BOARD02211

• Board Meeting Date: 7/20/2004
• Description: WSP Section - Platte River Recovery Implementation Program, State of CO Comments on the Draft Environmental Impact Statement
• Board Meetings - Doc Type: Memo

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environmental consequences from the action alternatives not be taken to restrict the range of
permissible responses under the Program's 151 Increment.

We believe that the framework and resource commitments in the Proposed Program provide
a reasonable approach for avoiding jeopardy and addressing species needs in the face of
scientific uncertainty, The DEIS fails to reflect that this jointly implemented program is
designed to react to trends to the species or habitat using a variety of management tools. The
DEIS and Service's biological opinion should evaluate the Program as a vehicle equipped to
work through future uncertainties and management options on the Platte with respect to
flows, sedimentation, habitat lands and other issues, and not unilaterally attempt to
predetermine the specific management actions that are today thought "acceptable." We
request that the Department of Interior analyze the Proposed Program as based upon
implementation of the 151 Increment Milestones and with specific recognition that it may
result in a range of permissible management strategies and responses,

4, The CWCB remains hopeful that we will be able to support the Proposed Program and the
Governance Committee Alternative. The CWCB does not support any ofthe "other action
alternatives" due to legal, technical, financial, and political issues associated with each of
these alternatives.

5, The DEIS contains extensive opinions which should be removed from the document. The
history of habitat use and trends for the target species and the impact analysis are not
objective and unbiased. The DEIS should be a factual summary of the no action and action
alternatives and a factual assessment of the outcome of the federal action. In addition, data
substantiating the positions or outcomes that are stated must be provided and referenced.

6, The DEIS should be revised to remove internal inconsistencies.

7. Reasonable, appropriate scientific methods are not used in the DEIS to evaluate present
conditions. The most recent species and habitat information is not used [i.e" whooping crane
and sediment investigations conducted during the Cooperative Agreement (CA), data
regarding tern and plover use of non-riverine habitat, and vegetation studies]. The
limitations of baseline data are also not disclosed. A technical review of the baseline data
(see CA Technical Committee comments dated October 22,1999, and subsequent comments
though 2003; see also John Nickum comments, United States Fish and Wildlife, April 2000
Technical Committee minutes) reveled significant deficiencies, which previously lead the
Service to conclude that the information could not be used as a quantitative baseline, (see
above references). Yet the information is erroneously recreated in the DEIS. Examples of
deficiencies include: lack of defined methodologies for data collection, changed conditions
between observations and data collection, use of non-peered reviewed models and methods,
and use of models that have not been updated with current information.

The DEIS also establishes a present condition which does not reflect environmental and
ecological variability that has occurred over time. This is especially true in regard to climate
changes. The mid-1800s were a period of extreme drought followed by a wet period in the
early 1900s. The river channel configuration and land use cover used in the DEIS do not
reflect a "baseline condition", as the geomorphology and land cover were reacting to
dramatic climatic shifts and the impact of settlers moving west.
Flood Protection. Water Project Planning and Finance. Stream and Lake Protection
Water Supply Protection. Conservation Planning