Final Environmental Impact Statement Volume II Appendix K, Part 2

• Description: related to the Platte River Endangered Species Partnership ‎(aka Platte River Recovery Implementation Program or PRRIP)‎
• State: NE
• Basin: North Platte
• Date: 7/1/1998
• Author: Federal Energy Regulatory Commission ‎(FERC)‎ Office of Hydropower Licensing
• Title: Final Environmental Impact Statement ‎(EIS)‎ - Volume II, Appendix K, Part 2 - Kingsley Dam ‎(FERC Project No. 1417)‎ and North Platte/Keystone Dam ‎(FERC Project No. 1835)‎ Projects, Nebraska, FERC/FEIS-0063
• Water Supply Pro - Doc Type: EIS

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COMMENTS OF U.S. ENVIRONMENTAL PROTECTION AGENCY
resource. The project area is habitat for eight federally listed
threatened or endangered species as well as over 300 species of
migratory birds, including 500,000 sandhill cranes and 7 to 9
million ducks and geese.
While FERC has specific responsibilities for this action
under section 7(a)(2) and section 9 of the Endangered Species Act
(ESA), section 7(a)(1) of that act also requires that all federal
agencies, in consultation with the U.S. Fish and Wildlife Service
(FWS), utilize their authorities to carry out programs for
protecting, conserving, and recovering threatened and endangered
species. Clearly section 7(a)(1) of the ESA requires that the
federal community vigorously protect the Platte River ecosystem
upon which federally listed species depend.
Based on our analysis of data developed by the hydropower
districts and the FWS, EPA has concluded that the implementation
of the preferred alternative is likely to cause persistent
exceedences of the applicable federally- approved state water
quality temperature standard and result in continued degradation
of the Platte River ecosystem, in particular the Big Bend Reach.
concurrent with this water temperature exceedence problem is the
need to maximize the occurrence of FWS's target instream flows at
the Grand Island stream gage for the protection of fish and
wildlife, including threatened and endangered species. The
preferred alternative fails to do this.
As the RDEIS makes clear, none of the alternatives will
provide sufficient summer /late summer flows to satisfy the
applicable temperature requirement at all times. However, the
preferred alternative is one of the least protective of fish and
wildlife (p. 4 -56, Table 4 -21) and will not support the river's
warmwater Class A aquatic life use. EPA's analysis of the data
has focused primarily on the ambient water temperatures
associated with the implementation of the preferred alternative
that are greatly in excess of the state of Nebraska's water
quality criterion for temperature (i.e., a maximum temperature
limit of 3VC for warm water aquatic life [90 °F]; Nebraska
Administrative Code ("N.A.C. "j; Nov. 1993; Title 117; Chapter 4;
Part 003 -01B). These exceedences are substantial and will
continue to occur over a long -term basis unless corrected by
FERC. If sustained, these temperature exceedences threaten the
continuation of the designated aquatic life use assigned by the
state to the river reach.
FERC's preferred alternative provides summer instream flows
of 800 cubic feet per second (cfs) only during normal to wet
years when reservoir volume exceeds 1.3 million acre -feet (MAF).
A reservoir volume lower than 1.3 MAF can be expected to occur 50
percent of the time under the 50 year period of record modeled.
In order to adequately meet the water quality temperature
RESPONSES TO U.S. ENVIRONMENTAL PROTECTION AGENCY