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

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Least Terns and Piping Plovers. The number one priority of flows as determined by the Service is during May and early June which is precisely when these species choose breeding locations. Flows exceeding 2000 cfs at Overton will eliminate virtually all bare sand in the upper half of the central Platte. Flows of 3,500 will eliminate all open sand in the entire reach. This has been the case since 1993. Thus, according to the Service's definition of suitable habitat, prior to a program there is NO suitable habitat for either of these species in the Central Platte River. SANDPITS Sandpits are suitable if suitable is described as a species utilizing an area repeatedly over a period of many years... SUCCESSFULLY. Success defined as a fledge ratio of chicks to adults of some value (0.7 and 1.2 respectively). Simply because the Service does not like the fact that sandpit spoil piles are the result of a mining operation does not lesson its importance to the species. The purpose of our actions is to HELP the birds. If protecting sandpit habitat accomplishes this, we succeed. The Service references the work by Kirsch in which it is stated there is no preference for in- channel habitat over sandpits and that the success rate for terns was no better in- channel than in sandpits, but the Service then ignores those statements and reverts to the Joint Study which stated that sandpits did not provide essential habitat needs for the species. The best science available states sandpits are viable habitat for the species and yet the Service chooses to ignore that. This is one example as to why there was not wide spread acceptance of the Joint Study and why we continue to argue these things. The service states sandpits had lower abundance of invertebrates in comparison to the river. Does the service have data showing that piping plovers nesting at sandpits can not meet their nutritional needs? It seems only important if food is lacking. Based upon the successful fledge ratios experienced by both the power districts, it is evident that invertebrates located along the shores of sandpits are not restricting the species. A question: If it is the Service's official stance that sandpits are NOT suitable habitat why were Section 6 funds given to the Nebraska Game and Parks Commission for the management of sandpits in the LOWER PLATTE WHERE NATURAL INSTREAM HABITAT ACUTALLY OCCURS? Pallid Sturgeon The data on the occurrence of pallid sturgeon is similar to that of whooping cranes. Twenty -eight sightings in 17 years are statistically impossible to analyze. However, given the above statement, has the Service analyzed the contribution of the central Platte River flows to the lower Platte and Missouri at the time of those occurrences?