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COMMENTS OF U.S. ENVIRONMENTAL PROTECTION AGENCY RESPONSES TO U.S. ENVIRONMENTAL PROTECTION AGENCY <br />EPA -23 2. Protection of Sutherland Canal Trout Habitat <br />• Current designation - Priority 2 <br />• Recommendation - Reduce designation to Priority 4; <br />emphasis of supplemental measures should be focused on <br />recovery of riverine ecosystem for endemic and <br />threatened and endangered species. <br />C. Supplemental Measures Related to Wildlife and Botanical <br />Resources <br />EPA -24 In order to reduce implementation costs of items 1 -4 listed <br />below, EPA requests that FERC reevaluate how the maintenance <br />costs for the various management areas could be restructured to <br />reduce the number of years costs are assessed and how costs could <br />be reduced by changing the proposed size of buffer areas to 0.25 - <br />mile instead of 0.5 -mile. Reducing the buffer areas could help <br />lower acquisition and maintenance costs, and thus make more money <br />available to include more habitat restoration areas in the <br />Priority 1 and 2 categories. <br />EPA -25 <br />11. River Bed Stabilization and Habitat Restoration - Keystone <br />Diversion to North Platte <br />• Current designation - Priority 1 <br />17 <br />EPA -25 The staff agrees that the focus of the Districts' management plan <br />for wet meadow tracts to be acquired in the North Platte, as <br />stipulated in the Agreement in Principal and the Interior Plan <br />(Program), should be on restoration of adequate surface waic:r <br />conditions. <br />EPA -22 See response to EPA -19. Staff agrees with EPA; the RPA does <br />not impose limits on Lake McConaughy levels relating to <br />EPA -21 meet the water obligations developed under the three <br />p rotection of walleye spawning. <br />state /DOI MOA.) <br />(cunt.) <br />• A provision that specifies that such saved new water <br />will be used only for release for instream flow <br />EPA -23 See response to EPA -19. We agree that other measures, dealing <br />purposes for fish and wildlife. Provisions that would <br />define when this cannot be done due to lack of <br />with protected species and their habitats, are more important. The <br />reservoir storage should be specified. <br />RPA does not require the Districts to construct devices to improve <br />• In order to expedite its implementation, the <br />fish habitat in the Sutherland Canal. <br />conservation plan should be filed with FERC no later <br />than 3 years after issuance of the license rather then <br />the 4 years currently suggested. <br />EPA -24 See response to EPA -19. The efficient use of appropriate monies <br />B. Supplemental Measures Related to Aquatic Resources <br />and resources available to the Districts for habitat protection and <br />1. Reservoir Water Level Fluctuation <br />enhancement has been re- evaluated. Staff believes the adaptive <br />EPA -22 <br />component of the RPA, and the various plans <br />• Current designation - Priority 1 <br />management <br />• Recommendation - Reduce designation to Priority 3; <br />required as part of the license orders, will ensure that supplemental <br />emphasis of supplemental measures should be focused on <br />7� recovery of riverine ecosystem for endemic and <br />measures are implemented efficiently. <br />�n threatened and endangered species. <br />v <br />00 <br />EPA -23 2. Protection of Sutherland Canal Trout Habitat <br />• Current designation - Priority 2 <br />• Recommendation - Reduce designation to Priority 4; <br />emphasis of supplemental measures should be focused on <br />recovery of riverine ecosystem for endemic and <br />threatened and endangered species. <br />C. Supplemental Measures Related to Wildlife and Botanical <br />Resources <br />EPA -24 In order to reduce implementation costs of items 1 -4 listed <br />below, EPA requests that FERC reevaluate how the maintenance <br />costs for the various management areas could be restructured to <br />reduce the number of years costs are assessed and how costs could <br />be reduced by changing the proposed size of buffer areas to 0.25 - <br />mile instead of 0.5 -mile. Reducing the buffer areas could help <br />lower acquisition and maintenance costs, and thus make more money <br />available to include more habitat restoration areas in the <br />Priority 1 and 2 categories. <br />EPA -25 <br />11. River Bed Stabilization and Habitat Restoration - Keystone <br />Diversion to North Platte <br />• Current designation - Priority 1 <br />17 <br />EPA -25 The staff agrees that the focus of the Districts' management plan <br />for wet meadow tracts to be acquired in the North Platte, as <br />stipulated in the Agreement in Principal and the Interior Plan <br />(Program), should be on restoration of adequate surface waic:r <br />conditions. <br />