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

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parties involved in this program. It is not open to collective agreement, although suggestions on clarifications or other constructive improvements are appropriate. Audubon's Position We feel that the R3 -1 document gives good general direction to the participants in the program. It assumes that some of the information collected during the program may be better than existing information, resulting in improved definitions and understandings. This document also tells participants what the Service wants to see measured but not how to measure it — that is clearly a role for the program. Audubon feels that this document adequately describes what information the Service believes needs to be collected as part of the Integrated Monitoring and Research Component and will be extremely useful to the Technical Committee as they design the protocols. We offer three comments below. Input 1. The tables within the R3 -1 document are useful, especially columns one and four. However, we question the need for columns 2 & 3 since they are based suggestions and will be subject to frequent updating. For the purpose of fulfilling the milestone, we recommend removing the middle two columns. 2. The "Assessment of Program Impacts" section will assist the Technical Committee with its responsibility of writing monitoring and research protocols. However, we question the weight given to the Baseline Document (R1 -1) in R3 -1. We recommend that the Service either revise the Rl -1 to reflect data and research which address the questions posed in R3 -1 or wait until the IMRC is written and use both the protocols and this document to revise the R1 -1 document. We feel that the current RI -1 document does not fulfill its intended role as part of this proposed program. 3. There is significant emphasis on models within the "Evaluation Process." Some of these models are new and have not yet undergone rigorous review by program participants. If the Service desires more cooperation from program participants, they should allow additional review of model assumptions, components and input/output. In conclusion, Audubon finds this final draft R3 -1 document to be useful to the program participants as it clearly shows the Service's priorities when measuring program progress. Sincerely, Paul Tebbel, manager Rowe Sanctuary, National Audubon Society cc: David Sands, Director, Audubon Nebraska Frank Gill, Director of Science, NAS Dan Beard, Director of Public Policy, NAS