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6. Incidental Take Statement Reopeners. We appreciate the Service's work on improving the <br />quantification of anticipated take in the Incidental Take Statement. The revised ITS specifies <br />a number of "new information" reopeners that are redundant of the general reinitiation <br />criteria set forth at the conclusion of the BO. For clarity, we believe a single section on <br />reinitiation is appropriate, and request that the additional provisions on pages 309, 313 and <br />316 of the Draft Final BO be deleted. <br />The concepts concerning scope of reinitiation at page 304 of the ITS also need to be <br />reiterated in the closing statement of the document. These changes are reflected in our <br />markup of page 321 of the Final Draft BO accompanying these written comments. <br />-4-