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 8 Draft Plan at p. 106. As described under Part 2, "Strategy ", cooperative and collaborative efforts are the preferred approach to sustaining aquatic ecosystems and ensuring that viable populations of aquatic species are maintained or improved on." Draft Plan at 252. These acknowledgements of the value of cooperative efforts, however, come with several "sticks ": "In the event collaborative efforts do not result in more workable and mutually acceptable solutions, the following [rules] apply." Draft Plan at p. 252. A.1. Management activities throughout the Unit should be consistent with the objectives of the Conservation Agreement and Strategy for Colorado River Cutthroat Trout in the States of Colorado, Utah, and Wyoming. For formally designated conservation populations of Colorado River cutthroat trout, 100% of existing habitat must be maintained. A.2. For all populations of vertebrate aquatic species other than Colorado River cutthroat trout: A.2.1. Streamflow in riffle habitats should beat levels that maintain minimum water depth, wetted perimeter, and mean velocity values consistent with those identified for each stream size category below: [Table included in Draft Plan]. A.2.2. Streamflow in each reach should be sufficient to maintain, for each life stage of each target species, a minimum of 50% of the Weighted Usable Area that would occur under natural flow conditions. A.2.3. Habitat quality, including large woody debris, residual pool depths, composition of habitat units (eg. pools, riffles), and overall habitat complexity, should be maintained or improved commensurate with reference stream conditions and in a manner that maintains viable, self - sustaining fish populations. The Final Plan must state the legal authority of the Forest Service to impose the conditions in Paragraph A.1, and must define the meaning of the statement "consistent with the objectives of the ... Agreement." The Agreement should be appended to the Final Plan. Overlapping A.2 "rules" in the Draft Plan, p. 252, describe inflexible habitat requirements in terms of riffle habitat, weighted usable area and habitat quality and complexity standards which appear to be driven by the HRV concept without regard to specific species viability requirements and water availability. Whether this strict guidance is to be the basis of collaborative efforts, or