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COMMENTS OF U.S. ENVIRONMENTAL PROTECTION AGENCY <br />EPA -33 13. Canoe Trail <br />I • Current designation - Priority 1 <br />• Recommendation - Reduce to Priority <br />EPA -34 14. Cultural Resources Protection Program <br />• Current designation - Priority 1 <br />• Recommendation - Reduce to Priority <br />Development and implementation of a Monitoring Plan <br />EPA -35 The environmental and economic importance of the Platte <br />River ecosystem combined with the amount of time and effort that <br />all parties have contributed to this relicensing effort <br />highlights the need for a detailed monitoring plan to be <br />developed for inclusion as a final license condition for both <br />projects. The implemented monitoring plan for this relicensing <br />process needs to address: (1) the effectiveness of modifications <br />to the existing flow control regime on the principal resource <br />values of the Platte River (i.e., irrigation, fish and wildlife <br />protection, hydropower generation, and recreation), (2) the <br />identification and implementation of a scheme to measure the <br />effects of implementing a water conservation plan on the <br />projects' operations, including any procedures to account for net <br />water conserved and ground water use, and (3) obtaining an <br />accurate calibration of the hydrological model upon which the <br />alternatives assessment and selection were based. Accurate model <br />calibration will be important if a need for a reassessment of <br />resource protection achieved or adjustment of operational flows <br />is identified later on after implementation, but within the <br />license period. <br />Monitoring should be both direct, in that specific variables <br />and targets for such variables (e.g., flow rates, instream <br />temperatures, dissolved oxygen levels) should be established for <br />the appropriate times of the year that they are applicable, and <br />indirect, whereby the effects (benefits) of the particular <br />combination of flows and water quality of the licensed operating <br />regime would be measured by monitoring the status of the <br />principal resource of concern (e.g., fishery populations, nesting <br />habitat availability). <br />It also is necessary for the monitoring plan to require that <br />these variables be measured in close proximity to the resource <br />population or habitat of concern and not indirectly at some point <br />up- or downstream where such monitoring is more convenient, at <br />least until a direct correlation can be demonstrated to support <br />such indirect monitoring. EPA strongly suggests that FWS be <br />consulted on the identification of appropriate monitoring sites <br />along the North, South, and Platte Rivers. <br />20 <br />RESPONSES TO U.S. ENVIRONMENTAL PROTECTION AGENCY <br />EPA -33 The staff eliminated this proposed supplemental measure due to <br />potential safety problems and funding constraints. <br />EPA -34 See response EPA -31. Under the terms of the Reasonable and <br />Prudent Alternative, the Districts would participate in <br />development of Programmatic Agreements, which include <br />additional site surveys. <br />EPA -35 See response to EPA comment 30. The staff assumes that, as <br />FWS will be responsible for determining focus and methodologies <br />for the monitoring component of the recovery program, that <br />concerns expressed by EPA in their comment will be adequately <br />addressed. <br />