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s <br />COMMENTS OF U.S. ENVIRONMENTAL PROTECTION AGENCY RESPONSES TO U.S. ENVIRONMENTAL PROTECTION AGENCY <br />the <br />EPA -19 Supplemental measures proposed by the resource agencies and <br />environmental standpoint has been the past and continuing <br />degradation of this riverine ecosystem to endemic <br />others have been modified as a result of the Cooperative <br />and threatened <br />and endangered species. Thus, the supplemental measures should and <br />between the Districts, the States Of Nebraska Colorado <br />place priority on restoring the Platte River ecosystems <br />structure, function, biological /physical processes and habitat. <br />and Wyoming, Interior, NGPC, Conservation Intervenors and the <br />EPA requests that FERC reset the priorities for the supplemental <br />measures to accommodate the needs of fish and wildlife while <br />Trust. The Agreement includes supplemental measures to be <br />still meeting other project purposes. Unless otherwise indicated <br />below, EPA concurs with the priorities for the <br />implemented or financed by the Districts as part of a basin -wide <br />supplemental <br />measures as indicated in the RDEIS. <br />program involving water conservation in the tri -state area and <br />A. Supplemental Measures Related to Water Management <br />allocation of saved water to the protection and recovery of listed <br />EPA -19 1 • Regulating Reservoir in Lower Project Reach <br />species. The staff has recommended the supplemental measures <br />• current designation - Priority 3 <br />and the operating plan contained in the Agreement (the FWS <br />• Recommendation - Completely remove or reduce to Priority 4 <br />Reasonable and Prudent Alternative (RPA) referred to in the FEIS <br />2. North Platte State Fish Hatchery Flows <br />as "Interior Plan (Program)') for reasons explained in the FEIS, <br />EPA -20 • Current designation - Priority 1 <br />Section 5. We concur with EPA that the costs and adverse <br />• Recommendation - Reduce to Priority 2; emphasis <br />of supplemental measures should be focused on recovery <br />resource effects of a reregulating reservoir outweigh potential <br />of riverine ecosystem for endemic and threatened and <br />endangered species. <br />benefits. <br />3. Water Conservation Program and Conjunctive Use <br />EPA -20 <br />EPA -21 <br />See response to EPA -19. The RPA includes a provision of <br />• Current designs +g++ - priority 1 <br />• Recommendation - agree with current designation; the final <br />hatchery flows up to 16 cfs, which we consider an important <br />license condition should specify: <br />beneficial use of a relatively small portion of the available water. <br />• Based on the current delivery efficiency of the <br />Projects being only 50 percent (page 4 -30, RDEIS), <br />additional water should be attained by specifying a <br />EPA -21 See response to EPA -19. The most important component of the <br />goal of reducing irrigation depletion by at least 15 <br />percent to be achieved over a specified time. <br />RPA and basis for staff recommendation is the basin -wide <br />• New water requirements should be based on compliance <br />Cooperative Agreement that brings more water to the central Platte <br />with the three state /DOI MOA of June 1994. <br />River. <br />• Allow this goal to develop new water can be achieved <br />either by improved irrigation efficiency, conjunctive <br />use of ground water or retirement of irrigation leases <br />or other appropriate means as the districts shall <br />devise. <br />• Specify the cost limit for obtaining additional water <br />and how this will be accomplished within the cost <br />ceiling. (It should be based on cost efficiency to <br />16 <br />