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f <br />Off -river roost sites for Whooping cranes are a reality and may be a part of the program lands. Sandpits <br />for tern and plover habitat are a part of the river and currently the only habitat used in the central Platte <br />and obviously a land component. Mitigation of these off -river habitats influence biological response <br />and should not be ignored in the evaluation procedure. The recovery plans look at many factors <br />affecting endangered species. FWS can not just select the Platte River and fairly evaluate only the <br />biological response of mitigation measures in the river. For example, the protection of sandpits by <br />NPPD more than tripled the number of chicks fledged per nest on managed sandpits compared to <br />unmanaged sandpits. This was a biological response to management. Disking islands, clearing trees, <br />changing the timing of flow and any manipulative action, may create a biological response. Mitigation <br />measures are not confined to only the river and therefore, the land component and management of off - <br />river habitat needs to be considered in the evaluation process developed in the R3 -1 to look at biological <br />response. Anything the program does may cause a biological response either positive or negative the <br />means of ascertaining this response should be rigorous enough to detect which it is. <br />Evaluation Process <br />The evaluation process needs to be based on peer reviewed "current knowledge" and agreed upon by the <br />TC. Any models used need to be peer reviewed and tested, calibrated, and agreed upon by the TC. It is <br />important that both the TC and the FWS work together in putting the process together for evaluating the <br />species response. <br />Baseline is borderline at best. Baseline data, if it exists, needs to be agreed upon prior to its use. It <br />should consist of data and method, not opinion. <br />Target Species Suitable Habitat (attached) <br />This document which is to be used as the justification ( "best science ") to define and measure habitat and <br />potential species response needs to be agreed to by the TC and needs peer review. The FWS /R3 -1 <br />should not evaluate biological response under a separate set of rules. Current knowledge must be <br />agreed to by the TC and peer reviewed before a species response is evaluated. My recommendation is <br />that this Suitable Habitat attachment be revised. The TC and FWS need to develop and agree on the <br />suitable Habitat definition. <br />- 2- <br />