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

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April 11, 2008 Page 17 a special water Plan index. The Roundtable meetings were designed to develop a general framework for dealing with water in the Draft Plan. The Draft Plan touches on water issues from a number of perspectives. Pipelines, wildlife habitat, timber - harvesting, recreation, cattle - grazing and other activities all can affect water quantity and quality. The SWCD does not believe that the goals of the Roundtable have been met unless the Final Plan itself includes a comprehensive table of water - related Plan items, similar to that attached as Exhibit "C" hereto, which represents only a beginning. b. SJPLC decision to move ahead with publication of the Draft Plan, despite the judicial overturn of the 2005 Rule. The SJPLC made the decision to publish the Draft Plan pursuant to, as represented in the Draft Plan, the 1982 Rule without any consultation with the Roundtable in which the SJPLC had participated for over 13 almost day -long meetings. Further, Roundtable members were not provided any written version of water - related aspects of the Draft Plan before it was published. The governmental representatives on the Roundtable were shown only slides of proposed language relating to the HRV concept and the two -step habitat protection discussion in the Draft Plan at p. 252. Had the SJPLC been more forthright in its intentions, these key water user issues might have been resolved prior to the Draft Plan publication. D. General Comments: Need for Opportunity to Comment on Revised Draft Plan of Final Plan if Significantly Changed from the Draft Plan. Should a revised Draft Plan or Final Plan designate additional streams as eligible and/or suitable or include Plan new sections which could negatively affect water development on SJPL, the SWCD asks for an additional opportunity to comment on such changes. E. General Comments: Unwillingness of SJPL Center to Extend Comment Period. The SWCD, together with a number of other public entities, had requested a 60 -day extension of the Comment Period on the Draft Plan, and then requested an additional 30 -day period after the SJPLC granted only a 30 -day comment extension. This denial, despite the SJPLC's more than 15 -month delay in publishing the Draft Plan, denied the SWCD a full opportunity to coordinate comments with other public entitles, conduct a complete review of final comments with the SWCD Board of Directors, and meet with the Governmental Water Roundtable more than once to review the Draft Plan. SWCD COMMENTS ON DRAFT EIS I. General Comments: Wild & Scenic River ( "WSR ") Eligibility and Suitability Analysis, Appendix D A. Governmental Water Roundtable ( "Roundtable ") consideration of WSR Issues. The Roundtable spent many meetings discussing WSR issues, in which numerous members of the Roundtable raised significant concerns about the proposed SJPLC process for evaluating streams for eligibility and suitability for WSR designation. Roundtable members made many