Platte River Channel Becomes a Focus for Platte River Cooperative Program Studies2001

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Messrs. Lochhead, Simpson, and Robotham 3 As concurred in by the signatories to the Platte River Memorandum of Agreement in parts II and V, the Service's flow recommendations cannot reflect any abrogation or inconsistency with responsibilities and requirements. Accordingly, the flow targets must be based on the best information available and that the flow target regime ". . . provide a means whereby the ecosystem upon which endangered species and threatened species depend may be conserved . . ." (16 U.S.C. 153). Thus, the Service's ongoing objective is to obtain input from everyone with applicable information regarding the biological and scientific sufficiency of the flow targets. I believe that the Service has done this. For example, all three Platte River Basin States were asked to nominate biological and hydrological experts to participate in the pulse flow workshop from which the Service's pulse flow targets were developed. All three States either nominated experts or concurred that the appropriate experts were already invited to the workshop. All experts' opinions and information were given equal and objective consideration. This was verified by the workshop facilitators who recorded the frequency at which Service and National Biological Survey (Survey) personnel verbally referenced the information provided by the respective experts (without the knowledge of the Service and Survey personnel that these references were being recorded) and determined that there was no bias or "favoritism" exhibited by the Service and Survey personnel toward one or more of the experts (B. Lamb, pers. comm.). Additionally, all interested individuals were given the opportunity to participate in the workshop. Some comments concerned issues of implementation (e.g., sources of water, social and economic constraints, and capabilities of water storage and delivery infrastructure). Such questions are both appropriate and necessary and relate directly to the future framework of reasonable and prudent alternatives to be established under the Memorandum of Agreement for the Central Platte River Basin Endangered Species Implementation Program (Program). However, such questions pertain to a separate phase of Program development and implementation that cannot be addressed through the kinds of information used in formulating the target flows. In other words, the information and tools used to construct a target are necessarily different from the information and tools used in attempts to achieve the target. Thus far, the negotiating group has not discussed the kinds of information and tools needed to determine the process by and extent to which flow targets could be achieved, regardless of the quantity or authorship of the targets. Consequently, any conclusion that implementation of the flow targets will cause severe economic consequences or are otherwise not realistically attainable are premature, absent information and analyses of the capability and effects of the water management system to contribute to flow targets. For example, even though there is more than 7 million acre -feet of legal water storage capacity in the Platte River Basin, not a single acre -foot is legally reserved for habitat requirements of the Platte River endangered and threatened species. To my knowledge, there is no information explaining why a portion of this storage capacity could not or should not be reserved for such species. This does not imply that the focus of additional information should be on demonstrating why the status quo cannot be changed, but on what