1997-06-13_REPORT - M1981302 (12)

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and has directed staff of the Colorado Water Conservation Board to conduct an instream flow assessment to help define the relationship between Preble's habitat and stream flow. Management Implications for Open Space Warm season grazing and over-grazing are identified as potential impacts on P P Preble's habitat. The terms "warm season grazing" and "over-grazing" are not defined by the Service, so it is likely that the OS grazing operation will be subjected to scrutiny and possible modification by the Service. Because the Service identifies a nexus between Preble's habitat and wetland environments, the OS irrigation program could also be affected. Similarly, the proposed rule specifically cites heavy use of recreational trails on OS lands as potentially destroying Preble's habitat as well as stating that "mowing or burning could adversely affect Preble's habitat" and therefore opens the OS Integrated Pest Management (IPM) and fire programs to review. Furthermore, the OS IPM program would likely be affected as the proposed rule states that the use "of pesticides and herbicides has undoubtedly increased across known Preble's range" and that these "chemicals could directly poison Preble's." Finally, OS can expect increased monitoring commitments both for OS projects and to help define the extent of Prebles on OS properties. In short, OS can expect various impacts to its resource conservation programs, agricultural operations, research activities, and recreational program. This would undoubtedly lead to a direct, although as yet undefined, fiscal impact through increased staff time and resources spent on Preble's monitoring, consultation, and administration, and management on OS properties. Potential City/OS Response Unless directed otherwise, we will continue to develop comments regarding the proposed rule and participate in the state effort. We will also assume the role of incorporating comments from other City Departments and will work with the City Attorneys Office or an outside council that the City Attorney's Office recommends to review the proposed comments prior to sending the comments. Protection and management of Preble's habitat on OS properties and support of the State effort could be furthered by moving forward with the proposed South Boulder Creek Natural Area. This designation is through the Colorado Natural Areas Program (CNAP) which is designed to protect special, rare, and threatened natural features in Colorado through a voluntary statewide system of designated natural areas. Natural Areas are protected through voluntary cooperative agreements between the state and landowners. At this time, various lands along South Boulder Creek have been "identified" as a potential natural area, the first phase of a three phase process to designate Natural Areas. The second phase is registration of the area, and would require submitting a map of the