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

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May 15, 2000 Comments on the U.S. Fish and Wildlife Service's April 17, 2000, "Draft Final R3 -1 Document" and associated April 21, 2000, "Draft Target Suitable Habitat" Document IMRC- The Milestones of the CA note the R3 -1 Document (Document) is to provide "procedures to determine the means of ascertaining biological response of species and habitat." While the Document presented by the Service does point out data needed, "possible" analysis methods and general time frames, primarily what the Document does is pose questions rather than laying out actual procedures. It proposes definitions of suitable habitat, which conflict with much of what has been discussed within the Technical Committee. The Document should adopt more of what the Technical Committee painstakingly incorporated into the IMRC. The development of the IMRC was a cooperative and consensus process which had its origins in the development of the R3 -1 Document. The Service's divergence from that process is difficult to understand. The development of the IMRC even included review by some of the same experts (e.g., John Sidle and Nell McPhillips). References - The R3 -1 Document provides little new insight into research and monitoring of target species and their habitat on the Platte. Much of the Document is little more than a reiteration of decade old Joint Study positions, some of which are taken from draft documents. Information used from the Platte River Ecology Study is nearly 20 years old. Instead of relying on recent peer reviewed articles, the sources of positions laid out in the Document are often opinion documents which offer conclusions with little quantitative, empirical data to back them up. References cited in the R3 -1 Document include numerous opinion papers, gray literature, unpublished reports and other non -peer reviewed papers. The "Prior to Program Implementation" section (item 1) notes its reliance on the "current knowledge" provided by Joint Study documents as the means of defining suitable habitat. Item 2 references use of a model used in numerous biological opinions and the sediment /vegetation model (which is as yet incomplete) and the controversial whooping crane model (which is being revised). Members of the Technical Committee have consistently questioned use of these models. The Service needs to explain how it intends to develop and use "long -range species recovery objectives" and note if the Technical Committee has any role in their development. The Document's reliance on recovery plans and biological opinions seems to backtrack from the cooperative and adaptive approach proposed in a Program. Budget /Costs- The R3 -1 Document doesn't provide an estimate of the cost to answer the litany of questions in the Document. Conducting the monitoring noted by the Service would involve funds that may far exceed the Technical Committee's budget being kicked around by the Governance Committee. Given the complexity of the questions asked it is fair to assume that it would take tens of millions of dollars to accomplish. Does the Service anticipate that costs associated with conducting the monitoring and research