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ub/1L/Luuo 10:37 FAX 3033126071 - EPA PAER [j001 <br /> • <br /> ".(141r4 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ` <br /> REGION 8 <br /> ry 999 <br /> 9 <br /> r� l t <br /> ;., 181.14 STREET-SUITE 300 <br /> DENVER, CO 80202-2466 O . <br /> "SFr rt�� , <br /> Phone 800-227 4917 <br /> http://www.epa.goviregion08 <br /> Ref: EPR-EP <br /> August 12, 2005 <br /> • <br /> Kara Hellige, Project Manager • <br /> US Army Corps of Engineers, Sacramento District <br /> Durango Regulatory Office <br /> 278 Sawyer Drive, Suite 1 <br /> . Durango, Colorado 81303 • <br /> • <br /> RE:. Public Notice No. 200575106 <br /> Town of Pagosa Springs <br /> • <br /> Dear Ms. Hellige: <br /> We have reviewed the referenced Public Notice regarding the after-the-fact application <br /> to place fill in the San Juan River in conjunction with a river enhancement project in Archuleta <br /> County, Colorado. The project includes bank stabilization, fish habitat structures, and instream <br /> recreational structures. <br /> We are concerned about the project's direct, indirect, and cumulative adverse impacts to <br /> the San Juan River in the Town of Pagosa Springs. It is our understanding that stream <br /> stabilization structures were already designed and in place within the river reach..The proposed <br /> project involves significant modification of the river reach and the application does not provide <br /> adequate information on the recreational purpose and need for the project. Furthermore; there is <br /> a lack of information that describes direct or indirect impacts to riparian vegetation (or wetland <br /> vegetation)resulting from the construction activities or changes in water elevations. The Public <br /> Notice should disclose any direct or indirect impacts to wetlands and not merely require; <br /> mitigation after-the-fact. <br /> • <br /> Accordingly, we recommend that the following concerns be addressed prior to permit <br /> issuance: <br /> 1) All riparian or wetland vegetation that will be directly or indirectly affected should be <br /> mapped and impacts described for those areas. <br /> 2) An alternatives analysis should be prepared documenting how the proposed impacts <br /> are the least damaging practicable alternative for the basic project purpose. • <br /> • <br />