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<br />BALcollm.&: GnE:", p.e. <br />ATTO&.'IJ!lYS -iT LAW <br /> <br />e <br /> <br /> <br />Dan Merriman and Mark Uppendahl <br />Telluride and MVMD Concerns for ISF Priorities <br /> <br />June 7, 2001 <br />Page 2 <br /> <br />, <br /> <br />segments is to provide fishery habitat. Telluride ~d the MVMD believe that appropriation <br />of additional instream flows in these segments is inadvisable for several reasons. <br /> <br />A. Insufficient Data <br /> <br />First, the data for the San Miguel's ba$eline flow is insufficient to analyze the <br />feasibility of additional instream appropriations. As you know, the Town of Telluride is <br />currently pursuing a change application in case ~umber 96CW313, Discovery in this matter <br />has uncovered possible irregularities in records ?I f v water releases from Blue Lake Reservoir <br />into the San Miguel. The extent of these irtegufarities is still unknown and it is CUITently <br />impossible to quantify the amount of water that has historically been released from Blue <br />Lake Reservoir into the San Miguel. As aresmt, i~ is simply impossible to determine the San <br />Miguel's baseline flow at this time. It is likewise impossible to protect ti:le existing rights of <br />other users in the river without this information. :Therefore, the CWCB should abstain from e <br />proposing appropriations in the San Miguel unlil this uncertainty is resolved. <br />, <br /> <br />In addition, even absent flow record mregularities, the outcome in case number <br />96CW313 willlike1y cause significant changes! in the San Miguel's flow regime. Any <br />appropriation of instream. flows for this segment should be made with an accurate <br />understanding of the impacts that will result from the resolution of 96CW313. <br /> <br />B. No Benefits Will Result from Addi~onal Instream Appropriations <br />, <br />Second, additional instream. flows in ~e San Miguel will not m.eet the CWCB's <br />stated purpose of improving fishery habitat. lAB you recall, Telluride and the MVMD . <br />commissioned Wright Water Engineers to co~duct a biological assessment of the San <br />Miguel near Telluride. The assessment. wing 'modeling techniques consistent with the <br />CWCB's R2CROSS methodology, was conduct~d in 1998. A copy of the report containing <br />the assessment results was provided to the CWp3 in May, 1999. <br />, <br />I <br />The assessment revealed that fishery ha*tat in the San Miguel between Mahoney <br />Street and Society Turn is limited by many factors other than flow. Without going into <br />. detail, the report noted that: there is insufficien~ fish habitat within the river; the channel <br />substrate is small and thus not supportive of b~thic organisms necessary to support fish <br />populations; there is very little. if any, shade.providing vegetation along the channel; _ <br />unstable chaIU'\el banks and mining tailings exist along and within the channel, causing . <br />increased sedimentation which impacts fisll anlji benthic organism habitat; dissolved zinc <br />