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 32 6. Dolores River Above McPhee Reservoir The segment of the Dolores River North of the Montezuma/Dolores County Line, which is bounded predominantly by National Forest land, has been designated as WSR eligible based on the combination of ORVs. The need for augmentation of future water supplies to support growth along the mainstem of the Dolores above the confluence with the West Fork presents a serious water development conflict with this designation. Water resource development in a Recreational WSR category may not accommodate potential growth. The conclusion that, "There are few conflicts north of the Montezuma/Dolores County line," is, therefore, incorrect. There are many potential conflicts with a WSR, including the facilities and water rights necessary to provide water to the Town of Rico. A WSR will have a major impact on Rico's ability to obtain, efficiently and cost effectively, the relatively small amount of water needed by the Town. Further, mining for numerous metals has occurred in the Rico Mining District since 1879 and there are numerous gravel pits. The Dolores River south of the Dolores/Montezuma County line is almost totally privately owned, "with the potential for conflicts of many kinds ", Appendix D at D -11, making it ineligible for WSR designation. Fishing in this segment qualifies as an ORV, despite mention in the Fisher's Guide to Colorado. Should the Dolores River above McPhee Reservoir be considered eligible in the Final Draft, it should continue to be found not suitable. 7. Dolores River: McPhee Dam to Bedrock To designate archeological /cultural resources as an ORV, the "Area of Consideration" must be the Colorado Plateau, which has 100,000 to 150,000 potentially eligible sites. Therefore, the sites in the mentioned stream segments do not rise to the exemplary level of an ORV, based on the criteria that: In order to be assessed as outstandingly remarkable, a river- related value must be a unique, rare, or exemplary feature that is significant at a comparative regional or national scale. A river - related value would be a conspicuous example of that value from among a number of similar examples that are themselves uncommon or extraordinary. Human habitation has always been concentrated along River corridors and other water sources to meet fundamental domestic and agricultural needs. Very strong Antiquities Laws and research programs are specifically designed to protect these resources much more effectively than a WSR eligibility or suitability designation. Further, the ORV of the Final Plan must recognize scenery in the segment is not flow dependent. DRD science has concluded that adding a small amount of base flow to the River is not the best way to use water resources to improve habitat.