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- 9 - . As previously mentioned, the DEIS analysis has a significant number of inconsistencies, A few examples are provided below, In one section the DEIS states that managed bridge segments for terns is termed "significant progress" yet for plovers "none ofthe action alternatives would result in significant benefits". Then in other sections the benefit of management is mentioned but again understated when there is little value assigned to the 194 fledged plover chicks at Lake MacConaughy in 2003, The description of action alternatives describes removal of trees and widening of channels and yet Governance Committee 1 has no increase in channel width over present condition, In some sections the DEIS states whooping cranes prefer channels of 200 yards or more but then describes adverse impacts if channels are less than 1000 feet. Pallid Sturgeon have not historically used the Platte River yet spawning habitat hypothesis are advanced and related to habitat conditions and trends in the Platte River. In various sections Pallid Sturgeon are described as needing 1) sandy bottoms, 2) gravel bottoms, and 3) rocky substrate the authors do not know. Pal1id Sturgeon use data is extremely limited in the Platte and data describing the condition of habitat use areas essentially does not exist. Forage fish flows are cited and referenced and have been debated since the 1990's and then yet another flow value (1200 cfs) is used for the analysis with no substantiation other than qualitative discussion, The DEIS states they can not quantify late summer flows",. .due to lack of gauge records from the early development period" however they use this same poor gauge record history for the quantification of peak flows and peak flow impacts, In conclusion, the CWCB has identified serious shortcomings, bias, and extensive opinions in the DEIS that needs to be addressed and removed when drafting the final EIS. It is clear that a more qualitative analysis is needed due to uncertainties, lack of quantitative data, and system variability, The final EIS should emphasize and highlight the value of a cooperative program based on extensive land, water, and habitat management and adaptive management. III. National Academy of Science Review Attachment 1 to this memo provides a copy ofthe executive summary of the findings of the NAS, The NAS address's several questions regarding the importance of the central Platte to the species, and the conclusions and science used by the U.S. Fish and Wildlife Service (Service). The NAS supports many of the Services findings, However, NAS emphasizes that there is considerable uncertainty regarding the relationship between flow and habitat and that the Sed Veg model while promising may not be ready for quantitative analysis. NAS also identifies data gaps regarding the species and the need to collect data, update models, and undertake adaptive management NAS also points out that many impacts to the species have occurred outside of the central Platte and that a broader view of the factors affecting their survival may be appropriate. In a similar vein the NAS highlights that the cost-effectiveness of conservation actions related to the target species is not well known and that choosing actions that have the greatest benefit to the species at the lowest societal cost may be appropriate. IV. Recommendation Staff would like the Board to provide further direction on the preparation and completion of comments. Staff will seek direction from the Board on the current level of detail and content of the comments. Flood Protection. Water Project Planning and Finance. Stream and Lake Protection Water Supply Protection. Conservation Planning