Draft Final R3-1 Document (2) - Laserfiche WebLink

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River, to unilaterally accept things like Joint Study documents, models and the exclusion of certain habitat types when we have consistently expressed our feelings on these subjects. Since the R3 -1 does not indicate how adaptive management will be used or how the information gathered will be used other than to evaluate the Program at the end of the first increment it does not serve much purpose for the Technical Committee. While the FWS may present the R3 -1 document to the Governance Committee as fulfilling their milestone I believe that the IMRC will better serve the Technical Committee as a basis to design our monitoring and research. In conclusion I am not sure of what the existing R3 -1 document is other than a different version of the IMRC backed by questionable data. Because of this I suggest the Technical Committee stick with the IMRC and the FWS try to better indicate how they are going to "ascertain biological response of species and habitat to mitigation measures ". Specific Comments; Page 2, first line — As a biologist familiar with the three target bird species and the Platte River I question how not having a Program would jeopardize the continued existence of the species and how this Program will alleviate a problem that doesn't exist. Page 2. Evaluation Process, first paragraph — The P3 -1 Document written by the FWS indicates that habitat and population responses of the target species and other species will occur on an ongoing basis (annually) to determine if the Program is serving as an RPA. The R3 -1 Document written by the FWS indicates the RPA determination will be made at the end of the first increment which is correct? Page 2. Prior to Program Implementation, Bullet 1. — The Joint Study does not constitute current knowledge. Much of the information in the Joint Study was professional opinion and is more than a decade old. If the Joint Study information had been based on empirical data collected in a scientific manner it would have received more support by all the participants of the Joint Study. That did not happen and nothing has changed that makes the Joint Study more acceptable today. Thus the FWS reliance on this document to identify suitable habitat can not be supported. The R3 -1 needs to be peer- reviewed if accepted by the Governance Committee and because of it's heavy reliance on past FWS documents I believe they should also be peer- reviewed through the Technical Committee Process. Page 2. Prior to Program Implementation, Bullet 2. — If the FWS is listening to input from the Technical committee, the Rl -1 document will not contain models and neither will the evaluation process. Numerous Technical Committee members have expressed their opposition to use of models in these venues. Page 3. Prior to Program Implementation, Bullet 4. - Are long -range species recovery objectives, population parameters, will they be specific to the central Platte River and how will they be used by the FWS in evaluating this Program? Page 3. At the end of the First Increment — The scenario outlined in this section makes little or no sense to me but this is my interpretation. We are going to look at the changes in quantity, quality and distribution of habitat and species use based on a FWS definition of suitable habitat. Then we are going to evaluate the sustainability of improvements by parameters defined by the FWS. Then Ultimately we are going to be held to FWS recovery objectives that are currently undefined. This would seem to totally circumvent the need for a Technical Committee and is hardly cooperative. Instead we are going to implement a FWS Program, evaluate if they were correct in their assessment of the situation and if not ask the Program participants to fix it? Instead of fulfillment of Program purposes shouldn't we be evaluating completion of \ Program objectives and taking an unbiased look at how that relates to Program purposes and then adjust the / objectives to insure the Program is fulfilling it's purposes through adaptive management. Page 3. Rationale for Determining Data Needs. - As a member of the Committee directed with making sure that any Program developed is based in sound science and logic I can not agree with the "Rationale for Determining Data Needs ". There are numerous papers, professional opinions, legal filings etc. that contradict the rationale used in the R3 -1 document. Without reasserting all of the issues this section brings up (which would be volumes of material) here are some specific questions and statements.