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Mr. Paul Tebbel <br />2 <br />Lack of Research Protocols and Inability to Address Causal Relationships <br />The document's lack of research protocols and statements of the Program's inability to identify <br />causal relationships are significant weaknesses. The purpose of the IMRC is to provide <br />biological evidence to support management decisions. Identifying and documenting causal <br />relationships will be an important part of this effort. We recognize that monitoring alone will, at <br />best, only correlate resource trends and management actions. However, given current hypotheses <br />of ecological relationships and system processes, "management experiments" can be proposed <br />which, coupled with carefully developed monitoring and research protocols, may provide <br />evidence to support certain causal relationships and refute others. We believe that development <br />of such "management experiments," carefully coordinated with monitoring and research efforts, <br />should be a focus of attention for the document. To this end, research should be considered <br />equally with monitoring rather than given the secondary position it currently holds in the <br />document. Only by formulating such hypotheses and research questions will such a coordinated <br />effort move forward, and the IMRC is the key document for this process. <br />Specific and Quantifiable Objectives <br />The monitoring and research program must include specific and quantifiable biological <br />objectives, currently lacking in the document. The effectiveness of Program management actions <br />will be based on certain measures of habitat response. If there is no clear statement of the <br />magnitude of the proposed response, there is no clear understanding of the magnitude of <br />management actions necessary to achieve the response. Conversely, without'a clear statement of <br />the magnitude of the proposed management, it is difficult to determine whether effects will be <br />measurable. In turn, developing effective monitoring becomes problematic without some <br />understanding of the expected effect size and the necessary statistical power to detect this effect. <br />Furthermore, indirect effects, such as population response of a target species to changes in <br />habitat, may become still more difficult to detect and correlate to management actions. Overall, <br />documenting the progress of the Program toward attaining first increment goals will be <br />impossible without such specific and quantifiable biological objectives. <br />Implementation or "Compliance" Monitoring <br />Key questions of program implementation and "compliance monitoring" must be asked by <br />Program managers, though the topic is specifically avoided in this document. These questions <br />relate to timely attainment of program objectives including acquisition, protection, and <br />restoration of 10,000 acres of habitat; and reductions of average annual shortages to target flows <br />by 130 - 150,000 acre -feet. Obviously, evaluation of the effectiveness of Program elements <br />cannot occur until these elements have been implemented and are acting on the system. While <br />other entities are responsible for developing related components of implementation monitoring <br />(e.g., Milestones W14 -1 and P3 -1), their use must be incorporated into this document. We <br />believe that this document must integrate monitoring of Program implementation and Program <br />effectiveness and identify specific protocols necessary for monitoring Program implementation. <br />Geographic Scope <br />Important questions of the geographic scope of the Platte River Basin for the purposes of <br />