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To: Clayton Derby From: Rocky Plettner Subject: Comments on the R3 -1 Document Date: May 18, 2000 Clayton — My comments are general in nature and were made prior to FWS revisions to the R3 -1 document. I think it is important to the working relationship of the Technical Committee (TC) that the FWS does not proceed at a rapid pace to push the R3 -1 document to the Gov. Comm. without the incorporation of comments from the TC. I realize that FWS is anxious to complete their task but because the R3 -1 is so closely tied to the R2 -1 milestone that time needs to be taken to mesh more closely the R2 -1 and the R3- 1. It appears that the FWS has tried to incorporate these two documents together so as to provide the right protocols (R2 -1) to meet the needs of the R3 -1 to evaluate biological response. I do not view the R3 -1 and the R2 -1 to be the same but the R2 -1 needs to mesh with the R3 -1. It is now extremely difficult to know if the IMRC (R2 -1) meets the needs of the R3 -1 or how the IMRC functions considering that FWS is not really considering the adaptive management approach during the fist increment. It may require more time to sort these two milestones out and make them mesh more closely together. It is my opinion that the FWS just rewrote the IMRC along with the R3 -1 and tried to push it right past the TC to the Gov. Comm. In the process decided not to count the land component because it will take 10 -13 years for that to function so we don't have to worry about adaptive management. We only have to worry about what happens in the river because that's where the mitigation falls. That is a lot to swallow in a flash, when we've been working for over a year on trying to refine the IMRC (R2 -1). The FWS's sense of urgency to complete their milestone should not override the importance of working within the TC to see that the development of the R2 -1 and R3 -1 complement each other. At one time the TC discussed putting these milestones together now they may be together in the R3 -1 document but I'm not sure where that leaves the IMRC. The R3 -1 and R2 -1 need to evolve together. My recommendation is that the FWS not get so excited about completing their milestone but provide the TC time to look at both of these documents more thoroughly and FWS /TC needs to evaluate the costs associated with collecting the data required to fulfill the needs of the R3 -1. Biological Response The R3 -1 is to develop procedures to determine the means of ascertaining biological response of species and habitat to mitigation measures. The land component is a mitigation measure. The R3 -1 document is too focused on the river and needs look more broadly at the species habitat, including off -river (the land component), and to this extent, does not outline the task. The land component, which is part of the first increment, includes habitat, which may not fall into the river "proper" but could significantly influence species, and thus their response to mitigative measures implemented by the program. Even if the land component is not really in place during the first increment insight could be gained in some areas. For example, with terns and plovers nesting on sandpits or wetland habitats which may be used by whooping cranes. - 1-