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<br />000898 <br /> <br />Page 2--7/30/93 <br />John Lawson, Chairman <br />Management Alternatives <br />NAS Comments on Draft <br /> <br />Work Group-PRMJS <br />"Platte River habitat Conservation Prog." <br /> <br />, <br />1. Lack of Water Management Goals and Objectives <br /> <br />(St:diull <br /> <br />~ ~, <br />~,~) <br /> <br />The current draft of the proposed Habitat Conservation Program <br />(Program) fails to include a comprehensive set of goals and <br />objectives for a water management program. Although a water <br />management plan has proven difficult to even discuss in many of the <br />PRMJS proceedings, failure to include a proposed water management <br />plan that sets measurable objectives is tantamount to providing less <br />than half the answers. Audubon cannot support a Program that does <br />not include a comprehensive set of goals and objectives for a water <br />management program. <br /> <br />Based upon the extensive research and modeling that has taken <br />place, especially over the last decade, the failure to include a water <br />management plan is not due to the lack of scientific data to <br />determine the goals and objectives for a flow regime. <br /> <br />As presented, the draft Program contends that It IS not possible to <br />establish a set of instream flow regime criteria because the current <br />estimates of water requirements do not include the positive benefits <br />(reductions in flow requirements) that the proposed land <br />management methods would confer. The converse argument, <br />improved flows would likely reduce the requirements for land <br />management, did not prevent the establishment of specific criteria <br />for a land management program. <br /> <br />Proposing a specific set of objectives for either land or water <br />management should not commit the Program to sacrosanct numbers. <br />Rather, setting forth water management goals and objectives should <br />be utilized to determine if the Program is making progress in <br />improving the flow regime, the same way that the land management <br />objectives would be utilized. Both sets of objectives should be open <br />to revision based on sound scientific evidence of changed <br />requirements. <br /> <br />2. Section 7 Consultations (Section 2.5) <br /> <br />As outlined in thc draft documcnt, this Program seems destined to <br />approach the question of dealing with Endangered Species Act <br />