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 25
1. In evaluating current county primary economic bases as they may affect
conflicts with WSR suitability designations, the Draft assumes the same array of primary
economic bases for all streams within a county. This assumption is too simplistic. See, by way
of example, Hermosa Creek, Appendix "D ", at p. D- 73 -79.)
2. The Draft Plan lists funds coming into the counties from retirees as a
primary industry for a number of counties. (South Fork Mineral Creek, Draft Plan at p. D -68;
Retirees 39 %, Dolores River above McPhee, Draft Plan at p. D -13.) This makes little sense and
could lead to conflicts with WSR suitability designations, depending on where retirees are
constructing homes.
I. Suitability Designations will Affect Stream Management. The following
statement occurs in the Draft Plan in relationship to all stream segments:
Finding this stream suitable for Wild and Scenic will not dramatically change the
management in this area; therefore the costs associated with the management of
this river segment would not greatly increase.
Appendix "D" at p. D -27 (West Dolores) (See also Animas River, Appendix "D"
at P. D -47)
We do not believe this statement is true. Suitability status could greatly increase the time and
expense for water users in water court proceedings and in obtaining special use permits. Further,
with the increased attention focused on suitable segments and increased public presence there,
management efforts for the SJPL will need to increase. Public agencies are increasingly
spending more funds on law enforcement budgets. This would be the case as enhanced
designations attract more people to stream segments. WSR suitability designation will, in almost
all cases, bring increased pressure on the designated stream segment and, thus, the need for
increased management, with attendant increased costs.
J. Need for Better Definitions in Draft Plan.
1. The Draft Plan needs to define development limitations on private and
public land within recreational, scenic and wild stream segments. The Draft Plan at Appendix
"D ", p. D -6 states
Many of the stream corridors studied included some intermingled private lands.
Analyzing or managing a river for Wild and Scenic status does not give or imply
any government control over private lands. If Congress were to designate a
stream as a Wild and Scenic River, there would be no federally imposed
management restrictions on private land.
However, the SW District believes there will be numerous indirect effects. The Draft Plan must
evaluate these indirect effects, especially for unintended consequences.