comprehensive management plan and i asked prepare for them or study river illegal because decisions in conclusions in those documents are not based on or supported by data second the plan fails to address use capacity as required by the act guidelines third the river area boundaries for the alcatel segment of the river are based on development plans and river protection therefore i address these agencies three full years from the time a designation to complete management plans here after waiting twelve years to prepare a plan and only doing so after being ordered to do so by a court the p service is prepared to draft plan for the river and issue the drastic within only six months of acquiring the plan that short time frame does not allow the agency time to prepare and collect data that would be essential for preparing a plan that is protective of river values in fact the park service ignores its own experts and ice and that advice of its consultants that stated during the planning process that the lack of data hinder the delivery of the pipes and service to prepare play and they will be protective of river values everyone knew that they need to take more time and collect data there was one of the number one comments made by the quantity that will not only protect those river values but will enhance them that's one of the important requirements of the statute that values to be enhanced which may mean in some cases restoration but again m first instance which is why we need to establish what's the maximum quantity of use we can have consistent with all of our management actions to protect this river and resource and that's why birth is illegal looking at how that used to really impacted the river on the ground and you noted that the lack of data was one of the reasons why the plan was illegal in green the district court of oregon also noted that da but i do think it's possible for them to collect data in a timely manner and for there to be an injunction in place that protects the river in that interim period park may be undamaged so the park service concluded i think quite reasonably that the better approach is to look at the particular areas and determine what level of use is appropriate for this area based on what we know about sensitivity so that presently a campground that's next to the river and we see that there's some damage there we can is own that so that can't can't be in use is no longer appropriate and then we'll monitor it to make sure that that continues to be the case but it doesn't say that that must be done by immediately having standards indicators so here the park service addresses resource protection by having these management zones by having this river boundaries to not more than three hundred twenty acres per mile which is one quarter mile so it puts an upper bound on what the agency can include six choice of a boundary has to be rational i think in this case it was that she didn't choose the num they didn't say you know just the high watermark they said it's the wider of the in fact designing that evidence in the record shows that zoning was placed in different locations primarily to address the kinds of development that the park service wanted to do and the management stonings don't address quantities of  taken in the context of litigation to defend the plan and lastly the plan does not achieve the goals of the incentives act the decisions made in it are not rationally connected to evidence before the agency there's an absence