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<br />. <br /> <br />. <br /> <br />. <br /> <br />. <br /> <br />p <br /> <br />that, for its next task, the subcommittee would develop proposed solutions to the <br />problems. This has not occurred. TU urges the Board to follow through with the <br />process it started, To the extent that the subcommittee did not identify the <br />enforcement issue described above, TU would further recommend that the <br />subcommittee add this issue to its list of priority problems needing solutions, <br /> <br />3. New Filings (Agenda Items 9 & 10) <br /> <br />· TU applauds this new round of filings, In particular, TU was pleased to see several <br />filings on behalf of the state Board of Parks, For some time, TU understands, there <br />has been a backlog of requests for appropriations from Parks, We urge the CWCB to <br />make these appropriations as expeditiously as possible, <br />. However, TU remains concerned about the overall downward trend in new <br />applications from the Board, <br />· In addition, TU believes that the Board needs to consider further bifurcation of its <br />filings to seek higher flows during the annual spring runoff, There are a few such <br />filings in this group (where the Board's application divides the year into three parts), <br />but TU believes that the Board should be seeking such filings on a routine basis, <br />. While the program has matured such that it is important for the Board also to focus <br />now on enforcing existing rights, continuing to identify new stream reaches for <br />appropriation is important to program overall. <br />· Recommendation: TU recommends that the next step for Board to take will be to <br />identify senior rights which may be available for donation or acquisition in instances <br />where its staff, or Division of Wildlife and Parks staff, identify critical reaches <br />needing protection, but where the reach does not have water available to make a new <br />appropriation meaningful. TU is willing to help the Board in this effort. <br /> <br />4. De Minimus Policy. (Agenda Item 12b) <br /> <br />. TU is concerned generally that the current policy is setting up practical and policy <br />problems that will burst onto the agenda in the not-too-distant future when critical <br />reaches where the Board holds instrearn flow decrees reach the 1% threshold, <br />. Recommendation: ISF Subcommittee should examine de minimus policy and craft <br />an action plan for how the Board should proceed when a new development reaches <br />the cumulative one percent limit, <br /> <br />5. Public Participation at Board Meetings <br /> <br />. The Board agenda states that the briefing materials for its meetings are on its web <br />site, However, after discussion with Board staff, it appears that these materials are <br />not available in advance ofa given meeting, This obviously makes it virtually <br />impossible for members of the public to determine whether they should comment on <br />a particular topic, without asking Board staff to mail out briefing information, <br />. TU would like to encourage the Board to use its web site to enhance public <br />participation, <br /> <br />'.:'- '-'," <br />