Wild and Scenic Management Plan Alternative Proposed

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This broad-based group of Stakeholders, including environmental groups,water users, recreational users, private landowners,and local governments, has worked together and in consultation with several divisions within the Colorado Department of Natural Resources since 2008 to develop the proposed Upper Colorado River Wild and Scenic Stakeholder Group Management Plan (SG Plan or Plan)to protect the outstandingly remarkable values(ORVs) identified in the BLM and USFS Eligibility Reports for Segments 4 through 7 of the Upper Colorado River. All references hereinafter to Segment 7 of the Colorado River are intended to include BLM Segment 7 and USFS Segments 1 and 2 of the Colorado River. The Plan has been endorsed by the members of the SG and the Colorado Water Conservation Board,and has been identified as the federal agencies' Preferred Alternative B2 in the DRMP/DEIS documents. The Stakeholder Group has invested substantial effort to date in the development of this collaborative SG Plan and believes it is the best approach for balancing permaner►tprotection of the ORVs,certainty for the stakeholders,water project yield,and flexibility for water users. We request that the federal agencies approve the proposed SG Plan as the means to address Wild and Scenic River value n the above-referenced segments of the Colorado River. The following three points are critical to the SG. We ask that BLM and USFS carefully consider them in proceeding with their land use planning process and developing their RMP/FEISdocuments and records of decision: 1. As BLM and USFS are aware,there exists a divide among members of the SG between those who believe Segments 4 through 7 maybe suitable or not suitable. The SG Plan was able to move forward based upon a fundamental principle that the Plan is contingent upon the agencies' "neutral"deferral of making any suitability determination for these segments for so long as the Plan is in effect(SG Plan Guiding Principles, p.9). We request that the BLM and USFS utilize an approach similar to the USFS process adopting the South Platte Protection Plan,where the basis and rationale for protective management of the ORVs is found in the current eligibility status. We specifically request that the agencies defer evaluation of the potential suitability of Segments 4 through 7 in the analysis for the Final Suitability Report, Final EIS,and records of decision,should the proposed SG Plan in Alternative B2 be approved. 2. A related and equally important principle of the SG Plan is that,should the SG Plan terminate, the BLM/USFS should proceed as expeditiously as possible with an evaluation of whether or not Segments 4 through 7 are suitable, providing an opportunity for and consideration of additional public comment at that time. It is our understanding that this process would likely involve issuance of arevised draft/final suitability report addressing the status of those segments. We request that BLM/USFS confirm this procedure in their respective decision documents. 3. The principles and elements of the SG Plan have been developed by means of a broad-based consensus process and are supported by the SG. Members of the SG view it contrary to the spirit of the Plan and this group's commitment to be united in supporting the Plan for individual stakeholders to comment now on aspects of the wild and scenic issues addressed under the SG Plan or on the merits of suitability/non-suitability for Segments 4 though 7 of the Upper Colorado River. For this reason,the SG collectively requests a subsequent 30-day opportunity for submission of comments on these issues for these four segments if the SG Plan in Alternative B2 is not selected. Page 2 of 4