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COMMENTS OF U.S. ENVIRONMENTAL PROTECTION AGENCY <br />E:4CLUSURE <br />DETAILED COMMENTS ON FERC'S <br />RL'VISED DRAFT EIS <br />FOR THE <br />KINGSLEY DAM AND NORTH PLATTE /KEYSTONE DIVERSION DAM <br />This section of EPA's letter is divided into general and <br />specific comments. Our general comments cover the topics of <br />water quality standard compliance, instream flow maintenance, and <br />modifications to the currently proposed supplemental measures. <br />The specific comments address the issues of the hydrologic <br />modeling, the economic and recreation analyses used in the RDEIS, <br />and the document's consistency with comprehensive plans. <br />General Comments <br />Maintenance of the State of Nebraska's Water ouality Standard for <br />Temperature <br />In its revised section 10(j) recommendations dated May 19, <br />x 1994, the Department of the Interior (DOI) discusses the impact <br />of repeated high temperatures on the aquatic community, including <br />N fish kills and impacts to fish survival rates, growth rates, <br />embryonic development, timing of spawning and susceptibility to <br />parasites and disease. The water quality of a stream is also <br />influenced by changes in water temperature which affect <br />solubility of dissolved gases, deoxygenation rates, and <br />synergistic toxicity. Thus, maintenance of the state water <br />quality standard is necessary to protect not only the diverse <br />fish community present in the Platte River, but also those fish <br />populations that comprise the forage food base for forage fish - <br />eating migratory birds, including the endangered least tern and <br />the bald eagle, and the pallid sturgeon. <br />May - September flows as presented in the preferred <br />alternative allow for substantial exceedences of the Nebraska <br />state water quality standard (Nebraska Administrative Code <br />(11N.A.C11); Nov. 1993; Title 117; Chapter 4; Part 003.01B) setting <br />a maximum temperature criterion of 32 °C (90 °F] for warmwater <br />aquatic life. This water quality criterion was adopted by the <br />state and approved by EPA as necessary to protect the beneficial <br />aquatic life use for the river, including the Big Bend Reach. <br />The water quality criteria developed and adopted by the state and <br />approved by EPA under section 303 of the Clean Water Act (CWA) <br />are ambient water quality criteria developed to protect a <br />specified beneficial use and are not discharge criteria, as was <br />suggested by Central Public Power and Irrigation District in its <br />July 14, 1994, filing in these proceedings. <br />Sections 301, 304(b), 306 and 307 of the CWA direct EPA to <br />develop effluent standards or limitations for specific groups of <br />pollutants based on the best available treatment technologies. <br />RESPONSES TO U.S. ENVIRONMENTAL PROTECTION AGENCY <br />