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February 6, 2006 <br />Colora.do ITS Proposal <br />1. The biggest problem with the birds is the surrogate index for change in channel <br />morphology. <br />2. There is not really a RPM for the change in channel morphology. I think we <br />should create an RPM that is tied to channel morphology, but more closely to the <br />certainty that the Program seeks. <br />3. Colorado suggests that the Service should adapt an RPM based on what the <br />Service already found acceptable for net erosion at page 3 and page 10. I would <br />change RPM 2 for a11 three birds as follows: <br />The Program shall implement the Land Plan in order to protect and, <br />where appropriate, restore 10,000 acres of habitat by no later than the <br />end of the First Increment [NOTE THIS IS A PAR.APHRASE OF <br />MILESTONE 51 and shall, subject to potential changes indicated by <br />the adaptive management plan, implement water management <br />measures for the benefit of the ecosystem to avoid take. [Note I <br />interpret "BENEFIT OF THE ECOSYSTEM" as code for clear, level <br />and pulse] [for the terns and plovers insert the following] The <br />Service must concur when Program water management actions will <br />be implemented for the benefit of ecosystem restoration when there is <br />a known potential for take. [ for the Whoopers insert the nezt <br />sentence instead] Program land management activities shall be <br />scheduled and conducted such that the possibility of take caused by <br />disturbance/harassment due to such activities is reduced or eliminated <br />on areas managed by the Program. <br />4. For the birds, condition the use of the habitat surrogate index to situations in <br />which the 5 year rolling average of the Tern and Plover population survey <br />decreases by greater than 10%. The thought being that there would not be any <br />indication of take if the population was stable and the 10% would reflect the <br />potential for natural fluctuations to skew the result. <br />5. More troubling to Colorado is the Pallid RPM 2 that directs the program to <br />"...minimize the effects of flow-related Program activities and new depletion <br />plans effects on February through July ... peak flows." Tied with the terms and <br />conditions for RPM 2, there will be no way net deple#ions could take place on the <br />peak of the hydrograph. I suggest that RPM 2 be amended to delete the words <br />"and minimized." The terms and conditions for RPM 2 should be deleted in their <br />entirety and replaced with: <br />During the first Program increment, impacts to tLe pallid <br />sturgeon that are caused by Program activities or by new water <br />related activities covered by the states or federal depletions plans will <br />be assessed. The assessment will be conducted through the paWd