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To: Clayton Derby From: Jim Jenniges — Technical Committee Member Subject: Comments on the R3 -1 Document Date: 04 May 4, 2000 Clayton, I am providing the following comments as a member of the Technical Committee for inclusion into the composite Technical Committee comments. General Comments: First and foremost I do not believe this document identifies any "procedures" that will evaluate mitigation measures on habitat or species. Instead it offers numerous questions on how the program will impact various aspects of habitat and species. The Technical Committee already developed that work product it is called an Integrated Monitoring and Research Component. After a brief discussion at the last Technical Committee meeting it became apparent that my interpretation of the "procedures" that would be used to answer the questions is quite different than what the FWS had in mind. For example we started to discuss Question A.3.a under whooping cranes I assumed that because sediment supply is a function of flow that we would be evaluating how Program water affected sediment transport and if the affect was detectable over baseline and was it beneficial or not to the habitat and species. The FWS however indicated that the way they looked at answering this question was to look at channel stability over the long -term and analyze sediment input at the top of the study reach versus sediment outflow at the bottom of the study reach. I believe that the R3 -1 document would be much more useful and less ambiguous if the FWS would expand their outline under the "Assessment of Program Impacts" to include how they feel the questions provided could be answered. I had trouble interpreting the tables provided. All of the questions asked in the text amount to research efforts and all the data needs and analysis in the tables amount to monitoring and model comparison which approach does the FWS promote. It would be helpful if the FWS would reword their questions where possible so that they more closely reflect what the Technical Committee has already agreed to in the IMRC. I also believe that the FWS should point out where they see differences between their document and the IMRC since I tried this but can not be sure of how to interpret their questions. The IMRC was based on input from basically the same people as reviewed the R3 -1 so there should not be many differences. If the true goal of this Program is to secure defined benefits to the target species then as a biologist I can not support using the "Draft Target Species Suitable Habitat" document the R3 -1 is based on.. It is based on past FWS reports, BO's and opinions. As you know there are numerous questions about the validity of all those documents and I will try and point them out where I know they exist. My review will be short and incomplete because over the years there has been mountains of material written on this very subject. Repeating all of them would take more time and effort then is being allowed and would amount to comments that are much longer than the original document. Because of the reliance on biased past material the R3 -1 does not even recognize what might be the best ways to secure benefits for the species such as; palustrine whooping crane habitat and sandpits (i.e. lakeshores) as least tern and piping plover habitat. As a member of the Technical Committee I can not support a Program that does not at least evaluate the suitability of off river habitats. While the proposed Program outlined in the CA does indicate that the Program will start by managing land as defined in the Joint Study it also identifies the need for adaptive management, data acquisition and peer - eview. It seems unreasonable to me for the FWS to believe that the Technical Committee of the CA, which is supposed to be made up of scientist currently working on or have a good knowledge of the Platte