Final Environmental Impact Statement Volume II Appendix K, Part 2

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EPA -13 tip v COMMENTS OF U.S. ENVIRONMENTAL PROTECTION AGENCY to reduce stream temperatures as well as better meet the section 10(j) recommendations of the DOI. Design changes to the preferred alternative to improve efficiency could include the amount of water releases currently designated for canal maintenance flows and base flows at Overton as well as how the environmental account will be managed to overcome reach losses between Overton and Grand Island. The preferred alternative also appears to fall short in its ability to improve measurably existing crane habitat during the fall migration. In addition, the connection between river discharge and channel morphology for crane and interior least tern habitat requirements should not be underestimated. To meet these requirements, there needs to be long -term flow targets coupled with continued availability of water for discharge at critical periods -- pulse flows -- to provide sandbar nesting habitat, riparian wetland and channel island maintenance, and river channel scouring. Finally, the DOI recently submitted revised comments to FERC under section 10(j) of the Federal Power Act (dated May 19, 1994). These recommendations identify periods during late spring and late winter of wet years as the most important time periods to target for timing and release of pulse flows. The next highest priority is flows during May 11 through September 15, regardless of whether conditions are wet, normal, or dry. The lowest priority during wet and normal years is the 1,000 cfs flow target for bald eagles. Since the preferred alternative was in part selected for meeting bald eagle flows (page 5 -36, RDEIS), EPA recommends that, in the final EIS, FERC substantially modify all alternatives to reflect the priorities of the revised DOI section 10(j) recommended target flows and maximize their occurrence at the Grand Island stream gage. This should be a condition in the Record of Decision (ROD) and final licenses for these projects. Supplemental Measures Implementation of a Water Conservation Plan Section 4.1.2.3 of the RDEIS highlights the specific water conservation concerns or practices recommended to be employed, including the employment of more efficient irrigation measures and the installation of impervious linings in existing water transport structures. The implementation of water conservation measures has the potential to result in both the more efficient usage and the direct and indirect reduction in demand for water by the competing resource interests in the Platte River drainage EPA-14 basin. As a final license condition for the projects, FERC should be explicit with respect to terms describing the implementation of a comprehensive water use and conservation 10 RESPONSES TO U.S. ENVIRONMENTAL PROTECTION AGENCY EPA -13 The FEIS includes consideration of Interior's revised flow recommendations. We note that Interior's emphasis on pulse flows increases the difficulty of achieving this objective and EPA's summer water quality objective. EPA -14 Opinion noted. The staff has revised its recommendations in light of the basin -wide Cooperative Agreement. We endorse the various measures comprising the FWS Reasonable and Prudent Alternative (RPA), as described in the Agreement in Principle for License Conditions for Project Nos. 1417 and 1835. Under the terms of the basin -wide Cooperative Agreement, the RPA requires the Districts to reduce gross irrigation demand by at least 27,444 acre -feet and to participate in the development and implementation of the basin -wide water conservation program.