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

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noted in the Document will come from Program funds? Is it realistic to think the Program can cover these costs? The Service should continue to work closely with the Technical Committee to prioritize monitoring and research and develop realistic budgets. R3 -1 Document ignores habitat benefits of off -river areas - In direct contrast to long- debated language in the CA and draft IMRC that had been agreed to through the consensus process, the USFWS inappropriately places the entire focus of biological response they are looking at to activities within the river channel. The Service's disregard of off -river roosting habitat for whooping cranes and sandpit reproductive habitat for least terns and piping plovers runs contrary to numerous discussions by the Technical Committee and, more importantly, contrary to sound science. Off -river roost sites for whooping cranes should be included in the Service's suitable habitat definitions. As pointed out in the comments of expert reviewer Lingle, "The data is overwhelming in that whooping cranes are birds of palustrine and lacustrine wetlands NOT riverine habitat. While whooping cranes do use the Platte River for roosting, it may be that the loss of wetlands bordering the river has had a greater impact on use." Lingle makes valid comparisons regarding habitat use by migrating whooping cranes that supports the relative importance of wetlands and data contrary to the river channel -focus of the R3 -1 Document. Amy Reichert's doctoral thesis likewise supports the use and importance of non - riverine wetlands by whooping cranes in Nebraska and should be factored into the Document. Discussions held in association with development of the Land Committee's Habitat Management Methods document (which tapped into the expertise of species and habitat authorities) likewise does not support the Service's "riverine only" approach to habitat management for least terns and piping plovers. Efforts to develop artificial riverine reproductive habitat for these birds were characterized as a dismal failure. Naturally occurring riverine habitat for terns and plovers doesn't currently exist in the central Platte River. Various species experts doubt the ability of target flows to provide or maintain nesting habitat. Kruse noted that permanent islands as recommended in Joint Study documents may experience higher predation rates and supported managing for "rolling habitat" throughout reaches of the river rather than development of more permanent structures. Management done by entities such as NPPD and Central lend strong support to the benefits of managing off -river reproductive habitats, the very sort of non - riverine habitats provided for in the CA and Proposed Program's definition of "associated habitats ". The Document notes the Service position that "a future Program should emphasize re- establishment of suitable riverine nesting habitat ", but what it doesn't do is justify a position that dictates the exclusion of off -river habitat. The Service needs to explain their differences in defining suitable habitat on the Platte River with those consistently used by other DOI personnel in other areas of the nation. Species and Habitat Needs - Over and above the concerns noted above, basic questions about whether or not whooping cranes are limited in any way by roosting habitat associated with the Platte.