BOARD00585

• Board Meeting Date: 11/23/1998
• Description: Federal "Clean Water Action Plan" and EPA's Advance Notice of Proposed Rule Making - Status Report
• Board Meetings - Doc Type: Memo

Power Act (where bypass flow requirements in FERC licenses is a practice oflong-
standing acceptance).

,Finally, Trout Unlimited questions the wisdom of the Board's apparent determination to
limiUhe Forest Service's authority to protect flows as against future development or in
the face of new biologic information, When new projects are proposed on National
Forests, new conditions or new information may result in different flow
recommendations for an affected stream. The ability to protect flows in those situations
should not be restricted by a poison pill provision. Among other problems, this could put
the Forest Service into a position where the only option'it has to protect Forest resources
is to reject a proposed project - rather than working with project proponents to modify
operations to address both water user and environmental needs.

Agenda Item 11: Anticipated 1999 Legislation

. Statewide Water Resource Planning, Many environmental and conservation
organizations, including Trout Unlimited have serious concerns about the version of
this bill that was under consideration in the 1998 legislative session, Trout Unlimited
urges the Board not to endorse any version of this bill for the 1999 session without
, hearing from all of its constituents.

. Water Conservation. Trout Unlimited strongly supported the original bill and offers
the Board assistance in ensuring its reauthorization in the coming session,

Agenda Item 20: CWCB comments re: EPA's ANPRM on Water Quality Standards

See separate handouts,

Agenda Item 21: Instream Flow Subcommittee Draft Report

Since the draft report was not available for public comment priorto the Board's meeting,
Trout Unlimited urges the Board to set aside some time on its agenda in January to
receive feedback on the report, particularly by those who participated with the
subcommittee, and to accept recommendations about the future direction and work plan
for the subcommittee,

Agenda Item 22: Instream Flow Appropriations & Work Plan Status Report

As discussed in part under Agenda Item 5, Trout Unlimited believes that the Board needs
to do more to prepare to receive donations of senior rights for instream flows. This is a
critical component of the Board's program, without which the only protection afforded
the environment is by fairly junior appropriations with little if any enforcement in the
field. Trout Unlimited therefore recommends that the Board add to the Instream Flow,
program work plan the items discussed above, Moreover, TU urges the Board to include
in its annual budget request sufficient funding to be able to receive donations as they
anse,

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