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AUG-15-2005 MON 04:32 PM FAX NO, P. 01 <br /> STATE OF COLORADO <br /> G�� <br /> Bill Owens, Governor <br /> DEPARTMENT OF NATURAL RESOURCES C7 \ q <br /> DIVISION OF WILDLIFE <br /> AN EQUAL OPPORTUNITY EMPLOYER 0" ~ <br /> 1OFD <br /> Bruce McCloskey,Director For wave <br /> - <br /> 6060 Broadway I•urPcu lc <br /> Denver,Colorado 80216 <br /> Telephone:(303)297-1192 <br /> 151 E. 16th St. <br /> Durango, CO 81301 <br /> 15 Aug 05 <br /> Ms. Kara Hellige <br /> US Army Corps of Engineers <br /> Durango Regulatory Office <br /> 278 Sawyer Dr., Unit 1 <br /> Durango,CO 81301 <br /> RE; Public Notice Number 200575106 -!''own of Pagosa Springs/San Juan River <br /> Ms. Hellige: <br /> The Colorado Division of Wildlife (CDOW) offers the following comments on the public notice referenced <br /> above. The proposed action entails constructing in-stream structures within the San Juan River through the <br /> Town of Pagosa Springs impacting 4000 linear feet of river. A portion of this work was completed in May <br /> 2005 and the applicant is seeking"after-the-fact"authorization. in 1994, aquatic habitat improvements were <br /> completed on a portion of the project area 1.5 miles upstream from the pedestrian footbridge. The river <br /> downstream of the pedestrian bridge was not included in the 1994 work and can be characterized as <br /> moderately degraded. Appropriately designed structural enhancement would improve this lower reach. <br /> It is important to note that the CDOW is supportive of the Town of Pagosa's desire to enhance aquatic habitat <br /> in the San Juan River. We also understand the Town's desire to meet multiple objectives including white- <br /> water boating. However, our comments correlate directly to our mission and focus specifically on impacts to <br /> the aquatic habitat. <br /> When appraising how the potential benefits of channel reconstruction offset potential impacts to aquatic <br /> resources we commonly evaluate the"purpose and need"of proposed actions. Impacts are also considered <br /> with the applicants' requirement to consider and use all reasonable and practical measures to avoid and <br /> minimize impacts. In light of these considerations,we believe the following components of the project fall <br /> short of meeting these standards. <br /> 1. Replacement of existing structures upstream of the pedestrian bridge. The CDOW fails to <br /> recognize a project need for replacing the 1994 habitat structures with new structures that essentially <br /> accomplish the same objective, at least in part. The public notice refers to these structures as"failed" <br /> or"partially failed"yet they appear stable and have met habitat objectives for 10 years. <br /> DEPARTMENT OF NATURAL RESOURCES,Russell George,Executive Director <br /> WILDLIFE COMMISSION,Jeffrey Crawford,Chair•Tom Burke,Vice Chair•Ken Torres, Secretary <br />