Laserfiche WebLink
<br />.. oj' . <br /> <br />- 6- <br /> <br />that "over the long-term. . . habitat is more strongly influence by the water plan." The <br />period of analysis for the DEIS, however, is 13 years; the land management methods under <br />the action alternatives will result in the most immediate and dramatic changes in habitat, <br />removing in many cases land covers that are over 40 years old and that have been subject to <br />and not altered by flows far in excess of flow recommendations <br /> <br />The DEIS team has a clear bias toward "wider is better" habitat, yet does not discuss the <br />tradeoffs involved with such an approach. An example is in the discussion of open areas for <br />terns, where the authors state the need for wide channels "presumably for early predator <br />protection." This is an opinion; the authors do not have data on predation and the <br />relationship between sight distance and predator success. The DEIS should careful1y <br />disclose the consequences and trade offs of managing for wider channels. For example, <br />wider channels may in fact be more difficult to manage and river stage changes will be <br />reduced. This is not analyzed in the DEIS. <br /> <br />In conclusion, the CWCB has identified serious shortcomings, bias, and extensive opinions in the <br />DEIS that needs to be addressed and removed when drafting the final EIS. It is clear that a more <br />qualitative analysis is needed due to uncertainties, lack of quantitative data, and system variability. <br />The final EIS should emphasize and highlight the value of a cooperative program based on extensive <br />land, water, and habitat management and adaptive management. <br /> <br />Respectfully Submitted on Behalf ofthe Colorado Water Conservation Board, <br /> <br />Rod Kuharich, Director <br />Colorado Water Conservation Board <br /> <br />Flood Protection. Water Project Planning and Finance. Stream and Lake Protection <br />Water Supply Protection. Conservation Planning <br />