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sediment issues is improper. The Technical Committee needs to fully understand and <br />review the model prior to its use as proposed in the Document. Apparently at least part <br />of the basis for the Service's concerns regarding sediment lies in their impression that EA <br />releases and efforts to meet target flows may directly result in bed degradation problems <br />which may throw the Platte out of its current dynamic equilibrium state. <br />Peer Review Milestones- <br />The Cooperative Agreement's Milestone R4 -1 states that the "...technical <br />committee... will establish guidelines and procedures for peer review of the documents <br />required in Milestones Rl -1, R2 -1, and R3 -1. This committee will develop and <br />implement a peer review work plan for the period of the Cooperative Agreement." <br />Additionally, Milestone R2 -3 states that "(p)eer review of habitat and species monitoring <br />and research conducted pursuant to Milestones R1 -1, R2 -1 and R3 -1 will be completed <br />and the results reported to the Governance Committee." The CA and the peer review <br />work plan specifically target the peer review of documents required for production of the <br />R3 -1 Document. In order to facilitate timely review, the source documents relied upon <br />by the USFWS should be independently peer reviewed. Given the R3 -1 Document's <br />significant reliance on Joint Study documents (draft and final), the whooping crane <br />instream flow model, and the sediment /vegetation model, I would suggest, at a minimum, <br />they be included in the review. The process and schedule laid out for completion of the <br />Document should not preclude the opportunity for incorporation of substantive changes <br />that may result from peer review. <br />A brief examination of the comments provided to the Service on a previous draft of the <br />Document seems to show that various comments were given greater consideration than <br />others. For example, Lingle's comments appear to have been summarily discounted <br />while those of Hutchison and Kirsch were gone over in great detail. <br />Adaptive Management- <br />The R3 -1 Document fails to adequately incorporate the adaptive management concept as <br />described in Section III.B. of Proposed Program. This critical component of any Program <br />is ignored by the R3 -1 Document. Parts 5 and 6 of Section III.B. of the Program proposal <br />specifically describe how the evaluation of habitat and species responses and how the <br />evaluations of Program effectiveness dovetail with the adaptive management process. <br />The Document needs to more fully develop and describe the procedures intended to <br />incorporate /facilitate adaptive management. <br />0 <br />