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: . \)009tJ7 management t9 the extreme, it would provide all manner of land management until there was no water left in the river. The National Audubon Society maintains that it is essential to establ1sn an initiai set of water management goals and specific objectives for an instream flow regime in order to commit the program to a measurable set of standards. Given the facts that the Platte River is already over appropriated and that the U. S. Fish and Wildlife Service's recommended target flows for endangered species and the habitat that they depend upon are only met approximately 45% of the time, the water management plan should adopt a "no net loss" principle that would insure there is no further degradation of the flow regime. At the same time Audubon does not expect that those standards would be inviolate, but rather that they could, and would, be periodically reviewed and revised based on the best new scientific evidence as' conditions change. In the absence of such goals and objectives, however, it will be difficult or even impossible to determine if Program activities are actually making measurable improvements in those areas to be considered in Section 7 consultations as outlined in the Framework for Future Section 7 Consultations, paragraph 3., page 24 of the draft. Recommendation Audubon recommends that the Management Alternatives Work Group either develop detailed water management goals and objectives or request that the Biology and Hydrology Work Groups develop them for inclusion and review in a revised draft plan. As a starting point the goals and objectives for the water management program need to: .recognize that flows in the Platte River are already depleted past the point that will sustain threatened and endangered species and the habitats upon which they depend. .adopt a "no net loss" principle that insures improvement in the flow regime necessary for threatened and endangered species and the habitats upon which they depend. Page 7 July 30, 1993 National Audubon Society- Comments on: PRl\tI,fS-l\tlA WG's Draft "Plutte River Habitat Conservation Program."