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cfs total appropriation from May 1 to dune 30 would still leave most of the snowmelt <br />runoff unappropriated and available for future water development. <br />BLM believes that the existing instream flow right of 3.5 cfs does provide reasonable <br />protection of the natural environment during the winter, According to the crass section <br />data collected by BLM, this flow rate allows the creek to meet two of three instream flow <br />criteria, the standard approach used by CWCB for setting winter flow rates. With its <br />extensive riparian community, Pauline Creek has pool habitat spread across the valley <br />floor. As long as flow in the creek is sufficient to ensure adequate water exchange <br />through these pools, overwintering fish will be protected. On the other hand, a decrease <br />in winter flow rate may result in a significant reduction in the number of pools that are <br />capable of overwintering fish. <br />For the reasons discussed above, BLM believes Pauline Creek is a good example of a <br />stream that is not well protected by a single year-round flow rate. BLM thus requests that <br />the Board give final approval to BLM's recommended enlargement of the instream flow <br />water right. <br />Sincerely, <br />1~lJ~Pir~.yu: l~. <br />Linda M. Anania <br />Deputy State Director <br />Resources and Fire <br />cc: Art Hayes, Gunnison FO <br />Kenny McDaniel, Gunnison FO <br />