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<br />,.",' 000903 <br /> <br />Recommendation <br />This principle should be clarified to allow for such circumstances, <br />making it clear that any mandatory license and/or permit conditions <br />that involve condemnation should be completed by the project <br />sponsor. <br /> <br />Principle number three suggests that the National Audubon <br />Society and other conservation group efforts to protect and restore <br />Platte River habitat can be relied on by developers to justify projects <br />that tend to degrade the environment. As presented in the draft <br />document, this principle could, in effect, force Audubon, the Platte <br />River Trust and other private efforts into the position of subsidizing <br />the compensatory mitigation requirements" that would normally be <br />paid for by the developers of the projects. <br /> <br />While it would be appropriate to credit the accomplishments of <br />conservation groups toward the ultimate land and water <br />management goals, it is Audubon's view that it would be <br />inappropriate to include any voluntary conservation efforts by non- <br />development interests as a contribution to the program's <br />requirements for compensatory' mitigation. <br /> <br />Recommendation <br />If this principle is intended to place Audubon and other voluntary <br />conservation programs in the position of paying for compensatory <br />mitigation requirements, it is unacceptable and should be deleted. If <br />the intent is to maintain an accounting of progress toward the <br />established goals, this principle should be clarified. <br /> <br />Principle number seven provides that the Program will acquire <br />water for endangered species habitat on an. equitable basis from <br />within all three states. "Equitable" is not defined and no basis for <br />determining equity is provided. <br /> <br />While it has obvious political appeal to impose the burden of <br />contributing water for wildlife equally on all three States, water <br />acquired in Nebraska is, acre foot for acre foot, far more valuable for <br />wildlife because the closer the source of the water to the habitat area <br />the more predictably it can be delivered to serve the needs of <br />wildlife and the habitat upon which they depend. Audubon is not <br />contending that Nebraska should shoulder an undue share of the <br /> <br />Page 3 July 30, 1993 <br />National Audubon Society- Comments on: <br />[lRl\rI.JS-l\tIA WG's Draft "PI:ltte River Habitat COlIserv~,tion Program.1I <br />