State Concerns with Draft Biological Opinion

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There are two main issues: 1. The draft BO states that FWS considers the Adaptive Management/IMRP component to be a fundamental part of a successful basin-wide recovery- implementation plan (dB0 :p. 291). The States agree. However, the draft BO then defines scientific adaptive management (dB0 p. 294 and 298), concludes that the current Program is iincomplete in this area (dB0 p. 297), but assumes "an acceptable scientific adaptive management process" will be developed and included into the final version of the Program (dB0 p. 298). Throughout the negotiations the States have; insisted on an adaptive management plan that is different than a"scientific" adaptive managernent process. The difference is that the States want the Governance Committee members to retain control of adaptive management decision-making. How a process might be designed to accomplish Program needs will be determined by the Governance Committee following the proposed series of workshops on the subject. The dB0 assumption that the Service position must be adopted seeks to predetermine the outcome of the workshops and the negotiations that follow. This assumption should be stricken and disavowed by the Service. 2. The draft BO Conclusions section (dB0 p. 317) states in part that, prior to the final BO and EIS, progress should be made toward making the Program consistent with the May 17, 2004 handout titled "BIOLOGICAL CONCERNS REGARDING THE PLAT'TE RIVER PROCpRAM." The draft BO suggests that among the areas that rriust change is that: a scientific adaptive management framework [must be developed] which iricludes a program objective to use combined Iand and water management activities to restore a semblance of natural riverine functions and processes (ie. Sediment supply and transport, a more normalized flow re€;irrie, floodplain connectivity, etc.); identification of hat>itat restoration as the primary focus for land management activities. This conclusion in the draft biological opinion should be deleted for the following reasons: • Nothing in the May 17, 2004 document addressed adaptive management, and as stated above, issues identified in this document were addressed by t:he June 14-15 Governance Committee document and should not be raised again. • This conclusion of the draft BO hardwires assumptions that are supposed to be testf;d by the adaptive management/IMRP process. ()(lflll()tll?l!\f\\G'?Cf t G '2 O . . . 8