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April 11, 2008 <br />Page 22 <br />2. River Protection Work roue ( "RPW ") Process: While the Draft <br />acknowledges the on -going RPW process (Appendix "D ", at p. D -9), initiated by the San Juan <br />Citizens Alliance and the SWCD, to identify the natural values for selected rivers, and new <br />means and alternatives for protecting these values, the Draft should describe a methodology <br />which would remove specific reaches of streams from suitability designation through a simple <br />Final Plan amendment if the RPW process generates alternative methods for protection upon <br />appropriate environmental compliance. <br />3. Dolores River Dialogue (DRD) Protection: The DRD is a science based, <br />collaborative community undertaking organized in 2004 to determine the most feasible and <br />efficient methods for protecting both the warm and cold water fisheries below McPhee Reservoir <br />while allowing water entitlements to continue to be used and developed. The DRD has spent <br />considerable time and resources in developing and testing hypotheses to evaluate the <br />environmental benefits which could result from management alternatives below McPhee Dam. <br />Management alternatives must protect the integrity of the Dolores Water Conservancy District's <br />obligations to irrigators, the downstream fishery, and the domestic users that all hold allocations <br />in the Dolores Project. The selection of ORVs on the Dolores River below McPhee Reservoir <br />does not appear to have utilized DRD science. In the Final Plan, DRD science must be used to <br />address Dolores River management below McPhee Reservoir. Although the DRD is mentioned <br />in Appendix "D" at p. D -20, an easy Final Plan amendment process needs to be identified when <br />appropriate ORV protection alternatives to WSR suitability designation result from the DRD <br />process, with the Plan's WSR suitability designation removed, not just supplemented. <br />E. Potential Negative Impact of Designation on Com etin Uses. The Draft Plan <br />has not adequately addressed all potential impacts to competing stream uses from suitability <br />designation including, but not limited to, development of water rights under the Colorado River <br />Compact, minerals /oil & gas development, and grazing uses, including conflicts for pending and <br />future water rights developments. Nearly all of the proposed WSR segments proposed as <br />suitable will have numerous conflicts with water resources development. The development of <br />new water rights under Colorado's Colorado River Compact entitlement may be impaired in <br />areas that are managed as suitable for WSR designation. The denial of special use permits and <br />the imposition of additional permit conditions will make development of new water extremely <br />difficult, if not impossible. <br />1. Incomplete discussion of potential conflicts in Appendix D. No mention <br />is made in the Draft Plan of major potential water conflicts, such as a Federal reserved water <br />right associated with a WSR designation and the impact within and upstream of the WSR <br />segment on existing and future water uses. This huge negative potential impact must be fully <br />addressed. <br />2. The Affect of suitability designation on water development. <br />a. A suitability designation requires additional SJPLC consideration <br />in the issuance of special use permits for ditch and headgate easements, maintenance and <br />