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proposed area along with a letter stating that Open Space wants to see these lands <br /> registered. Formal designation is the final phase and requires the completion of a <br /> cooperative management agreement, called "Articles of Designation" between the <br /> landowner and the State, and approval by the Colorado Natural Areas Council, County <br /> Commissioners, and Colorado Parks Board. <br /> OS owns important Preble's habitat in the proposed South Boulder Creek Natural <br /> Area. This proposed South Boulder Creek Natural Area contains much of the occupied <br /> and potential Preble's habitat that has been identified so far in the Boulder Valley. In <br /> addition, the area also contains important Ute-ladies tresses orchid (a federally threatened <br /> species) habitat, as well as plains top minnow and Bobolink habitat, both species of <br /> concern. By bringing the proposed registry to the forefront OS can be proactive in <br /> supporting the State effort. Timing of developing the cooperative management plan <br /> conveniently coincides with the on-going development of the South Boulder Creek Area <br /> Management Plan. <br /> OS could proceed with the proposal for registry by submitting a letter requesting <br /> registry and submitting an up to date map of the proposed area. We believe that <br /> registration and subsequent designation would be actively supported by the DNR as it <br /> would be in support of the state led response to the proposed Preble's listing. <br /> It is our hope that by participating in the state effort and moving forward with South <br /> Boulder Creek Natural Area designation and development of a management plan for the <br /> area, OS can be sheltered from undue involvement of the Service into OS land <br /> management and operations. <br /> We will keep you informed as developments occur and circulate draft comments <br /> on the proposed rule once we develop them. <br />