologically or hydrologically <br />to benefit or recovery the species, Colorado has addressed concerns about potential <br />on peak and other flow and sediment transport issues by the following conditions to its <br />"3. New water related activities will not be covered by this plan once the average <br />annual water supply to serve Colorado's population growth attributed to the <br />sources of "Wastewater Exchange/Reuse" and "Native South Platte Flows" <br />exceeds 121,000 acre -feet. The 121,000 acre -feet figure represents gross water <br />deliveries (supplies) to meet new demands for an average hydrologic year, and is <br />not a consumptive use or diversion limitation. In analyzing proposed new water <br />related activities that have supplies derived from the storage of native South Platte <br />flows, only those supplies resulting from diversions to storage during the period <br />from February through July will be counted toward the 121,000 acre -feet. In the <br />event that a new water related activity is not covered by Colorado's Plan pursuant <br />to this subsection I.H.3, Colorado and the activity's proponent can consider <br />amendments that will allow Colorado's Plan to provide ESA compliance for the <br />activity as provided in Section E of the Program Document. <br />4. The Colorado Plan for Future Depletions does not cover the construction of a <br />major on- stream reservoir located on the main stem of the South Platte River <br />anywhere downstream of Denver, Colorado. In addition, the Colorado Plan for <br />Future Depletions does not cover hydropower diversion/return projects that divert <br />water including sediments from the main stem of the South Platte River anywhere <br />-6- <br />