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

EPA -7
to
ON
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COMMENTS OF U.S. ENVIRONMENTAL PROTECTION AGENCY
relicensing process to address the issues of water conservation
and wetland mitigation as part of the supplemental measures for
this project. We believe that water conservation is particularly
important since it would be a source of "new" water to a system
that lacks sufficient water to protect fully current uses.
Finally, because of the ecological and economic significance
of the Platte River ecosystem, it is critical that, as part of
the final EIS, the Record of Decision, and the final license
conditions for the projects, FERC provide clear direction
concerning the assessment of the effectiveness of instream flow
regimes and supplemental measures. Given the extreme complexity
of this system, we believe that it is critical that FERC include
a detailed reopener clause for both projects' new licenses to
ensure that all parties to this licensing process will have the
opportunity to comment and provide recommendations as the
projects' operations are implemented and so that FERC can make
appropriate modifications to license conditions based on
developing scientific knowledge.
FERC may also wish to consider the approach of using
"adaptive management," as currently under development by the
Department of Interior for dam operations. The Bureau of
Reclamation is pursuing an adaptive management approach for its
operations at Glen Canyon Dam (see "operation of Glen Canyon
Dam ", Draft EIS, U.S. Department of the Interior, May 1994). To
be successful, adaptive management requires decisions based on
science, coordination by a senior scientist, changes made on
selected, measured biological criteria and a clear line of
authority to FERC for necessary revisions to license conditions,
if warranted. Certainly, an adaptive management approach would
meet the concern of the state of Nebraska that the preferred
alternative be flexible and able to adjust to changing
conditions.
Thank you for the opportunity to comment on the RDEIS. If
you have any questions, please call Ms. Cathy Tortorici, EPA
Region 7 Project Manager, at 913 - 551 -7435. You may also call
Anne Miller or Ken Mittelholtz of my staff at 202 - 260 -5053. We
would like very much to work as closely with FERC and the state
of Nebraska in developing an environmentally sound preferred
alternative as FERC's relicensing process will allow. Please
expect a formal request from EPA for a meeting to discuss the
resolution of these concerns.
Since ely,
R hard . Sanderson
D rector
Office of Federal Activities
RESPONSES TO U.S. ENVIRONMENTAL PROTECTION AGENCY
EPA -7 We agree with EPA on the importance of ongoing assessment and
redirection as needed. We have included a monitoring program to
provide ongoing assessment; we recommend an operating regime
that lends itself to adaptive management; and the licenses, if
issued, will include the opportunity for reopening if conditions
warrant.