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• The Program document at III B specifically states that changes of <br />Program Objectives may only be done with the approval of the <br />Governors and the Secretary of Interior. This provision of the draft BO <br />is objectionable because it calls for change of a Program objective <br />through the design of the adaptive management process instead of <br />using the III B process. <br />The June 14-15, 2004 agreement reached by the parties concerning the <br />May 17, 2004 concerns addressed the natural riverine functions and <br />processes issue by adding language to page 12 of the Program <br />Document, paragraph E.l.b labeled "Peak Flow Recommendations." <br />The agreed upon language does not track the suggestion on this issue in <br />the draft BO. <br />The proposed addition of a"scientific adaptive management <br />framework" with "adaptive management objectives" appears intended <br />to narrow greatly the scope of available adaptation. The examples <br />given of adaptive management objectives [dB0 pp. 299-3001 as well as <br />the "Program objective" of "restoring a semblance of natural riverine <br />functions and processes" appear to hardwire some of the same <br />assumptions identified above into the IMRP as objectives to be <br />achieved. These objectives would prevent the Governance Committee <br />from exploring and implementing other options as described above if <br />the assumptions do not "prove out." <br />C. Incidental Take Statement. <br />The Incidental Take Statement (ITS) negates the regulatory certainty of the program <br />by defining take in such a manner as to adopt results based habitat criteria and to <br />make the states responsible for effects on the species outside of their control. The <br />States will separately address the ITS. <br />9999919000187561.5.4 <br />onnmm?nnn\u-rci ic z n <br />' " 7