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

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April 11, 2008 Page 30 We do not understand how the 4.7 miles of Navajo Lake trail and eight other trails leading out of the corridor are related to a WSR eligibility designation for the mainstem itself. (See Draft Plan, Appendix D, at p. D -27.) While the WSR eligibility recommendation for the West Dolores River might still be considered in the Wilderness portion of the West Dolores River above Burro Bridge, the Lizard Head Wilderness designation already affords a high level of protection without the need for an eligibility designation. Changes in private land ownership and development since the original WSR study and Congressional recommendation in the segment below Burro Bridge are grounds for reconsidering the appropriateness of an eligibility designation for this segment. The SWCD concerns with the Draft Plan's conclusion that the West Dolores River should not be designated as suitable. Little weight should be given to previous Study recommendation, especially given the fact that the USFS did not implement or concur with the Colorado Department of Natural Resources recommendation for a suitable Recreation River. 4. Dolores Tributaries in Wilderness Study Areas ( "WSA "): Bull Canyon and Coyote Wash While these tributary canyons may be stopping points for rafters on the lower Dolores River, such canyon use, in and of itself, does not rise to the level of an ORV, especially considering that these tributaries are already in a WSA and managed as Wilderness. Even the Draft Plan, Appendix D, at p. D -35, states that the upper portion of Bull Canyon could be excluded from eligibility status without compromising recreation opportunities. Therefore, it is unclear why this portion is included as eligible. Management for Wilderness values provides an existing, superior means of protecting any legitimate ORVs. WSA protections will safeguard the values of these tributaries and their recreational association with the mainstem of the lower Dolores River. See Draft Plan, Appendix D, p. D -37. ( "Much of the portion of Bull Canyon containing the recreation ORVs is within the Dolores River Canyon Wilderness Study Area ensuring protection of the recreation ORV ... ) Moving from WSA to Wilderness status may be more likely than moving from WSA to a WSR designation. For geologic ORVs, the "Area of Consideration" should be the entire Colorado Plateau. Bull Canyon and Coyote Wash are not "unique, rare or exemplary" at such a comparative regional scale. Pools on side streams are a common occurrence on the Colorado Plateau. Ecological information, which may be completely outdated, seems to indicate Protection Urgency Ranks of P3 to P4 and Management Urgency Ranks of M3 to M4 on a scale of 1 to 5 which can more than adequately be addressed by WSA status. Further, we doubt whether, compared to other recreation areas, Bull Canyon has "outstanding" recreation opportunities. Finally, in Bull Canyon there is extensive uranium leasing. Therefore, the SWCD concerns that in the Final Draft, Bull Canyon should not be designated as suitable. DRD current science must be used as the basis for any WSR designation for Coyote Wash.