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 28
Roundtables do not initially propose funding for a project, a project sponsor has to propose
funding.
O. Information from Colorado Departments and Divisions. It is unclear exactly what
information was provided by the Colorado Department of Natural Resources and its Divisions to
the SJPLC and whether all the information provided was used in the Draft Plan and how it was
relied on.
P. Release of Eligible Streams from WSR Management. The Governmental Water
Roundtable was informed that the designation of a limited number of streams as "Suitable" in the
Final Plan would release the remainder of the "Eligible" streams from WSR management
criteria. The Final Plan must either abandon Suitability designations or explicitly release all
other Eligible stream segments from such management criteria.
Q. The Final Plan must discuss how management guidance for any stream designated
as finally suitable will be developed. The Final Plan must detail the collaborative process, with
appropriate notice, for the development of stream habitat guidance for streams finally designated
as suitable.
II. Specific Comments Regarding the Appendix "D" WSR Analysis Re: Designation of
Individual Stream Segments as Eligible and/or Suitable.
A. Dolores River Basin
1. Introduction
Both the Dolores River Dialogue (DRD) and the SWCD have previously provided specific
comments on the preliminary Dolores River Basin eligibility analysis. A number of comments
on specific streams are repeated here as they were not recognized in the Draft Plan and are based
on the knowledge of individuals about streams in their area who are concerned about both water
development and stream protection.
2. Rio Lado
While the presence of Colorado River Cutthroat Trout (CRCT) in this very small stream may be
worthy of some protection, considering this population in the context of the Conservation
Agreement and Strategy for Colorado River Cutthroat Trout in the states of Colorado, Wyoming
and Utah," ( "Tri -State Agreement "), the appropriate "Area of Consideration" is an entire three
state area. In this Area of Consideration, the small Rio Lado CRCT population is not "unique,
rare or exemplary" at a comparative regional or national scale so as to rise to the level of an
ORV and, therefore, this stream should not be designated as eligible. Draft Plan, Appendix D, at
p. D -20, admits this, in stating: