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<br />2. Identification of recommendations at issue: <br /> <br />Recommendations presented by staff and adopted by the Board at the <br />January 2002 Board meeting, for the Big Blue Creek ISF on the Gunnison <br />River, as shown on the attached Exhibit A. <br /> <br />3. Brief and plain statement of the reasons Trout Unlimited seeks Party status: <br /> <br />TU emphasizes that it supports the CWCB's efforts to secure adequate in-stream <br />flows in this case. TU submits this Application for Party Status in order to ensure <br />its participation in any and all negotiations concerning the quantification ofthe in- <br />stream flows at issue herein, and to ensure its ability to submit, for ~he record, <br />technical evidence, technical Witnesses or file legal memoranda. <br /> <br />4. Contested facts, the matters which Trout Unlimited claims should be decided, and <br />a general description of data Trout Unlimited intends to present to the Board: <br /> <br />a. TU will rely on CWCB staff and Bureau of Land Management ("BLM") <br />reports and memos about the subject recommendations, all attachments <br />and appendices to the aforementioned documents, infoffilation in TU's <br />possession and available from TU's contractor, and any other public <br />information, such as USGS stream gage records. <br /> <br />b. TU identifies the following contested facts and issues: <br /> <br />Whether or not the CWCB staff recommendation of 11.3 cfs (May <br />1- October 31) and 10.4 cfs (November 1 - April 30) is sufficient <br />to preserve the environment of Big Blue Creek to areasonable_ <br />degree. <br /> <br />Whether or not the recommendation of the BLM for 11.3 cfs (May <br />1- October 31) and 10.4 cfs (November 1- April 30) is sufficient <br />to preserve the environment of Big Blue Creek to a reasonable <br />degree. <br /> <br />Whether or not water is physically available to support <br />appropriations in the amounts and time periods recommended by <br />the CWCB staff and/or the BLM. <br /> <br />Whether or not appropriations in the amounts and time periods <br />recommended by the CWCB staff and/or the BLM would cause <br />Injury to the water rights of others. <br /> <br />c. TU reserves the right to identify additional contested facts and issues, and <br />additional data and documents upon which it may rely as new information <br />becomes available. <br /> <br />2 <br /> <br />I <br />