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 20
The eligible portion of the Los Pinos remains somewhat unique within Colorado
as an extensive river drainage falling entirely within designated wilderness.
Wilderness designation does rp ovide substantial protections for the stream and the
scenery ORV. Wild and Scenic designation could complement this protection and
place greater emphasis on the river values.
Appendix "D" at p. D -83.
Wilderness designation does provide a great deal of protection for this stream
segment, particularly for the scenery, recreation and geology aspects, but Wild
and Scenic River designation could provide additional protections and focus on
the Colorado River cutthroat fishery.
East Fork of Piedra, Appendix "D" at p. D -98
Looking only at the portions of the West Fork of the San Juan within the forest
boundary, the ORV of geology would be well - protected by existing national
wilderness designation.
West Fork of San Juan, Appendix "D" at p. D -106. (Emphasis added)
As set forth below, by way of example, wilderness status is credited with protecting ORVs in
numerous places in the Draft Plan, but considered insufficient for other streams, without any
justification. WSR suitability designation on a stream in a wilderness area does not provide any
stated additional resource protection and, will increase public visibility and usage, and, therefore,
increase management needs with their attendant increased costs.
For the West Fork of the Dolores River, the ORV is located within or adjacent to
the Lizard Head Wilderness Area and would be adequately protected by either
wilderness designation, the management proposed under the plan that natural
processes would be allowed to dominate, or the CWCB instream flows that exist
for this stream and tributary.
Draft Plan, Appendix D, p. D -28. (Emphasis added.)
The Los Pinos River and the tributaries were previously studied and
recommended for Wild and Scenic River designation. The ORV determined in
the 1979 study was scenery. Its inclusion in the Weminuche Wilderness has
maintained those values.
Draft Plan, Appendix D, p. D -81. (Emphasis added)
C. ORVs May be Protected Without a Federal Reserved Water Right: