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Ground Water Commission Meeting Minutes Page 12 <br /> May 16, 2025 <br /> Mr. Jones then described how the need for these proposed rule changes came <br /> about, noting examples where individuals objected to cases with seemingly <br /> little merit. Mr. Jones concluded his remarks by stating that he would feel more <br /> comfortable if item 13(C) simply required the objector to state their basis for <br /> objection. Mr. Jones is also concerned that objectors may assume their <br /> objection must be based on unreasonable impairment or waste as the form and <br /> rules are currently drafted. Mr. Jones also suggested that the draft rules allow <br /> objectors to submit their objections in formats other than the form required <br /> under item 13(A). <br /> Ms. Mele commented that she does not interpret item 13(C) as requiring <br /> objections to be made based on unreasonable impairment or waste only. Ms. <br /> Mele noted that the intent of the language in item 13(C) is to clarify that when <br /> an objector is making an objection based on unreasonable impairment, the <br /> objector must identify which well or other structure is being impacted and <br /> where that well or structure is located. <br /> Acting Chairman Noble commented that there has been a history of objectors <br /> in the Southern High Plains basin submitting blanket objections to applications <br /> without owning a well or other water right that could be impacted by the <br /> application. Acting Chairman Noble pointed out that the requirement in the <br /> draft rules to require objectors to state which structures owned by the <br /> objectors will be impaired by an application would assist with better <br /> understanding the claim. This requirement would also force an objector to <br /> consider the problem with claiming impairment but not actually owning a well <br /> or water rights that could be impacted by an application. Chairman Noble <br /> expressed that he believes the draft rule changes are intended strike a balance <br /> between not limiting the basis of objections for objectors, and helping the <br /> Hearing Officer and Commission quickly identify unfounded objections. <br /> Mr. Jones commented that he does not anticipate that the Hearing Officer <br /> would be dismissing a substantial number of cases submitted by pro-se <br /> objectors due to minor omissions or errors when filling out the proposed <br /> objection form. Mr. Jones also said that he expects the Hearing Officer to <br /> review objections from the standpoint of meeting the minimum standards <br /> outlined under the new rules, with an ability to request edits or clarification of <br /> the objections when the minimum standards are not met. <br /> Ms. Kosloff responded that she interprets the rules as not allowing the Hearing <br /> Officer and Commission to dismiss objections that aren't based on <br /> unreasonable impairment or waste. The objectors simply need to clearly state <br /> what their basis for objection is. <br /> Mr. Jones responded that he interprets item 13(C) as not limiting the basis of <br />