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Page 6. I. D. 1,2 & 3. - Does the FWS have some kind of information that would indicate that we would benefit the whooping crane population by having more stop on the river, utilize different areas of the river or stay longer? Why would this Program want to impact the migration dynamics of a crane population that at the current time is expanding as rapidly as can be expected? Page 6. II. A. 1. A - How do wide channels without sand equate to habitat? 17 Page 7. II. A. 2 - What is sustainability? Page 7. II. A. 2. A - Bar formation suitable for nesting is much more complex than sediment supply and _e,�a transport. You can have all the sediment in the world but if it can not build bars at heights sufficient to stay dry during the nesting period it is not habitat. If it does stay dry it has to stay intact, that is be firm enough to withstand erosion from the sides, or have gently sloping banks that reduce velocity with out eroding. _ 7 The bar must also form at elevations too great for vegetation establishment or it will only be available for one year and then be a vegetated island that can no longer erode. If a bar meets all of these criteria it must also then erode within a couple of years or become vegetated. The last time these kinds of conditions occurred was in 1983 and 1984 and those were 100 -year flood events that resulted in about 7 years of habitat. Is the FWS suggesting 100 -year floods every 10 years with water management? Page 7. II. A. 2. B. - The processes of woodland encroachment into the Platte River are better understood than most of the other processes, I suggest that the FWS read the numerous published papers from Dr. Carter Johnson, South Dakota State University. Page 7. II. A. 2. B. - Once again I can not support using a model to evaluate the Program. If we show the data does not support the model all we have done is wasted time trying to support a model. I can not over emphasize the importance of collecting emperical data in a scientifically sound manner with analysis built into the study design. Page 7. II. A. 2. C. - First question does management result in habitat (i.e. birds) then ask other questions. Do we really care about fish habitat or do we care about numbers of small fish? Numerous habitat types will support large populations of small fishes although they may be different species. Page 7. H. B. - Can we detect affect of land and flow management on distribution of birds and is it z desirable to redistribute them? What is reproductive rate? Section III. - Most comments from Section II apply to Section III. Section IV. - I believe the obvious question is can we detect a change in flow in the lower Platte that is a .- result of flow management in the Central Platte for the bird target species? Tables - I do not believe the Technical Committee or the FWS can define data needs, sources of data or analysis methods until there is a better definition of the actual "procedures ". Draft Target Species Suitable Habitat - Comments Page 1, Third paragraph. The use of Joint Study documents is not acceptable to me. As a professional °- biologist I do not agree with some of the information contained with in these documents. If they are to be used by the Program they should be peer- reviewed by outside experts along with the numerous critiques of those documents. Although I was not a participant in the Joint Study, I understand that it was a format similar to the Technical Committee and because the FWS would not listen to other parties they quit participating. Is that what we are shooting for again? Page 1. Paragraph 4. The sightings in Allen 1952 have been critically reviewed since that time and many are not accepted as legitimate sightings. This is the reason that the FWS implemented the confirmed v sighting process they have today and why sightings are only reported back to 1942. 4