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WSPC06991
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WSPC06991
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Last modified
1/26/2010 12:08:46 PM
Creation date
10/9/2006 6:13:07 AM
Metadata
Fields
Template:
Water Supply Protection
File Number
8408
Description
River Basin General Correspondence
State
CO
Basin
South Platte
Water Division
1
Date
7/30/1993
Title
Platte River Evaluation: USBR - National Audubon Society Comments on Platte River Management Joint Study Management Alternatives Work Group's Draft "Platte River Habitat Conservation Program"
Water Supply Pro - Doc Type
Report/Study
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<br />00.0916 <br /> <br />Page 3, paragraph one. - The term "administering" should be <br />replaced with "implementing most of the actions under." <br /> <br />Page 6. - Please delete "use" from No.2, as it makes the <br />sent<enr.<e llnd\llv restrir.tive. "Water riahts" should be added <br />after "water" in No.3. Please clarify-how "equitable" will be <br />determined in NO.7. The inclusion of such term may appear to be <br />a gesture of fairhess but will lead to much disagreement in the <br />future. Finally, "sound business practices" are not defined and <br />should be. The document should recognize that what may be <br />expeditious in the business world may not meet legally required <br />procedures for Federal agencies. <br /> <br />Page 7, No.9. - This document assumes that all actions consulted <br />on will receive "likely to jeopardize opinions" and that there is <br />a jeopardy situation on the Platte River. However, the document <br />does not state that this is the case nor does it provide the <br />foundation for such assumption. Please revise as appropriate. <br />Please also correct statements on this page and throughout the <br />document relating to jeopardy that do not include the "likelihood <br />of" language that is in the ESA. <br /> <br />Page 8, top of page. - Please state if the tern and plover <br />habitat includes gravel pits. <br /> <br />Page 13, paragraph D. - Please revise to recognize that <br />irrigation efficiency could increase the quantity of water <br />available. <br /> <br />Page 13, paragraph E. - Consideration should be given to the idea <br />of leasing water from irrigators in dry years and compensating <br />them for lost income. The Department of the Interior was <br />recently a party in an agreement to compensate Scandinavian <br />fisherman for not harvesting salmon for 2 years. The salmon <br />spawn in rivers on the East Coast of the United States and their <br />stocks were dangerously low. The concept of leasing dry year <br />water is similar to the salmon agreement and has been proposed in <br />Colorado to meet East Slope municipal needs. Additionally, <br />storage use rights may need to be acquired or instream flow <br />rights may need to be appropriated in Nebraska. <br /> <br />Page 15, last paragraph. - Please revise so that the document <br />does not imply that non-Federal parties will direct the <br />activities of Federal agencies or expenditure of Federal funds. <br />They may, in the proper circumstances, suggest or recommend, but <br />they do not have authority to "approve" the research activities <br />of Federal agencies. Additionally, this paragraph mentions the <br />Conservation Committee, which is further described in Section 3. <br />The current composition and description of the Committee falls <br />under the restrictions and requirements of the Federal Advisory <br />Committee Act. Violation of the procedures to establish an <br />advisory committee could lead to an injunction against the entire <br /> <br />2 <br />
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