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December 14, 2001 <br />Ralph Morganweck <br />Regional Director <br />Region VI <br />U.S. Fish a nd Wildlife Service <br />134 Union Boulevard <br />Suite 400 <br />Lakewood, CO 80228 <br />Dear Ralph, <br />This letter is a follow-up to correspondence exchanged in the late summer and fall of 2000 <br />regarding development of Central Platte River species recovery goals. After reflecting on the <br />pros and cons of establishing those goals, we believe that such an effort is presently unnecessary <br />and in fact would be inconsistent with the CA and potentially counterproductive to reaching <br />agreement on a long-term basinwide Platte River endangered species Program. <br />Consequently, we believe it woald be more productive for the states and tke F&WS to <br />collectively keep our focus on the goals and objectives of thz CA than to establish the species <br />recovery goals. The existing recovery plans for the species can serve as a"placeholder" during <br />the first increment of the proposed Program. The draft recovery goal report does not offer any <br />new i.nformation to help resolve ongoing disagreements regaxding the species, their habitat needs <br />or the significance of the Platte River to those species. We believe that if we axe successful in <br />innplementing a Program, the first increment will provide the essential information and data to <br />better understand the effects of the proposed Program and the effects of other recovery efforts. <br />In contrast to the potential benefits we see resulting from the Program formulation efforts, we <br />believe that the dxaft species recovery goals report includes information that is incomplete andlor <br />inconsistent and that it also conta,ins inappropriate bias. It is not the purpose of this letter to go <br />into detail on each of the problems that we see with the draft material. However, a few general <br />examples will illustrate our concerns. First, the current work product states that "pooled expert <br />opinion" was obta.ined and that best available scientific data, knowledge, and judgments were <br />used in the deliberation. However, there is no description of the criteria that were used to qualify <br />"experts" and there appears to be bias in the weight/validity that was assigned to information <br />provided by workshop participants. Minority and dissenting opinions are not provided or <br />discussed nor is it explained why those opinions were or were not viewed as best available <br />science. In some cases (especially whooping crane experts) many or most of the experts were <br />not present for the workshop. Furthermore, individuals in attendance at the workshops indicated <br />that much of the summarized information does not reflect the actual discussions and information <br />exchanged. <br />clrshare/cook