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Department staff time and fiscal resources are largely dedicated to ecosystem and smaller-scale area <br /> management planning. The Plan recommendations, and the possible mechanisms and timing of <br /> recovery implementation, should be addressed during this planning process. <br /> It is likely that the development of an orchid recovery program in the Boulder valley and vicinity <br /> will be a long-term endeavor. In the interim, the Open Space Department will continue to protect <br /> and manage orchid habitat on City of Boulder lands, and provide public education. <br /> Specific Comments <br /> 1. "Disjunct" populations or sub-populations and their treatment in the recovery process. <br /> There is consensus among the recovery team members who are familiar with S. diluvialis habitat in <br /> the Boulder Valley that the recovery planning and implementation process should apply equitably <br /> to orchid occurrences in wet meadow (non-riparian, termed "disjunct" in the Plan) and riparian <br /> habitats. Wet meadow and riparian orchid habitats in the Boulder area lie within the same <br /> tloodplain. and are related hydrologically. Even though seasonal irrigation, mowing, and/or grazing <br /> are common in wet meadow orchid habitat, these management treatments do not result in an <br /> ecological separation of orchid habitat types in the area. Conditions occurring in both wet meadow <br /> and riparian areas satisfy orchid habitat requirements, and contribute to the survival of the species. <br /> As plans for orchid recovery develop in the Boulder Valley, the various orchid habitat types, and the <br /> processes that create and maintain those habitat types will require equal attention. Therefore, the <br /> Interdisciplinary Teams defined in the Plan should evaluate all orchid habitat, propose Habitat <br /> Conservation Areas and Critical Contributing Areas by considering all components of watersheds <br /> that support S. diluvialis, and develop Management Objectives and Standards and Guidelines for <br /> Riparian/Aquatic/Wet meadow habitat. <br /> The statement on page 28 that"...disjunct populations will be protected and managed until such time <br /> as the species is recovered or the populations are no longer considered essential for orchid <br /> recovery.", suggests that the wet meadow, hayfield populations of S. diluvialis are expected to be <br /> less important than riparian populations for the long-term conservation of the species. There are <br /> several reasons to anticipate the need for long-term protection and management of wet meadow <br /> populations and the processes supporting them. These include: 1) Some of the largest known <br /> populations or sub-populations of S. diluvialis occur in wet meadow, "disjunct' habitat on land <br /> managed by City of Boulder Open Space Department. 2) Results from genetic studies by Anna Arft <br /> (doctoral student, University of Colorado, Boulder) of several orchid populations throughout the <br /> species' range indicate that each population is genetically unique and important for the conservation <br /> of the species. 3) Presently,most populations of the orchid are influenced and maintained by human <br /> manipulation of hydrologic processes. In the Colorado Front Range "natural' riparian or wet <br /> meadow habitats are lacking. Even with a watershed-level management approach, ongoing human <br /> activities such as flood control, water use, and recreation will continue to alter and replace natural <br /> disturbance and other processes. It is possible that the anthropogenically-maintained, wet meadow <br /> orchid habitat in Boulder Valley has the greatest potential for long-term sustainability because of the <br /> degree of control land managers have over this habitat type. An interdisciplinary watershed <br /> 2 <br />