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roads. She said the use of HRV was rejected in planning rule efforts and asked how, <br />therefore, the Agencies could use HRV in the Draft Plan. The concept of HRV has a huge <br />effect on water development because before European settlers, all the water was in the <br />streams. Almost any water depletion, therefore, could affect HRV. <br />Steve agreed and said the concept could affect existing rights as well as new ones. He <br />asked whether this could be a tool used to demand bypass flows. <br />Thurman said he was not aware of the HRV concept being rejected, and asked the SWCD <br />to provide details about this in its comments letter to the SJPLC. He noted that the Draft <br />Plan states that the intent is not to manage a planning area according to HRV conditions <br />but to use HRV as a context. He said more detail may be needed from a terrestrial <br />standpoint, rather than an aquatic one. <br />Janice said it should be made clear that "valid existing rights" include conditional as well <br />as absolute water rights. <br />She also expressed concern about the analysis under "Aquatic Systems and Aquatic <br />Species" at p. 252 of Volume 2. When the CWCB uses the R -2 Cross habitat method, or <br />whatever method is used, there is a balancing act. It does not lead to just one answer, but <br />in the Plan there are absolutes. Some variables aren't being considered, such as water <br />availability. Some of the terms in the analyses appear to come from different <br />methodologies for measuring what conditions are needed for fish populations. It seems <br />the Draft Plan pulls from different methodologies. How the habitat requirements were <br />arrived at needs to be explained. <br />One page mentions "reference stream conditions" but there is no statement of what those <br />are. There is also a mention of viable "sustainable fish populations," but those are not <br />defined either. Neither is the term "desired non - native fish" defined. <br />Janice said some of the language looks more like standards than guidelines. <br />Chuck Wanner agreed that term definitions are important. He said since the Draft Plan is <br />written under the 1982 Rule there should be less use of "may" and more use of "should" <br />and "will." If things are more tightly defined, things are easier to understand. <br />Janice commented that the Dolores River Dialogue does not appear to be mentioned as <br />much as the RPW, and the DRD should receive more attention in the Plan. <br />From the audience, Mike Preston, General Manager of the Dolores Water Conservancy <br />District, said it should be noted that much of the concern about wilderness and WSR <br />designations involves the possibility of a federal reserved water right. It may be possible <br />to work with the congressional delegation to make sure a federal reserved water right is <br />not part of any such protection package. <br />on <br />