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 4 ii. Protecting the function and integrity of streams by "providing for adequate in- stream flows as part of new water - development planning as well as for existing water development operations." Id. iii. Sustaining the natural range of hydrologic flow patterns. Id. iv. Maintaining or enhancing aquatic habitat quality and quantity in order to provide for the long -term sustainability and viability of all native and/or desired non - native vertebrate species. Draft Plan at 25 (emphasis added). V. Requiring that all native and/or desired non - native fisheries thrive in the vast majority of systems historically capable of supporting such fisheries. Id. (Emphasis added). These prescriptions are to be applied across the SJPL regardless of whether a particular species currently exists within a stream segment. As applied to aquatic ecosystems, SJPLC could utilize sustainability criteria, based on the HRV concept, to "ratchet back" existing water developments to pre - settlement levels, arguing that water development projects, among other causes, have: reduced the quantity and/or quality of aquatic habitats, as a result the ability to support self- sustaining and functioning populations of fish and other aquatic biota has been reduced in a number of streams and rivers within the planning area. This is most evident in areas impacted by consumptive uses of water. The cumulative impact of hundreds of existing water developments have resulted in adverse and on -going impacts to the composition, structure and functioning of aquatic habitats. Where fish population monitoring has been conducted downstream of water developments, significant decreases in population densities have been observed.. More recently, fish population levels have been reduced by prolonged drought. This has reduced natural streamflow and resulted in increased demands for water for human consumptive uses. These increased demands have, in turn, resulted in numerous additional water development proposals. With continued drought and the increasing demand for consumptive uses, aquatic habitats and fish populations are likely to experience additional declines without aggressive, proactive management efforts. Draft Plan at p.24 (emphasis added). Further, the Draft Plan establishes as a program strategy and emphasis: