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April 11, 2008 <br />Page 27 <br />See also Appendix "D" at p. D -43 re Animas River. (The Draft Plan must clarify why it is <br />significant that whitewater rafting occurs above 9,300 feet in elevation.) <br />Vallecito Creek is popular with extreme kayakers due to its difficulty (Class V +) <br />and the sheer - walled granite canyon, which provides extremely narrow slots. It is <br />recommended for expert kayakers only. It has crystal -clear water flowing through <br />an incredible gorge with some of the highest - quality drops to be found. It is also <br />nationally significant for whitewater recreation. Its listing on American <br />Whitewater's national river inventory, while not sufficient by itself to be an ORV, <br />supports the ... analysis. <br />Vallecito Creek, Draft Plan, Appendix D at p. D -85. <br />It would appear from the number of such statements that neither Riversearch.com nor American <br />Whitewater is very selective in its listings. Given the number of streams for which the ORV is <br />recreation based on some type of rafting or boating, the Final Plan must clearly describe how <br />such activity is remarkable on a regional or national scale. The Draft Plan needs to explain how <br />these organizations rate rivers and why their ratings are trustworthy. Ratings by such groups, if <br />of any value, are useful only as a start for the SJPLC's ORV research. SJJPLC needs to have <br />prepared its own study of rating values to determine whether, within an appropriate Area of <br />Consideration, a stream meets the standard for ORVs. A number of ratings appear to be self <br />serving to the boating community. <br />Further, recreational rafting should not be considered as an ORV on the Dolores River below <br />McPhee Reservoir and on other stream segments unless there are explicit assurances that <br />Colorado water rights will in no way be usurped to support rafting without a decreed <br />Recreational In- Channel Diversion water right To alleviate concerns about rafting on WSR <br />eligible segments, the Final Plan should focus on other ORVs that support the rafting experience, <br />rather than using recreational rafting as an ORV in and of itself. <br />M. Prior Designation as Suitable not Necessarily Persuasive. Just because a stream <br />segment was previously designated as suitable is not in and of itself a basis for a current <br />suitability designation of a stream. In the time since the prior designation, land uses have <br />changed considerably and water conflicts have increased. See Dolores River McPhee Reservoir <br />to Bedrock, Appendix D, p. 19. The prior suitability designation was made before McPhee Dam <br />was constructed. <br />N. Work of BB1177 Roundtable. The work of the Southwest Basin Roundtable to <br />date has not been to consider prioritizing water projects. Therefore, all references to such <br />Roundtable decision - making should be modified to reflect that if the HB 1177 Roundtable does <br />prioritize projects that Final Draft may be amended via a single process to reflect such situations. <br />(See, for example, Draft Plan, Appendix D, at p. D -12, last sentence, 13.) Further, BB 1177 <br />