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To: <br />Martha Tacha, USFWS <br />Cc: <br />Clayton Derby, West, Inc. <br />From: <br />Paul Tebbel, National Audubon Society <br />Date: <br />5/19/00 <br />RE: National Audubon's comments on the R3 -1 Document <br />These comments represent National Audubon's positions on the Draft Final R3 -1 document <br />circulated by the Fish and Wildlife Service (Service) on April 17,2000. <br />Background <br />It is no secret that the different sides represented in the Platte River Cooperative Agreement do <br />not agree on the conclusions or quality of the science used to take a position on the needs of the <br />target species. These positions are often based on conclusions, which, because of the rare <br />presence of their subjects, are not statistically significant. When science is based on limited <br />information and inconclusive results, it is easy prey for opposition. I have been part of this <br />process for over five years and I know first hand that there will never be agreement on scientific <br />efforts like the Joint Study, Carter Johnson's work, or Paul Currier's work —just to name a few <br />examples. <br />The Proposed Program will likely involve the most intensive monitoring and research effort on <br />the target species in this area to date. Not only will the target species be observed more often and <br />more carefully, but also those observations will be based on protocols that should allow for <br />appropriate conclusions. Likewise, changes in habitat quantity and suitability will be carefully <br />monitored especially when these changes can be directly attributed to program actions. Through <br />this long and careful process, it is hoped that the results will show conclusively that benefits for <br />the species are being secured. Clearly, the success of this program will be based on what we <br />learn from our efforts, not from continuous arguing over past positions. <br />Audubon believes that the best hope for helping threatened and endangered species lies with good <br />science. We believe that the proposed program, as envisioned, is the best option for the target <br />species because it is based on good science. <br />This Document <br />The R3 -1 document follows past positions taken by the Service, as it should. This will result in <br />strong disagreement from some parties within the Cooperative Agreement. We feel it is <br />appropriate for all sides to register their positions clearly at this phase. However, unlike work <br />products that are cooperative in nature, this R3 -1 document signifies the positions taken by the <br />Service to complete their responsibilities as mandated by the Endangered Species Act. Its <br />function is to describe what the Service views as their responsibilities and positions to the other <br />