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<br />000901 <br /> <br />National Audubon Society Comments on: <br /> <br />Platte River Management Joint Study <br />Management Alternatives Work Group's <br />urafi ::Piatte Kiver Habiiat Conservation 'Program" <br /> <br />1.0 INTRODUCTION <br /> <br />1.1 Purpose <br /> <br />The final phrase of the statement of purpose ("to levels that <br />will contribute to recovery of the species. ") would more clearly. <br />articulate the goals of the program if it were changed to: "to insure <br />that the development and management of the Platte River does not <br />limit the survival and recovery of endangered species that use the <br />river." This would also be consistent with the description of what the <br />Program would do in Section 7 consultations (page 22). <br /> <br />If, as the stated purpose indicates, this program will primarily <br />focus on the 89 mile stretch of the Platte between Lexington and <br />Chapman, then it is unclear what role (if any) this program will play <br />in other decisions regarding threatened and endangered species on <br />adjacent stretches of the Platte. Will there be a geographic <br />limitation, or is the intention is to leave those decisions to the future <br />managers of the Program? <br /> <br />Recommendation: In either case, the expectations regarding the <br />geographic coverage should be clearly defined. <br /> <br />The draft (page 1) says that the parties "intend" and "expect" <br />that implementation of the proposed program "will allow water... <br />development in Colorado, Nebraska, and Wyoming to proceed in <br />compliance with the Federal Endangered Species Act." From <br />Audubon's viewpoint, this statement reverses the emphasis of the <br />Program from preventing the extinction of species to facilitating <br />additional development. This is particularly troubling, in light of the <br />fact that the proposed Program fails to include a detailed <br />comprehensive water management program that. would contribute to <br />preserving species and the habitat upon which they depend. <br />