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

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I for these birds can only be characterized as a dismal failure. The habitat simply does not exist under current conditions. My study of the nesting ecology of both species from Chapman to Lexington during 1985 -1991 chronicles the situation (see annual reports submitted to FWS dated 1985, 1986, 1987, 1988, 1989, 1990). My nesting habitat data and population estimates �z during those years do not agree with Tables 1 -2 and 1 -3 (op cited, Lingle 1993. Causes of nest failure and mortality of least terns and piping plovers along the central Platte River. Pages 130 -134 in Proc. Missouri River and it tributaries: piping plover and least tern symposium). River use was greatest in 1985 following back -to -back 100 -year flood events during the summers of 1983 and 1984. This stochastic event created plentiful sandbars along the river which were used by both species. The shift to sandpits occurred during the subsequent years to the extent that sandpits or dredge islands are the only places where young have fledged in recent years. This begs the question as to whether it is in the best interest of the species long term well -being to attract them to an area where they are likely to be flooded or eaten by je m predators. The best production occurs at Lake McConaughy and the lower Platte River �es but the Cooperative Agreement does not allow for those areas to be considered. Clearly ' stochastic flood events provide the necessary requirements for these species to nest throughout their range and it is this ephemeral nature of that type of habitat with which these species evolved. It is unrealistic to think we can replicate these types of flood events through releases from the Environmental Account stored in Lake McConaughy. The birds will nest at sandpits and one way to insure their success is to hire tern and plover wardens to guard each nest young 24 hours a day through the nesting seasons One 4other way to provide habitat is to ensure instream flows do not exceed 800 cfs during the * nesting season. Pallid Sturgeon How you can monitor the impact of flow releases on a fish species that may or may not exist 200+ miles downstream is beyond my comprehension. Fortunately, I do not have to deal with that problem. Other Species of Concern The institutionalized clearcutting of riparian forests that is currently underway under the guise of endangered species habitat augmentation can only be characterized as dendrophobic (dendrophobia is the irrational fear or hatred of trees). No one knows what is being lost since there are no thorough inventories being done prior to treatment. The avifauna associated with these riparian zones is rich with neotropical migrants (e.g. willow flycatcher and Bell's vireo) that are experiencing serious population declines elsewhere in their range. Riparian cottonwood forests are perhaps the most endangered habitat type in the West and Southwest yet here they are treated like musk thistles. The arbitrary and capricious nature of the Cooperative Agreement is best revealed by the fact that the federally endangered Bald Eagle was not included in the list of target species. This was done despite the fact that the central Platte River hosts one of the largest wintering concentrations in the lower 48 states and has an increasing number of