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<br />OQ0908 <br /> <br />~"'..., <br /> <br />obe based on the best current scientific information available, <br />sUbjec't to revision as that information base improves. <br /> <br />odefine the flow levels and timing necessary to meet both <br />1 I.. _ . _ u.1 _._ _ _ ~ _ _ __ _ _ ..1_ <br />Ili::1Ullal (111U :Sl1Cl,;H;~ llC;CU~. <br /> <br />orecognize that land based habitat management is not in every <br />case a suitable and appropriate substitute for providing the <br />necessary flows and flow regime, and require that any such <br />substitution demonstrate that the effects of land based <br />management are appropriate as "reasonable and prudent <br />alternatives." <br /> <br />2.3 Research and Monitoring <br /> <br />It is unclear from the description in the draft document how <br />research and monitoring under the Program would be coordinated <br />with the research and monitoring that the Districts, for example, will <br />have to do under the new FERC license. Likewise, it is unclear if the <br />Program would assume responsibilities for research and monitoring <br />that might be included as a permit or licensing condition, or if there <br />would be some contractual arrangement available. <br /> <br />Recommendation <br />These issues should be clarified and spelled out III the revised draft. <br /> <br />2.4 Information and Education <br /> <br />National Audubon has no comments at this time. regarding the <br />information and education provisions in the draft document. <br /> <br />2.5 Section 7 Consultations <br /> <br />As outlined in the Draft document, the proposed Program <br />would amount ~o the creation of a kind of Platte River "mitigation <br />bank," which would appear to violate the spirit, if not the letter, of <br />the Endangered Species Act. <br /> <br />Section 7 of the ESA contemplates consideration of the jeopardy <br />question, including identification of "reasonable and prudent" <br />alternatives, in the context of individual projects. It is difficult to see <br /> <br />Page 8 July 30, 1993 <br />National Audubon Society- Comments on: <br />PRl\-US.i\'IA WG IS J)raCt 1I1)latte River H:lbitat Conservation I'rogram." <br />