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002551 AMJ comments regarding 12-21-2004 proposed stipulation between Pueblo and CWCB Broad Policy Concerns . Colorado should be concerned about maintaining the integrity of the Water Acquisition Program. o The State must be able to rely on the Program to provide an alternative to federal bypass flows, reserved rights, endangered species issues, and other statewide issues. Using the Program as a "parking place" or "dumping ground" for abandoned or othelWise questionable water rights will diminish the integrity of the Program. o The Board adopted strict rules regarding procedures for accepting Water Acquisitions. Any proposed acquisition must follow those procedures. Accepting a donated water right as the basis for the Board's withdrawal from a water court case, without following the procedures outlined in the rules, could have the appearance of a sweetheart deal or bribe, and again diminish the integrity of the Program. . Accepting the donation of an interest in an RICO water right could put the CWCB in a difficult situation should there be a legislative or judicial reversion of RICOs. Would the CWCB find itself in the position of arguing IN SUPPORT of RICDs since it would be a partial owner? Detailed Concerns . Which rights would be conveyed and what are the reach lengths? . Is this a natural stream channel? . Is there a natural environment to be preserved? . Is there sufficient native flow available to meet the donated rights (from Ted's description, it sounded like there was a side deal with Colorado Springs to release water for the RICO from Pueblo Reservoir? Would CWCB be a beneficiary? If so, then why not convey an interest in that water right to the Board as well?) . How much water is required to preserve or improve the natural environment in this reach of the Arkansas? What if OOW finds that 100 cis exceeds the maximum amount of water required to preserve or improve the natural environment (Tom Sharp's concern with the Moser transaction)? How can we agree to accept the water right and settle the case if we don't know what the OOW will find? (Seems a little like "What you need is what I read!") . If there is a natural environment to preserve at night, why not also donate an interest in the RICO during the daytime as well? . Any proposed acquisition must comply with Board procedures for accepting a donation including the 120- day review and public comment period, and publiC hearing. . Designation of Pueblo as an agent of the Board for administration and enforcement may go too far in allowing Pueblo to place formal calls for administration. Although the Board has granted agent status to other entities.