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(��.��I US ARMY CORPS OF ENtat n R <br /> t.__ RELEn ED <br /> AUG 15 2005 <br /> August 15,2005 DURANGO REGULATORY OFF 1L <br /> Comments: Public Notice No. 200575106 <br /> Whitewater park development in Pagosa Springs, CO <br /> To: Kara Hellige, USCOE <br /> Durango Regulatory Office <br /> Durango, CO <br /> From: David Wegner <br /> Ecosystem Management International,Inc. <br /> Durango, CO <br /> 1. General Comments <br /> • Rebuilding rivers for any specific purpose is never a good idea. Especially with <br /> concrete and grout. Hardening a river changes its geomorphic characteristics and <br /> can result in the flex and threshold points of the river changing or moving. <br /> Rivers form a shape and dynamics based on the watershed(geology, slope)and <br /> hydrologic characteristics that are unique to that area. Unless design takes into <br /> account the watershed dynamics it is likely that the desired results will not <br /> materialize. No discussion is presented that indicates the designer looked at these <br /> factors. This is particularly relevant when one begins placing structures into the <br /> stream. <br /> • In this particular example,the use of grout to"harden and smoothen"the San <br /> Juan River is neither appropriate nor necessary. It is the easy way to create a play <br /> feature in the river for kayakers rather than working with the natural dynamics of <br /> the San Juan River. What is the part being designed for—kayakers,rafters, <br /> fishermen, tubers? <br /> • There is reference in the public notice to the "failure"of previously installed fish <br /> habitat structures. No discussion exists as to if these structures failed from a <br /> recreation perspective or from a biological perspective. Fish habitat structures are <br /> designed for fish, not kayakers. Please define what is meant by"failure"and why <br /> this occurred. Perhaps there is a lot that could be learned from this experience <br /> and applied to the proposed project. <br /> • The project description purports to have a dual purpose of recreation and fish <br /> habitat yet no discussion occurs on the impacts of the proposed project to the fish <br /> habitat in the San Juan River(except as related to overwintering habitat). <br /> Specifically: <br /> o Movement corridors <br /> o Young fish cover habitat <br /> o Juvenile overwintering habitat <br /> o Macroinvertebrate(food base)production? (Bugs have a hard time getting <br /> to habitats that have been concreted). <br /> 1 <br />