Incorporation of Governance Committee Comments on draft IMRC

Home Browse Search

COMMENTS FOR THE INTEGRATED MONITORING AND RESEARCH DOCUMENT General Comments The CA participants have agreed to implement certain land, water, .and habitat management activities. These activities are to be implemented to provide benefit to the species. However, given the overall habitat range of the species the CA participants can only affect a small portion of the species habitat and therefore can only incrementally benefit the species. The CA acknowledges this and does not suggest that the participants should be responsibly for recovery of the species. The Service has the responsibility for the overall range of the species and their responsibilities go beyond those of the CA participants. The IMRC does not clearly distinguish'CA goals versus overall Service goals. It is acknowledged that the IMRC is a scientific document, but as a CA deliverable it should not include activities that are the Services responsibilities. It is useful to delineate the overall context in which the CA is being implemented but as written the IMRC blurs the lines of responsibility. This is especially evident in the Pallid Sturgeon section. The document should be clarified in all sections in this regard. 2. The introduction of the IMRC should include a section that describes what the overall purpose of the program is and the monitoring and research activities should be more closely tied to the program goals. It is suggested that the program goals from CA Attachment III page 3 be incorporated as the governing principle(s). The individual sections for the species should be modified to more closely align with the CA program goals. 3. Many of the various committees involved in the CA will likely have some monitoring needs. A more holistic effort needs to be made to integrate the Technical Committee efforts with individual committee monitoring needs. This is especially true for the EA Committee and Water Management Committee. 4. The document as currently written is very nebulous in regard to what is currently known about the needs and distribution of the species (i.e., baseline condition). Some effort needs to be made to establish and include acceptable current estimate of species distribution and numbers. In addition, numeric species population goals are provided for the Platte River but the central Platte is handled more generally. This commentor agrees that it seems inappropriate to set definitive population goals for the central Platte for the reasons stated in comment 1. However, the document suggests that population numbers will be one of several parameters that the Service will use to evaluate the success of the proposed Program. The document also states that the Service will not use specific numbers for the first increment. This issue of performance should be raised to the governance committee because the document should identify the overall objectives for the monitoring. As it stands the document attempts to both reserve the rights of the Service to reject the Program even if the parties perform all necessary actions, and to provide the parties some form of comfort by stating that specific numbers of birds will not be used. The document as written creates further ambiquity on these issues and should be revised.