Letter April 11 2008 Concerning Comments of the SOuthwester Water Conservation District in response to Notice of Availability of Draft San Juan Public Lands Land Management Plan and Draft Envrionmental Impact Statement

• Description: Comments on the SJLP
• State: CO
• Basin: San Juan/Dolores
• Water Division: 7
• Date: 4/11/2008
• Author: Sheftel, Janice
• Title: Letter April 11 2008 Concerning Comments of the SOuthwester Water Conservation District in response to Notice of Availability of Draft San Juan Public Lands Land Management Plan and Draft Envrionmental Impact Statement
• Water Supply Pro - Doc Type: Correspondence

April 11, 2008
Page 14
Statement 5.1: Desirable native plant species needs to be defined?
Statement 5.6: The consequence if a stream does not now have narrowlife or Rio Grande
cottonwood must be made clear.
Statement 5.7: The native species in fens must be defined. It must be explained if this
design criterion harks back to the HRV concept.
Draft Plan Volume 2, p.:.._29
Statement: San Juan Public Lands Highlight Species: In considering management actions
to prevent species listing under the ESA, the Draft Plan must indicate clearly how the SJPLC
considers the extensive populations of a species that may exist outside SJPL See Vol. 2, p. 40,
Statement 3.8), and, further, how the "Highlight Species" concept is related to HRV. How
achieving "ecological or other multiple use objectives" relates to the definition of Highlighted
Species also must be defined.
Draft Plan Volume 2, p. 40
Statement: Special Status Species - General.
Statement 8.1. The Draft Plan needs to define how, in determining highlight and sensitive
species, the HRV concept comes into play.
Draft Plan Volume 2, p. 41
Desired Conditions: Special Status Plant Species
Statement 9.7. Hanging gardens occur on the walls of a canyon and are supported by
seeps, not the stream below. Therefore, the Draft Plan must explain why it is necessary to
designate the stream below the seeps as suitable for Wild and Scene River ( "WSR ") designation:
See discussion of hanging gardens regarding McIntyre Canyon, Draft Plan, Appendix D, p. D-
32.
Draft Plan Volume 2, p. 43
Statement: Threatened and Endangered Species.
Statement 10.2. The location of the needed willow habitats needs to be specified. The
Draft Plan must explain the consequences if willow habitats are created by a reservoir used for
irrigation in which water levels fluctuate because of the primary uses of the reservoir.
Draft Plan, Volume 2, p. 44