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undergone neutral per review, or are not complete. It is troubling that the Service has <br />placed such great emphasis on the sediment vegetation model as an analysis tool prior <br />to it being completed, validated or peer reviewed. The Service has suggested that this <br />model might be used in 13 of 26 areas of analysis. <br />A more detailed discussion regarding the process, priorities and options for <br />determining the means of measuring biological response would be useful. The <br />language of R 3 -1 is very ambiguous and needs to be clarified. Views have been <br />expressed that during the first increment R 3 -1 is aimed at identifying how one might <br />go about measuring biological response, and then the methods developed would be <br />agreed to and used in the second increment. <br />7. Issue — The concept of isolation has been included in R 3 -1. This concept appears to <br />have a relationship with the concepts of buffer and suitable habitat. Some of the CA <br />participants have expresses the view that program money only be used to acquire <br />habitat. In addition, this concept appears to go beyond the intent of R 3 -1. <br />Discussion — The concept of isolation is very subjective and the goal of the CA is to <br />obtain specified quantities of habitat. If the Service has specific recommendations <br />they should share them. If the concern is to identify anthropological influences and <br />the impact, if any, then this may be of interest to the program but may not be <br />appropriate as a means of determining biological response. Including isolation as a <br />criteria needs to be reconciled with the land goals. In addition, how does the Service <br />intend to interpret effects of changes in land use on habitat that is being used, but is <br />not part of the proposed program? <br />Issue — The concept of sustainability has been incorporated into the R 3 -1 document <br />(used for channel morphology, wet meadows, and riverine nesting habitat). This term <br />is very subjective and goes beyond the objective of R 3 -1, which is to determine the <br />means of measuring biological and habitat response. <br />Discussion — Improving and protecting habitat and securing defined benefits for the <br />species should be the focus of our efforts and the evaluation of our efforts. <br />Measurement of habitat quantity and quality and trends is an appropriate and effective <br />tool. The term and concepts described under sustainability should be eliminated. <br />9. Issue - There is concern that the current process is not allowing enough flexibility to <br />foster adaptive management. In fact R 3 -1 tends to inhibit the proposed program <br />from implementing activities which may be considered "out of the box ". <br />Discussion - There are no provisions in R 3 -1 to encourage unique /progressive <br />species and habitat management methods, which could yield valuable data, because <br />there is an overemphasis on past positions and conclusions. In addition, the logistics <br />of acquiring habitat, managing habitat, obtaining species information, interpreting <br />data, and modifying hypothesis and management methods needs to be reconciled with <br />