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

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Crane Workshop, China) that describes habitat use. Once again, wetlands were the predominant habitat type for roosting. Also, refer to Amy Reichert's 1999 Ph.D dissertation on whooping crane habitat use from the University of Nebraska. Development of wetlands in the Platte Valley by The Nature Conservancy and other conservation groups has resulted in use by whooping cranes as well. Even at Bosque Del Apache NWR in New Mexico, the cross - fostered whoopers roost in the highly regulated water impoundments adjacent to the Rio Grande River unless the impoundments freeze. Only then will they roost in the river. My point is that off -river roost sites must be included not only for biological but also for economic reasons as well. NPPD's Cottonwood Ranch is a case in point. As you know, the FWS intends to clearcut a gallery forest and engineer a channel which meets the definition of roost habitat. The purple loosestrife problem, the sediment concerns, and the ongoing disking necessary to maintain the open river channel will be a costly experiment. This does not even consider the loss of biological diversity resulting -from the clearcutting efforts currently underway. It may be less costly and more beneficial to whoopers to create wetlands in the former wet meadows there. By restoring marginal croplands to prairie and wetlands, the same enefits to whoopers may be attained. If not, the more intensive clearcutting route can be taken. It is interesting to note that since the completion of the Kingsley Dam in 1941, the whooping crane population has increased 13 -fold. My point here is that use or population size may not necessarily prove a cause and effect relationship. I wonder if the Platte River would even be considered if the FWS was charged with designating critical habitat today. Whooping crane experts that I have visited with would be hard pressed to consider the Platte River given our current state of knowledge. Certainly none would be willing to state on a witness stand that the continued existence of the species would be in jeopardy if the Platte River were to disappear. That aside, the development of off -river roost sites will not diminish the need to maintain instream flows due to the direct positive relationship of river stage to groundwater levels in the adjacent aquifer. On page 4 of the Draft R3 -1 Document states "In February and March, rising ground water levels thaw the soil and initiate biological responses of soil organisms." What specific studies on what soil organisms were used as a basis for this statement? I am not aware of such studies yet I know this argument has been used as a basis for instream flow requests and other legal proceedings. If there are any, you should include them in this document with supporting evidence. Least Terns and Piping Plovers At the February Monitoring and Research Workshop held at the Trust offices, it was interesting to note that the species experts did not think it wise to create permanent -y nesting habitat due to the problems associated with predation. That the central Platte River does not offer any naturally occurring nesting habitat for these species is amply demonstrated by fact that there were no tern or plover chicks were known to fledge on any natural river sandbar during the entire decade of the 1990's. A 50 -60 day window of flows less than about 1500 cfs during late May through mid July is necessary to allow for nesting and subsequent fledging. This did not happen in the 1990s. Nests and /or young `' were flooded out. The efforts exhibited by conservation groups to provide nesting habitat