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<br />01>.'''''-:- . <br />. . <br /> <br />~ <br /> <br />4) The mid-90's troul die-off in Beaver Creek in no way was lied to low water flows that an instream <br />flow would have prevented, Although the rcason for Ihe die-off is unknown all theories are <br />unrelated to waler flows and therefore instream flows would not further protect trout beyond what <br />the DOW and USFWS water rights already protect. <br />S) Protection for trout habitat exists under the existing State Wildlife Area. Instream flows do not <br />accomplish further protection of trout populations or habitat. <br /> <br />. <br /> <br />Little Cottonwood Creek above Freeman Reservoir: <br /> <br />I) Little Cottonwood Creek above Freeman Reservoir typically flows between April and June of each year <br />and dry the remainder. Discussions with CWCB staff indicate their desire to assign a seasonal adjudication <br />during wet periods. We do IIOl support adjudicating s.:ao;onal flows without data suggesting seasonal flows <br />will protect trout habitat in otherwise dry creeks, <br /> <br />2) The Blue.headed Sucker, Round-tailed Chub, and Flannel Mouth have survived for generations without <br />instream flows in Little Cottonwood Creek. No evidence exists that the hydrology, habitat, nor land use <br />characteristics of Little Cottonwood Creek above Freeman Reservoir will change. espt.'eially since it is <br />under US Forest Service management. <br /> <br />3) As waler becomes more precious and storage of that waler becomes increasingly important. it is <br />imperative that Ihe ability to expand Freeman Reservoir be maintained. An instream flow above Freeman <br />R~servoi!" pre\ler.!s possih!e expar.s!on of F!"ccrna!l Reservoir, which would likely ~!m~d2te greater than 50 <br />fOOl of the proposed instream flow. <br /> <br />Moffal County requests the eWeB nOI accept the proposals for instrcam flow adjudications on Beaver <br />Creek and Linle Cottonwood ereek for the above listed reasons. If the ewcs is unwilling to deny these <br />proposals, we request affected interests and water nght owners be given the opportunity to review the <br />proposals and accompanying data before a decision is made. To date. no data other than the limited maps <br />provided in the Candidate Streams for Inslream Flow Appropriations Division 6, has been made available. <br /> <br />. <br /> <br />Sincerely, <br /> <br />DllIT): Steele. Chainnan <br /> <br /> <br />Z~.-It& ~ <br /> <br />/p.- -!)() ~ dS <br /> <br />e <br />