CWCB Comments on the Draft Wild and Scenic Eligibility Report for the Bureau of Land Management Uncompahgre Planning Area

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-2- conducted its own field investigation and review, the CWCB recognizes the Draft Report is the result of a federal administrative inventory and evaluation that will undergo further impact analysis, consultation and coordination with interested stakeholders during the suitability phase. • The CWCB appreciates the Draft Report's commitment to collaborating with non - federal stakeholders during the suitability phase of Wild and Scenic River analysis for the Uncompahgre Planning Area and portions of the Dominguez - Escalante National Conservation Area. The CWCB has been and continues to be actively involved in a number of non - federal stakeholder groups coordinating with the BLM and US Forest Service as appropriate during the suitability analysis for stretches of the Upper and Lower Colorado River, the Dolores River, and the San Juan River basins. These stakeholder efforts are attempting to develop management plans to protect the values associated with the various segments, as identified by the federal agencies as being eligible for wild and scenic rivers designation, while allowing Colorado to fully use its entitlements under the Colorado River and Upper Colorado River Basin Compacts. Between 2007 and 2009, the CWCB was also able to provide resources and funds to explore reasonable and acceptable alternatives to wild and scenic designation by federal agencies. The CWCB looks forward to a similar collaboration, to the extent resources are available, during the suitability phase of the Wild and Scenic River investigation for the Uncompahgre Planning Area to further evaluate the eligibility classifications of the inventoried river segments and identify whether and to what extent there are plausible alternatives to designation of eligible segments as suitable. • The Draft Report notes that the San Juan Public Lands Draft Land Management Plan recognizes a segment of the upper Dolores River as eligible. It further provides that the northernmost 11.8 miles of this segment is within the UFO's jurisdiction and will be evaluated by the UFO during the suitability phase. The CWCB recommends the UFO coordinate with the San Juan Public Lands Center, the Dolores River Dialogue stakeholder group and Lower Dolores Plan Working Group when conducting the suitability analysis for the Dolores river segment within the UFO's jurisdiction. These entities have been working together for the past 24 months to identify potential methods for securing needed protections of the outstandingly remarkable values without limiting reasonable water development along the Dolores River segment between McPhee Dam and Bedrock, Colorado. The UFO should incorporate and build upon these past and ongoing consultations to develop consistent management strategies for the contiguous stretch of the Dolores River. • The Comments provided herein focus on the primary interests of the CWCB with regard to the Draft Report. Lack of additional comments should not be construed as agreement with or an admission of all factual and legal assertions made therein. Nor should silence on factual and legal characterizations in the Report be deemed a waiver of any of rights for the purposes of any future legal, administrative, or other proceeding. Flood Protection • Water Project Planning and Finance • Stream and Lake Protection Water Supply Protection • Conservation Planning