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2 <br /> My comments contained in this report are requested by the US Army Corps of Engineers <br /> involved in assessing a review of the report: "A Comparative Study of a W weir and U drop in <br /> the San Juan River in Pagosa Springs, Colorado,"written by: G.Lacy, S. Shipley, M. Harvey <br /> and C. Mahaffey. All of the authors are affiliated with Recreation Engineering and Planning in <br /> Boulder, Colorado. <br /> The dominant feature of the Lacy et al. "study"is the apparent lack of documented data, <br /> subsequent analysis, or scientific credibility to back up the statements and conclusions presented. <br /> Misrepresentation of design criteria presented in their report indicates a lack of rigor in <br /> investigation of the authors in documenting factual information currently available in published <br /> literature and verifiable by many W-weir structures installed in rivers not only on the San Juan, <br /> but on other major rivers within the state. <br /> My comments will be based on specific statements or subject areas presented in the Lacy report: <br /> The report indicates that I am a stream biologist. Quite the contrary,I am a certified Professional <br /> Hydrologist(American Institute of Hydrology), with a Ph.D. in fluvial Geomorphology. I do <br /> work with fisheries biologists; however, I integrate river features into habitat requirements. <br /> The report indicates that the only purpose for W-weirs was to"enhance habitat,but many other <br /> functions have been overlooked." One of the items overlooked was the inability to pass <br /> recreational boats,making a"significant hazard to downstream navigability." I have personally <br /> paddled all of the structures in the San Juan River and had no difficulty with any of the structures <br /> including the W-weir. Many of the local paddlers started using the river the first year of <br /> construction and were very happy with the boating recreation improvements. I recently asked <br /> these avid paddlers if the W-weir constituted a safety hazard—all of which stated,"No!" If this <br /> question persists, I can provide documentation and quotes from various individuals that have <br /> paddled W-weirs for 10 years. The W-weirs have been in place for ten years, withstood floods <br /> of over 5,000 cfs and have required very little to no maintenance throughout the river project. I <br /> know of no accidents or"close calls"for a range of"boating flows" (flows between 30 percent <br /> of bankfull stage and higher water, including flood stage). The only"river rescue"needed was <br /> on the W-weir when, during a record drought, a young child was stranded on a rock with a tube. <br /> The rescuers walked across the river and lifted the small child off the rock in the center of the <br /> channel. At drought baseflow conditions, boating generally ceases except for inner tubes and <br /> blow-up mattresses. During such low flows, I have personally observed tourists and young <br /> children that"tubed"these W-weir structures for 10 years without incident. If the claims made <br /> by the authors that the W-weir is a"hazard to downstream navigation by all types of watercraft <br /> and users," then for a ten year period where thousands of boating days occurred(#of boats/day <br /> for the last 10 years), why was there no public warning from town officials? If, all of a sudden, <br /> there is this"perceived"great hazard,why are there not signs warning the boating public of such <br /> "serious hazards"? <br /> The photograph in the Pagosa Springs Sun in 1995 (Figure A), describes the structure(W-weir in <br /> photo) as a"recreational haven for residents and visitors. This week numerous rafters and tubers <br /> enjoyed the new rapids and eddies in front of the Chamber of Commerce...while fisherman <br /> pulled large trout from the pools around the rock formations." The project including the W-weir <br />