Comments on the Draft Final R3-1 Document and the Draft Target Species Suitable Habitat Document

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Mark Peyton's comments on the Draft Final R3 -1 Document These comments are a little disjointed as I had difficulty understanding just what this document was actually intended to do. In my view it is a simple list of questions that will require extensive research to answer. We did a very similar thing in the development of the IMRC. However in the IMRC we prioritized the questions and developed a basic estimate of cost. I think the Service would be wise to utilize the IMRC instead of this document. With that said, here are some comments. JOINT STUDY I was a little disappointed in that this document and the document describing suitable habitat are basically re- writes of the Joint Study. The Joint Study started out as a cooperative venture but because so many issues could not be resolved it turned into a Service Product. The same issues are what we are dealing with in the CA and to simply use the Joint Study without incorporating the extensive data collected in the District's Deficiency Response and subsequent studies, the multitude of comments on the various drafts of the Biological Opinion of the Districts' license, and opinions and studies done by others will not resolve those issues. The Service has stated that it does not want to "renew old arguments over these issues ", however, until those issues are settled they will continue to be stopping blocks for the process. It has been a constant in the CA process that materials would be peer reviewed to insure they were conducted using scientifically sound methods. Very little of the Joint Study was reviewed by outside reviewers. Any studies, models, etc. that will be used in the R3- 1 document need to go through the review process and the Service needs to identify those items so that process can begin as quickly as possible. INCOMPLETE RI -1 AND R3 -1 DOCUMENTS We have been asked to review and comment on an incomplete document. The Baseline (R1 -1) Document is, as yet, incomplete and the Draft Final R3 -1 document repeatedly states that the baseline will be used to make comparisons. If nothing else, the Service should first complete the Baseline. In addition to an incomplete baseline, the sediment/vegetation model is not yet complete. In looking at the chart attached to the R3 -1 document, 13/26 areas of analysis will utilize this model. In 5/26 areas of analysis the GIS information developed for the CA is to be utilized, and in doing whooping crane habitat analysis the "new" whooping crane model will also be used. Neither the GIS database nor the "new" whooping crane model has yet to be provided to the members of the Tech Committee for evaluation. Without having seen these models and the information contained within them it is impossible for other members of the Tech Committee to evaluate if these are adequate for the analysis of the information stated in the chart.