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Commenf of the Platte River Project on the <br />Platte Ri r Recovery Implementation Program DEIS <br />Consistent with Section E.2.a of the Program Document, as long as Tamarack 1 is <br />constructed and operated as described herein, the target flow shortage reduction <br />credited to Tamarack 1 individually or to the Three initial water projects <br />collectively will not be reduced even if the real time frequency and magnitude of <br />flows in excess to targets at Grand Island causes Tamarack 1 to produce an <br />average annual yield that is less than that projected under historic flow conditions, <br />regardless of the reasons for the change. <br />The DEIS analysis of impacts incorrectly relies on the Sed Veg Model. <br />he DEIS portrayal of environmental consequences incorrectly relies on the Sediment <br />Vegetat on Model. There are significant unknowns regarding the use of this unproven tool. The <br />states o Colorado, Nebraska, and Wyoming had an independent review of the data and model <br />develop A by the Department of Interior [see Platte River Channel Dynamics Investigation, <br />Parsons May 2003]. The Parsons investigation cast serious doubt regarding the conclusions <br />reached by DOI. Significant issues concerning process relationships (geomorphic, plant <br />physiology, and the linkage of the two) and calibration and verification persist. Yet, this "tool" <br />forms tl e foundation upon which the assumptions and projections of impacts in the DEIS are <br />he National Academy of Science (NAS) review of Endangered and Threatened Species <br />on the latte River (April 2004) also recognized that the Sed Veg Model has not been fully <br />comple d or tested for application and decision making on the Platte River. The Academy had <br />the folldwing remarks: <br />"The study committee did not evaluate three items ... an advanced computer <br />model, SEDVEG, to evaluate the interactions among hydrology, river hydraulics, <br />sediment transport, and vegetation being developed, but not yet completed or <br />tested, by USBR for application on the Platte River ...." (p. 5) <br />"The committee did not assess the newer models, because they have not yet been <br />completed or tested, but it recommends that they explored for their ability to <br />improve decision - making." (p. 9) <br />"The committee also recognizes that there has been no substantial testing of the <br />predictions resulting from DOI's previous modeling work, and it recommends that <br />calibration of the models be improved." (p. 9) <br />"Current DOI model developments, including the emerging SEDVEG model, are <br />likely to be helpful and useful in both understanding and managing the Platte <br />River. DOI's determination of suitable habitat rests on the best available science. <br />-8- <br />