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

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COMMENTS OF CONCERN: Some comments in the document are a cause for concern: Long range species recover objectives are vague and confusing. Will these be Platte River objectives? Can we set long -range species objectives knowing that the Platte River is only one of many habitat areas for all the target species? The section on land use patterns raises concerns for landowners in the Central Platte. We have consistently told landowners that if they choose not to participate in the CA they do not have to. If land use is going to be one of the criteria used to evaluate the effects of the Proposed Program then these landowners ARE going to be effected. The use of the term sustainability is of concern. How will the Service determine sustainability of a habitat type? As other individuals have commented there was basically NO least tern and /or piping plover habitat identified in the central Platte River prior to the repetitive 100 -year floods of the early 1980's. The habitat created by those floods lasted about 6 -7 years. If 100 -year floods are the only means for natural sustainability of this habitat then the Program will not be able to meet this Service requirement. FISHAND WATER TEMPERATURE: The Service indicates that water temperatures and forage fish are a concern to the target species. Does the Service have any data showing that the temperature of the water has a negative effect on any of the four target species? Does the Service have data showing that forage fish have been impacted in the Central Platte, and subsequently, least terns were without food resources? If neither of these variable are presently limiting to the target species then the Program need not deal with them. WET MEADOWS AND SEDIMENT TRANSFERE Two things seem to be of high concern to the recovery efforts as outlined by the Service. One deals with flows for the creation and maintenance of wet meadows. There is no question that wet meadows are utilized by whooping cranes, however, research has shown that river flows have a limited impact on adjacent wet meadows. Thus it is doubtful that flow management in the river will be sufficient to recreate the extensive wet meadow complex that once existed in the Central Platte Valley. The leveling and draining of vast areas of the surrounding land is what has caused the extensive loss of this habitat and no amount of water manipulation in the river over two - three months of the year is going to recreate it. The other area of concern is in sediment transportation. If the river is presently in equilibrium, something many hydrologist believe, then there is the potential that by changing the flow patterns in the way the Service has requested disequilibrium could