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5. The overall level of effort involved with the monitoring and research program needs <br />to be revised to fit within a budget that is comensurate with the overall program <br />budget. The level of effort involved in each monitoring and research subtask will <br />need to be reduced considerably. <br />6. The IMRC should have more emphasis on monitoring milestone compliance as <br />established in the CA versus species recovery. <br />Specific Comments <br />1. Page 6 Please be more specific about what type of biological models are being <br />considered and why they "must be developed ". It is unclear how the models can <br />fulfill the objectives stated later in the paragraph. <br />2. Page 6 It should be clarified that the Coottonwood Ranch site is part of the 10,000 <br />acres under the first increment. <br />3. Page 7, 1St full paragraph, The EA annual operating plan does not currently provide <br />any consideration of the "status of the species of concern, status of the habitat <br />characteristics of the species of concern, and the goals of the Governance <br />Committee ". Either the EA plan needs to be modified to include this information or <br />the document needs to be revised to reflect the EA plan. <br />4. Page 7, 3rd full paragraph, A detailed discussion should be included to describe the <br />current range of the target species and their use of the 57 mile habitat area. This <br />discussion should also acknowledge the limitations this imposes on the program <br />monitoring. In doing so a better understanding will be provided regarding why the <br />program can not be considered a recovery program. <br />5. Page 8, top of page, It is recommended that the IMRC state a clear preference to <br />have monitoring protocols be identical unless there is a specific reason why you <br />would want to vary the monitoring protocols. <br />The section also states that monitoring of specific projects is also needed. The IMRC <br />seems to encourage having a separate overall monitoring program, and project <br />specific independent monitoring activities. The sum of the monitoring of specific <br />projects should constitute the monitoring program. <br />6. Page 9, top of page, Given the complexity of the task and the absence. of good <br />baseline information doesn't it make sense to place more emphasis on simply <br />monitoring when and how the species use the modified habitat and any trends. <br />Currently there is significant focus on trying to develop a program that will evaluate <br />"cause effect relationships" via multivariate analysis. This type of approach is very <br />time consuming and is driving the cost of the monitoring. <br />7. Page 9, last paragraph, The Pallid Sturgeon is described as being a target species in <br />the CA and the CA also indicates that the Service will consider adding it as a target <br />species for the preferred alternative. Can this be clarified? It is this commentors <br />understanding that positive effects, if any, to the Pallid Sturgeon would be considered <br />a desirable bonus of the program but that the sturgeon is not a focus of the program. <br />This point is critical in regard to understanding what level of monitoring should be <br />performed for the sturgeon. <br />8. Page 9, bottom of page, The discussion uses the example of water supply projects as <br />a reason to be sensitive to other species. This is somewhat misleading. The impacts <br />associated with grossly disturbing 1000's of acres of vegetation is more likely going <br />to cause direct mortality of organisms as well as loss of habitat. These impacts need <br />to be aknowledged and reconciled in a more meaningful way in the IMRC. Are there <br />less destructive ways to achieve species benefits without impacting so much riverine <br />2 <br />