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

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How will changes in the quantity, quality and distribution of roosting habitat benefit whooping cranes? Are nesting or foraging habitat limiting terns or plovers on the central Platte? Are river flows significantly affecting water temperatures? Are water temperatures limiting forage fish? Is forage fish availability limiting least terns? How much habitat do the target birds need on the Platte and what constitutes suitable habitat? What sort of flows are needed? What are the assumptions underlying the Service's positions? The Document notes the need for wet meadow flows that seem to contradict information developed by others in the DOI, which indicates relatively little affect of river flows on groundwater levels in adjacent meadows. The Service needs to explain why suitable habitat for the target species on the Platte River is apparently different than suitable habitat used in other regions in which they are found. Volumes of pertinent comments regarding the basic ecological, geomorphic and hydrologic conditions of the river as well as data on the use and reliance of the target species on the Platte River have previously been provided to the Service. They apparently continue to be ignored or discounted. Without a greater emphasis of the R3 -1 Document on research, answering the questions posed in the Document and evaluating any Program effects will be impossible. Overemphasis of Pallid Sturgeon - The Background Section of the Document discusses the purpose statements and long- term objectives from the Proposed Program, and in the process conveniently skips over the important Program goals. This is particularly important in light of treatment of the pallid sturgeon. The Program's goals include "testing the assumption that it is possible to improve habitat for the pallid sturgeon by managing flow in the Central Platte River that may also affect the pallid sturgeon's Lower Platte River habitat." Without this significant clarification, the Service's statements in the R3 -1 Document distort the intent of what the Program will try to accomplish for pallid sturgeon. The R3 -1 Document's overemphasis on pallid sturgeon not only runs contrary to the CA, but also Technical Committee discussions of dealing with the pallid sturgeon issues in a step -wise mode. Inappropriate reliance on models - The R3 -1 Document's use of a controversial whooping crane model to document habitat and species response is inappropriate and will not serve a cooperative joint effort. The Technical Committee has not seen the USFWS's revised whooping crane model or had anything except a cursory overview of the draft sediment /vegetation model and thus cannot endorse their use. Reliance on modeling results was a mistake apparently made by parties involved a similar endeavor at Glen Canyon. Use of such models to help devise management schemes is one thing, but using them to evaluate Program success is inappropriate. We are setting ourselves up for controversy, not closure with use of these models in the ways presented in the R3 -1 Document. The Document obviously emphasizes the importance of sediment. Reliance on an uncalibrated, unverified and, as yet incomplete sediment /vegetation model to analyze