*4.3. Participation by Users*

The GWMPA mandates that stakeholder groups be consulted during development of the IMP (see, e.g., §46-715(3)(f), (5)(b) and §46-717(2)). The IMP reflects statutorily mandated decision-making by NeDNR and the NRD; requires meetings with stakeholders; and outlines the process for NeDNR and NRD to annually review the progress of the IMP and jointly agree upon any amendments. Although the NeDNR and the NRDs may amend an IMP at annual review, there are no explicit provisions for involving stakeholder groups in the amendment process (see §46-715(5)(d)(ii)). The goals and objectives for this IMP, as well as the major strategies for addressing depletions to the Platte River, evolved from ideas discussed among NRD staff, irrigation district board members, and municipal officials prior to the start of the planning process. During the planning process, the NRD held public meetings for stakeholders and members of the public. These meetings fulfilled the consultation requirements in the GWMPA.

Decision maker and stakeholder perspectives on participation varied widely. One interviewee reported that his engagemen<sup>t</sup> with the NRD and other stakeholders predated the IMP, and that a grea<sup>t</sup> deal of mutual exchange and education among surface and ground water users had already occurred. On the other hand, another interviewee reported that those who proposed increasing minimum accretions to stream flow were "laughed off the floor." Still another questioned whether the NeDNR and the NRD actually consulted and collaborated with stakeholders to a meaningful degree, as opposed to simply gathering input and then writing the plan on their own.

The most frequent comment was that IMP stakeholder meetings were infrequent compared to the other IMPs in the western part of the state, and that consultation was perfunctory. Several reported attending and listening, without offering any input. Some stakeholders had specific ideas to propose but had the sense that the NRD was controlling the agenda. These perspectives seem to reflect characteristics of the GWMPA that restrict decision making to select entities, or do not adequately define what appropriate collaboration is among stakeholders in the IMP:

**Mandatory IMP Interviewee #8.** "Collaboration in this sense was basically, "We will meet with you and take your input." We were told many times during the (name of NRD redacted) IMP process that the NRD board would make the decisions. We sent in comments. My recollection was that the NRD drafted the IMP and presented it to the stakeholders. In many cases the department responded the same as the stakeholders did. Everyone was feeling their way. There was no set process".

**Mandatory IMP Interviewee #7.** "The statutes say that they are to consult and collaborate with us. Those are two different words. They have two different meanings. And very often what we find is, they come and consult, and they say, "We are consulting and collaborating with you now." And we would often ask, "Where is the collaboration? Where is the part where you are asking us to be involved with and participate in finding solutions to this? Because it seems like really what you are doing is consulting only".

Other interviewees who participated in various IMP development meetings believed that the highly technical nature of discussions impeded participation. As one stakeholder commented:

**Mandatory IMP Interviewee #9.** "And I do know that the water professionals and irrigators came. I think the process would have benefited from a much more educational bent. Because not everyone was on the same level of education on how water works and how this whole thing gets put together. There was very little if I remember it right, very little effort to bring people up to speed with all the stakeholders in fact. And I think I came at it with a fairly decent knowledge, but there was a lot of jargon and acronyms and things like that that probably limited how well people could participate".
