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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No data is provided in the DEIS showing that the prescribed flow relationships and the
magnitude and duration of flow recommendation and Sed Veg modeling will result in the
scouring of vegetation. It is equally likely that the hypothesized processes for vegetation
removal will have the opposite effect by in fact distributing seedling with a short term pulse
and growth (and narrowing of the channel) through late summer irrigation via release of so
called forage fish flows.

It is requested that the Sed Veg model not be used to describe impacts. Given the
uncertainties in the knowledge a more qualitative assessment is needed with the
understanding that the action alternatives will monitor effects and offset negative impacts as
necessary using proven habitat management methods.

9, The DEIS grossly understates the benefits of habitat acquisition and management and
restoration provided by the Governance Committee Alternative, especially in relationship to
the species use and needs on the Central Platte. The management of 10,000 and ultimately
29,000 acres of habitat for the species is conservatively more than enough to ensure that the
Platte River is not limiting recovery (see Management Joint Study and References). The
Governance Committee Alternative ensures the protection and management of this habitat.
Simply put the Governance Committee alternative provides the requisite habitat that is
necessary to ensure that the action can serve as a reasonable and prudent alternative,

10, The land management sections ofthe DEIS should be rewritten to remove inaccuracies and
bias. The portrayal of Governance Committee I versus 2, as described in the DEIS, is to
"display a range of outcomes." The range of outcomes from Governance Committee I are
portrayed as a "minimum"; this is not reflective of the actions described in the Program, For
example, islands and channel banks will be cleared to increase sight distance yet the DEIS
says that it is the same as present conditions. An additional quantity of sediment will result
from island leveling in the monitoring and research program and due to vegetation removal;
it certainly is not 0 as described in the DEIS. The DEIS states that the channel could narrow
to 800 feet which is suitable habitat for the species and in fact reflects the highest use channel
width by the species.

The DEIS inappropriately elevates the importance of, and impacts to, wet meadow habitat.
Whooping crane foraging data suggests extensive use of other land covers for foraging (i.e"
irrigated fields) and there is reasonable uncertainty regarding nutritional needs and food types
ingested during migration. The DEIS describes a 31 percent increase in lowland grass (note
_ the definition of wet meadow appears to be a term of art used in the Platte that is arbitrarily
defined but generally fits within this land use cover type) from 1982-1998, This increase
adds approximately 7000 acres of lowland grass increase for a total of 28,000-30,000 acres of
this land use type. Yet the DEIS directs its analysis on projecting hypothetical processes
relating to "impacts" to wet meadows rather than acknowledging and emphasizing the
positive trends in lowland grass. The DEIS discusses impacts to wet meadow hydrology and
river stage without presenting any data either for present conditions or historic trends. This
misportrays the nature and magnitude of projected environmental consequences to the
species.

The DEIS disproportionately focuses on riverine processes and underestimates the value of
land management in the securing of habitat. For example, the DEIS team offers the opinion
Flood Protection. Water Project Planning and Finance. Stream and Lake Protection
Water Supply Protection. Conservation Planning