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April 11, 2008 <br />Page 3 <br />capabilities of the land, protecting and preserving all of the ecological pieces, not <br />irreversibly impacting ecosystem resilience or ecosystem resistance to change, <br />and preserving the ability of ecosystems to meet the needs of future generations. <br />Draft Plan at p. 101 (emphasis added). <br />Although this emphasis on sustainability may not initially appear incompatible with <br />water development on the SJPL, by utilizing the concept of the Historical Range of Variation <br />( "HRV ") as the basis for formulating the "Desired Conditions" that support this " sustainability" <br />criterion, the Plan's standards and guidelines developed to advance these desired conditions <br />result in requirements that cannot be met by current and future water users. To elaborate, the <br />Draft Plan states: <br />[t]he Historical Range of Variation (HRV) is used as an important concept for <br />protecting species diversity and viability, sustaining ecosystems, and for <br />developing Plan components relative to SJPL ... The intent is to use HRV <br />conditions as reference points from which to help formulate attainable and <br />sustainable desired conditions to meet a range of land and resource management <br />objectives. <br />Draft Plan at 17 (emphasis added). Using HRV as a reference point in the Draft Plan could <br />exclude all human water diversions and uses occurring since the time of European settlement of <br />the area: <br />HRV describes the range of ecological conditions ... that existed within the <br />planning areas during the reference period (the period of indigenous settlement <br />lasting from approximately AD 1500 to the late 1800's ... European- American <br />settlers had not yet introduced the sweeping ecological changes (including... water <br />diversions [and]dams). <br />Draft Plan at 17 (Emphasis added). <br />The "Desired Conditions" and "Management Objectives," informed by the HRV's pre - settlement <br />vision for southwestern Colorado, include the following, among numerous others, which <br />establish standards that may preclude the authorization of new water projects and deny the re- <br />permitting of existing water developments: <br />Retaining "free- flowing" or "unregulated" streams in their "current <br />undeveloped condition because they provide "reference conditions" and <br />offer unique opportunities for recreation, species conservation and <br />pleasing aesthetics. <br />Draft Plan at 23. <br />