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<br />MH}9'O a <br /> <br />how it is possible to generically identify all of the types of reasonable <br />and prudent alternatives that it will be appropriate to take into <br />account for_ all future Platte River water development projects. <br /> <br />Furthermore, the program seems to assume that in all instances <br />projects will be built, and reasonable and prudent alternatives would <br />consist of compensatory mitigation. This approach ignores the <br />requirement under the Endangered Species Act in determining <br />"reasonable and prudent" alternatives to examine ways of designing <br />and operating a project. or not building the proposed project at all. in <br />order to avoid environmental injury in the first place. <br /> <br />2.5.1 <br /> <br />General Approach to Section 7 Consultations <br />on Water Projects <br /> <br />The assertion, made on page 21 of the draft, that "the Program <br />will provide far greatcr benefits to threatened and endangered <br />species than would occur under Section 7 of the Act," is not <br />substantiated. This is certainly what National Audubon would want <br />the program to accomplish, but there is no clear demonstration of the <br />superiority of the Program over continued Section 7 consultations. <br /> <br />Recommendation <br />This statement (should either be clearly justified, changed.or deleted. <br /> <br />One commendable aspect of this proposed approach is the <br />requirement that any reasonable and prudent alternatives must be <br />completed before the impact occurs from any new projects. This <br />principle is generally becoming the accepted requirement for any <br />project requiring compensatory mitigation and should certainly be <br />included in any plan intended to provide reasonable and prudent <br />alternatives under Section 7 of the Endangered Species Act. <br /> <br />As set forth in the draft (page 23) the "depletion charge" <br />appears to be an improper offer to developers to allow them to <br />jeopardize threatened and endangered species in exchange for <br />financial compensation to the government. The' notion that financial <br />compensation can constitute part of a package of "reasonable and <br />prudent" alternatives is problematic. Even assuming the money is <br />used to support the program, it is far from obvious that the wildlife <br />benefits of the Program purchased with these funds will offset the <br /> <br />Page 9 July 30, 1993 <br />National Audubon Society- Comments on: <br />PU.MJS-1\'IA WG's I>nlrt IIPlatte River Habitat Conservation Program. II <br />