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

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L w PLATTE RIVER WHOOPING CRANE MAINTENANCE TRUST, INC. 6611 W. WHOOPING CRANE DRIVE, WOOD RIVER, NE 68883 Jim TEL (308) 384 -4633, FAX (308) 384 -7209 trust @whoopingcrane.org • www.whoopingerane.org May 19, 2000 Dear Clayton: Thank you for giving us the opportunity to comment on the Draft Final R34 Document dated April 17, 2000, The USFWS has assembled a comprehensive list of procedures for ascertaining biological species response and habitat mitigation for the Platte River Cooperative Agreement. The Trust believes that most of the proposed measures are on the right track, and it's important to include the channel cross - section profiles established by the Bureau of Reclamation for monitoring channel changes. Although it would be desirable to assess the direct causes and effects of the Program, it will be difficult to do that after the Program is in place, particularly since much of the river's flows will be re- regulated. Some mitigation efforts, such as flow releases for specific purposes, may be tracked directly to understand the direct effects, but it will be very difficult for the most part to separate natural flows from Program flows. Specific comments: 1. We believe the Service's interpretation of the R3 -1 definition should include an evaluation of the effect of mitigation measures on the quantity, quality, and distribution of habitat for non- target species (Page 1, 3rd paragraph). 2. We have a concern about examining the immediate impacts on channel morphological processes. It appears to us that we will not see immediate morphological changes, because we are dealing with an episodic process (e.g., unpredictable high flow events). Consequently, we may be able to measure flow and flow characteristics immediately, but sediment and morphological process may not be measurable immediately. 3. In terms of the flows created by the Program, we feel that the questions related to the impacts on habitat should focus on the overall impact of the combined Program and natural flows as opposed to evaluating just the Program flows. For example, Al (whooping crane) should be worded as "How does river flow management under the Program ..." Therefore, we believe that examining overall flowsAre important because separating the impacts of Program and natural flows will be difficult. 4. General comment: There is quite a bit of overlap in the data collection for each of the species. Collection for all species should be coordinated whenever possible. 5. Species responses: We believe that it will be difficult to show a oamse and effect for the targeted species relative to the Program. There are no guarantees that specific tracts of land under the Program will be used by target species. For example, the measures should reflect the habitat use of whooping cranes throughout the critical habitat, and not just on Program lands. Moreover,