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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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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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12/16/2014 4:49:32 PM
Creation date
4/28/2014 5:25:45 PM
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Water Supply Protection
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
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April 11, 2008 <br />Page 35 <br />strides to improve water quality in the Animas River Basin, but the native mineralization of the <br />Silverton Caldera could overshadow the hoped -for water quality improvements. <br />d. The Town of Silverton municipal water intake is upstream of <br />Mineral Creek on a tributary. WSR suitability designation could have major impact on any <br />much needed changes or further development of the Town's water supply. <br />e. WSR designation will effectively prohibit future mining activity <br />within the WRS corridor and development of additional water resources for mining and other <br />activities. Because future mining plans will be subordinated to recreation and other ORVs, an <br />additional layer of regulation to that already existing will likely make mineral extraction <br />impractical. Because of the constraints of terrain, including avalanche activity, the most <br />practical sites for mine plant development would be within the WRS corridor, which would <br />likely be inconsistent with maintaining the WRS values. <br />WSR eligibility and suitability designation carries an implied undefined reserved <br />water right. Whether any additional diversions upstream or within WSR segment would be <br />allowed, even if very small, is unclear. This brings great uncertainty to future water <br />development potential. <br />The development of additional water resources will be required for future mineral <br />development. Special use permits will be needed for water facilities to cross or divert from <br />public lands. These special use permits will be subject to WSR river considerations, which could <br />preclude or severely limit future water development. <br />2. Animas River Bakers Bridge to Silverton <br />a. WSR Classification — Recreational. The SJC Plan calls for the <br />Animas River below Silverton to be for limited recreational use. <br />b. Land Ownership — The part of the stream from Silverton south to <br />Kendall Gulch, approximately 1.5 miles at the upper end of the reach, is over 50% privately <br />owned. The Draft Plan tables and classifications do not represent the effective land ownership in <br />the area near Silverton, especially since the right -of -way of the Durango and Silverton Railroad <br />(RR), which pre -dates the Forest, runs almost the entire length of the corridor and should be <br />considered private land in the Draft Plan. As long as the RR right of way is used for that <br />purpose, it functions as private land, regardless of any reversionary provisions. The Draft Plan <br />does not appear to recognize this land ownership. Such recognition could change the land <br />ownership pattern significantly. <br />C. Mineral Potential — There is significant mineral development <br />potential within the stream segment, especially the section from Kendall Creek to Silverton, but <br />also in other portions, as outlined in the Draft Plan. A suitability designation would conflict with <br />
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