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,(}GG9.fiS In its Final Report (page 92), the Biology Work Group deferred any recommendation on a water management commenting that, "The Biology Work Group purposefully did not discuss water management methods in the description of alternatives. These methods will be deveioped more fuiiy by the Hydroiogy Work Group." lne Hydrology Work Group in turn deferred developing recommendations until management alternatives proposed by the Management Alternatives Work Group were being evaluated. The current Draft Habitat Conservation Program seems to contemplate a tradeoff between land and water such that additional water depletions would be permitted so long as countervailing management of riverine and riparian lands were undertaken. Based on this premise, the draft' program summarily justifies the lack of objectives for an instream flow regime in the water management plan on the basis that current estimates of water requirements do not include the positive benefits of the proposed land management methods (page 11). The implicit proposition is that water requirements cannot be determined now because they may somehow be reduced by the benefits of the land management program. The converse proposition, improvements in the flow regime will reduce the land management required is undoubtedly true, but that did not prevent the definition and quantification of a clear set of land management goals. This line of reasoning also seems to assume that land based habitat management actions will serve as equitable substitutions for providing the necessary flow regime. In certain circumstances, land < based habitat management may mitigate some effects of additional depletions or provide the necessary habitat at lower flows, but there has been no demonstrated and supportable scientific evidence to quantify and support this assumption, Lacking such evidence does not justify the failure to include. recommendations for specific objectives for a flow regime. Cun'ent and past proceedings regarding water allocations and management on the Platte have included specific recommendations for flows from the USFWS and there is a considerable body of research to support those recommendations. Further, this assumption of substituting land management for water depletions has obvious limits. If the Habitat Conservation Program followed this substitution of land management methods for water I':tge 6 July 30, 1993 National Audubon Society- Comments on: I'R1\tI.JS.{\tIA \VG 's I)raft "Platte River Habitat COllservation Program."