Letter April 11 2008 Concerning Comments of the SOuthwester Water Conservation District in response to Notice of Availability of Draft San Juan Public Lands Land Management Plan and Draft Envrionmental Impact Statement

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April 11, 2008 Page 15 Statement 10.14. The Draft Plan must explain why, of the flows which support the habitat of black swifts are at the headwaters of a stream, a WSR designation is necessary to protect an entire stream reach. See discussion of black swifts regarding West Dolores River, Draft Plan, Appendix D, p. D -24. Statement 10.20. It is unclear whether the river otters for which habitat support is needed include only native populations or also stocked populations. It is unclear if this condition is related to the HRV concept. Draft Plan Volume 2, p. 46: Desired conditions - Species Status - Aquatic species. Statement 11.1. How the native fish populations that are to be supported by aquatic habitats are determined requires explanation, as does the relationship of this idea to the HRV concept. Statement 11.2. The population parameters required for sensitive species are viable must be defined. The meaning of the phrase "to be genetically diverse if there are only limited populations" requires clarification. The meaning of the term "genetically diverse" must be spelled out. Statement 11.3. Again, the terms "sustainability" and "viability" require clear definition, as does the use of the phrase "all native ... species" as it relates to the HRV conditions. Statement 11.4. This represents another place in the Draft Plan where all native species are to thrive in "the ecosystems historically capable of supporting these species" and still another example of the improper use of the HRV concept in the Draft Plan. Statement 11.5. An additional example of the improper use of the HRV concept. Statement 111. Another place in the Draft Plan where the terms "viable" and "desirable aquatic species" require definition. The reason Colorado pikeminnow and razor back fish are now endangered is that they were extirpated as undesirable to allow the stocking of game fish. Draft Plan, Volume 2, p. 48. Management Indicator Species ( "MIS ") Table 3.1: It is of grave concern to water users that certain species, whether all are native trout species, were selected to study effects to water quality due to water depletions associated with reservoirs, diversions and oil and gas development." This appears to be another major example of the misuse of the HRV concept. Draft Plan Volume 2,_p. 49.