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r 5419CEIVED JAN2 61996 <br /> 999 III RFCEIVED <br /> JUN 13 1997 <br /> y�L <br /> j� CITY OF BMg9Mia16Vf0§PACE OPERATIONS <br /> 66 S. CHERRYVALE ROAD,BOULDER,CO 80303 <br /> (303)441-4142 FAX: (303) 499-6181 <br /> January 26, 1996 <br /> Field Supervisor <br /> U. S. Fish and Wildlife Service <br /> 145 E. 1'00 South, Suite 404 <br /> Salt Lake City, Utah 84115 <br /> Dear Field Supervisor, <br /> Enclosed are comments on the Public and Agency Review Draft of the Ute ladies'-tresses <br /> (Spiranthes diluvialis) Recovery Plan (the Plan) (Sept., 1995). Thank you for the opportunity to <br /> review the Plan. The City of Boulder Open Space Department (the Open Space Department) is <br /> charged with habitat protection and management for a significant portion of the total number of <br /> orchids known throughout the species' range. In order to conduct a thorough evaluation of the Plan, <br /> the Open Space Department has consulted with Ute ladies'-tresses recovery team members who are <br /> familiar with local, Colorado Front Range populations of the orchid. The resulting comments have <br /> been compiled by a recovery team member on the Open Space Department staff. <br /> General Comments <br /> The framework for watershed-level management recommended by the Plan is an excellent model <br /> for ecosystem management planning. As suggested in the Plan, the recovery implementation <br /> designed by interdisciplinary teams could benefit numerous native plant and animal species that <br /> depend on functioning natural processes in riparian and wet meadow systems. The concept of <br /> natural processes-oriented management of hydrologic, and biotic resources is compatible with recent <br /> planning efforts in ecosystem management in the Boulder Valley and vicinity. As landscape-level <br /> natural resource management is developed in our area, interdisciplinary watershed management can <br /> be addressed. <br /> It is difficult to predict the time frame in which the Plan recommendations could be initiated and <br /> implemented in the greater Boulder area. Existing interdisciplinary natural resource teams may or <br /> may not be the appropriate entities to take on the tasks of recovery implementation. It is clear that <br /> the organization and long-term direction of an interdisciplinary watershed management team will <br /> be labor-intensive, requiring a significant staff time commitment. Presently, Open Space <br />