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<br />" <br /> <br />- 6- <br /> <br />Preliminary Comments <br /> <br />. <br /> <br />Staff offers the following comments for consideration of the Board, Detailed comments will also be <br />prepared, At this time staff would like input from the Board to determine if the comments are on <br />point and to get a sense of the level of detail for the comments. <br /> <br />1. The DEIS contains extensive opinions which should be removed from the document, The <br />history of habitat use and trends for the target species and the impact analysis are not <br />objective and unbiased, The DEIS should be a factual summary of the no action and action <br />alternatives and a factual assessment ofthe outcome ofthe federal action. In addition, data <br />substantiating the positions or outcomes that are stated must be provided and referenced, <br /> <br />2. The DEIS establishes a present condition which does not reflect environmental and <br />ecological variability which has occurred over time, This is especially true in regard to <br />climate changes. The mid 1800's were a period of extreme drought followed by a wet period <br />in the early 1900's, The river channel configuration and land use cover used in the DEIS do <br />not reflect a "baseline condition", as the geomorphology and land cover were reacting to <br />dramatic climatic shifts and the impact of settlers moving west. <br /> <br />The summary of river trend and fluvial processes does not adequately take into account the <br />natural variability of the system, Sufficient data is not presented to support hypothesis and <br />conclusions. Conjecture and basic scientific theories should not be used to "fill in the . <br />blanks", For example, there is no description of the presence and configuration of "sand bar <br />habitat". It is not clear that this habitat ever existed, No d<!ta is presented describing historic <br />versus current trend in the frequency, distribution, size, and elevation of sand bars. <br /> <br />3, The DEIS does not literature citation when presenting information that is characterized as <br />factual but appears to be opinion, The citation must be provided and the data referenced. <br /> <br />4, The DEIS does not do an adequate job describing the benefits of a cooperative program and <br />the value of an adaptive management program. The DEIS fails to adequately highlight how a <br />jointly implemented program could react to, adjust to, and if necessary offset negative trends <br />to the species or habitat using a variety of management tools. <br /> <br />5. Reasonable, appropriate scientific methods were not used to evaluate each impact for both <br />present conditions and the action altematives, In the case of present conditions the most <br />recent species and habitat infonnation was not used and the limitations of baseline data were <br />not disclosed. A technical review of the baseline data reveled significant deficiencies which <br />lead the Service to conclude that the information could not be used as a quatitative baseline. <br />Yet the information is erroneously recreated in the DEIS, Examples of deficiencies include: <br />lack of defined methodologies for data collection, changed conditions between observations <br />and data collection, use of non-peered reviewed models and methods, and use of models that <br />have not been updated with current information. <br /> <br />In the case of the impacts and environmental consequences, the analysis by the Department <br />of Interior (DOl) relied too heavily on the use of the Sed Veg Model. The states of Colorado, <br /> <br />Flood Protection. Water Project Planning and Finance. Stream and Lake Protection <br />Water Supply Protection. Conservation Planning <br />