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Letter to Technical Committee <br />Comments of Platte River Project on draft IMRC <br />possible to improve habitat for the pallid sturgeon by managing flow in the central Platte <br />River that may also affect the pallid sturgeon's lower Platte River habitat." (Proposed <br />Program, p. 3). As implemented through the proposed IMRC, this goal would import -- as <br />a Program responsibility -- a multi - million dollar monitoring and research program for the <br />sturgeon in the lower Platte. Aspects of this research program would include an estimated <br />$1.3 Million monitoring effort concerning spatial and temporal movement patterns of the <br />pallid sturgeon, and another $1.3 Million toward monitoring of its prey, base occurrence and <br />distribution. We are not convinced that these efforts are essential to test the assumption that <br />Program flows in the central Platte will also benefit lower Platte River habitat. <br />Similar questions exist regarding proposed IMRC activities for the other three target species. <br />For example, we question whether it is essential that the Program fund research on the <br />effects of temperature on insects eaten by piping plovers ($600,000) or on the availability <br />of prey base in non - riverine reproductive habitats for terns and plovers ($350,000), <br />particularly where it is not established that prey base availability limits populations of these <br />birds. <br />B. What is the relative priority among the essential tasks? <br />C. Among these tasks, are there more cost - effective or alternative means of <br />accomplishment? <br />As one example, assuming the proposed rate of $35 /hour for technicians, the task alone of <br />monitoring the pallid sturgeon's prey base has been allocated 2,857 hours per year for each <br />of the 10 -13 years of the Program first increment. Even assuming that is a necessary <br />Program undertaking, we question whether this level of effort and expenditure is appropriate. <br />Another example is the monitoring of river flows and other physical components in the lower <br />Platte River, including influences of major tributaries. The proposed cost of $ 100,000 per <br />year for this purpose appears excessive for a monitoring effort. We need additional <br />informational support to justify this level of spending. <br />D. Is the proposed level and extent of monitoring realistic? <br />The proposed funding level for the category of General Activities/Protocols for All Species <br />is extremely costly. It is difficult to conceive of a database effort needing funding at $ <br />150,000 per year, or that such a large budget for monitoring changes in the physical and <br />structural characteristics of habitat ($ 225,000/yr) is necessary in addition to the monitoring <br />that is projected for each of the target species. <br />2 <br />