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 31 The ORV for Coyote Wash is ecology, based on the Kachina daisy population "in horizontal crevices in seeps" Appendix D, p. D -38. This species is "the most imperiled of all plants in San Miguel and Montrose counties. Id. The two counties not an appropriate "Area of Consideration ". Recreation is also listed an ORV for Coyote Wash because of hiking in a "flat sandy bottom" with "vertical canyon walls ". Appendix D at p. D -38. Again, the ORV is not supported by an appropriate "Area of Consideration" since it is labeled as a hiking experience rarely depleted in southwest Colorado." Appendix D, p. D -38. Therefore, the hiking experience is not unique on a regional or national scale. The hiking experience in the Canyon is commonly duplicated in numerous places in the Colorado Plateau. Further, Coyote Wash is already protected as a WSA and "WSA status minimizes opportunities for future conflicts" Appendix D, p. D -40. The Final Plan must clearly explain why "Interim protection of wilderness values under WSA status does [not] provide significant levels of protection to Coyote Wash." Id. And should not designate Coyote Canyon as suitable. 5. Non -WSA Dolores River Tributaries: Summit and McIntyre Canyons. Although Summit Canyon is listed as one of three canyons in the SJPL with canyon tree frogs, which are ranked G5 and S2, their presence is not a value which is "unique, rare or exemplary at a comparative regional or national scale" so as to rise to a level of uniqueness or urgency of an ORV. Further, these ecological data may not be as current as DRD science, which the SJPLC must use as the basis for any WSR designation. The fact that water flow in McIntyre canyon may be ephemeral only in response to rain events. . precludes it from WSR eligibility designation. McIntyre Canyon, as admitted in the Draft Plan, Appendix D. at p. D -29, has a high potential for oil and gas development, and is also in the Slick Rock Uranium District with active uranium leasing. The Eastwoods' monkeyflower in the hanging garden of McIntyre Canyon is related to seeps, not the flow in the Canyon itself; the presence of the Kachina Daisy, in seeping alcoves, does not relate to any free flowing river segment. Although the Draft Plan, Appendix D, at p. D -32, describes its imperiled status, This status appears to be based on 20- year -old data, not recent DRD sources, and, further, no mention is made of any proposed federal or state endangered species listing. Therefore, neither Summit nor McIntyre Canyons should continue to be designated as eligible. If the Final Plan continues to designate Summit and McIntyre Canyons as eligible, neither Canyon should be designated as suitable for WSR status. Appendix D admits that other protection options could be appropriate for Summit Canyon. Appendix D, p. D -31. ( "It is reasonable that the potential effects of mineral development to the ORV could be awarded or managed." Id. Again, the Draft Plan fails to specify why other protection measures are not the most desirable for Summit Canyon. A mere connection with the Dolores River does not describe a sufficient reason for a suitability designation as opposed to, for example, an ACEC, which the Draft Plan admits could provide "sufficient protection ", Appendix D, p. D -3, but Appendix "U" does not discuss and ACEC for Summit Canyon. DRD alternative protective measures should lead to a Final Plan reopener and elimination of any final suitability designation.