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April 11, 2008 <br />Page 19 <br />Examples of Appendix 'Us" only minimal discussion of any compelling need for WSR <br />designation, and the specific flaws of other potential protection mechanisms include the <br />following statements, among many others: <br />Alternative approaches to protecting Mineral Creek include establishment of <br />instream flows and perhaps some form of special management area for the <br />purposes of conserving the Chattanooga iron fen. Wild and Scenic River <br />designation, however, could provide similar or better protections than the <br />combination of instream flows and special management prescription while <br />providing the additional recognition of the recreation and scenery ORVs, and <br />could complement the All- American Road and National Scenic Byway status of <br />the nearby San Juan Skyway. <br />Appendix "D ", Page D -64. (Emphasis added) <br />Alternatives to Wild and Scenic River protections would include a combination of <br />instream flow protections and special management prescriptions for the <br />maintenance of the fen community. Wild and Scenic River designation could <br />accomplish the same protections and could provide some additional surety of <br />protection and marketing benefits. <br />Appendix "D ", Page D -68. (Emphasis added) The above statements, among many others <br />suggesting the need for a WSR suitability designation, fail to discuss why WSR <br />designation is the best alternative and why a WSR suitability designation provides <br />"additional surety of protection ". A detailed discussion of the compelling need for WSR <br />protections must be included in the Final Plan or WSR suitability designations must be <br />eliminated. <br />2. Failure of Draft Plan to Discuss Why Wilderness Status and CWCB ISF <br />Water Rights do not Provide Adequate ORV Protection: The Draft fails to adequately discuss, <br />especially for the stream segments that are already in a wilderness area or a wilderness study area <br />(WSA), why these protections are insufficient to safeguard ORVs. The Draft Plan states: <br />Public comment is specifically sought on the potential benefits of Wild and <br />Scenic River protections for stream segments entirely within designated <br />Wilderness areas. <br />Appendix "D ", page D -83. <br />The SWCD does not believe WSR protection of ORVs is needed in addition to wilderness <br />protection. Examples of specific, very limited Draft Plan discussions regarding the need for a <br />WSR suitability designation in addition to a Wilderness or WSA designation, include the <br />following, among many other examples: <br />