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<br />. <br /> <br />Mr. Ralph Morganweck <br />December 14, 2001 <br />Page 2 <br /> <br />To simply allege, as is done in the draft report, that best available science, knowledge and <br />information were used does not demonstrate or ensure that these principles in fact governed the <br />discussions. Data summaries are not included or referenced and judgments are not supported by <br />references to scientific principles or literature. For example, different methodologies are used to <br />anive at the percent recovery objective for each species and no specific justification is provided. <br />Statements like "ninety-eight plovers does not appear to be enough to support a viable population <br />of', when combined with the exclusion of certain areas because there is little knowledge of <br />species activity in those areas also reflects the lack of scientific justification for the conclusions. <br /> <br />In regard to whooping cranes, the document states that a 90-10% split in habitat should occur in <br />the Central and Upper Platte but then concludes that 100% of the goals should be met on the <br />Central Platte. Both of those conclusions are presented while acknowledging that only 16% of <br />the whooping crane sightings in Nebraska have been on the Central Platte. <br /> <br />The information on the pallid sturgeon suggests that there is extensive information about its use <br />of the Platte River but does not provide any direct data on distribution, number and demography <br />ofthe species to support the assertions. This information appears inconsistent with previous <br />literature reviews and data summaries. <br /> <br />. In previous correspondence your agency has indicated that many of the CA participants have <br />advocated the need for Central Platte recovery objectives. While we understand that the question <br />"How will we know when the Platte River is not restricting recovery?" might be interpreted to <br />suggest the need for species recovery goals for the Central Platte, it was not our intent to propose <br />that such recovery goals be developed. For the reasons noted, we believe that such an effort is <br />unnecessary, and would be counterproductive. We recommend therefore that the process to <br />establish species recovery goals for the Central Platte be terminated, that we reserve the energies <br />and resources that might otherwise have to be consumed in finalizing that effort, and that we <br />instead focus on completing formulation of the Platte River Program. <br /> <br />Sincerely, <br /> <br />Don Ament <br />State of Colorado <br /> <br />Mike Besson <br />State of Wyoming <br /> <br />Roger Patterson <br />State of Nebraska <br /> <br />. JC <br />