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1891 occur in years when John Martin Reservoir would spill and, therefore, would not reduce the usable water available to downstream users. Further, these deple- tions during John Martin spills were included in annual averages; therefor~, the annual average usable enhancement was somewhat larger than the 300 acre-feet per year shown, under historic operation. Both the State of. Kansas and the Arkansas River Compact Administration based thei rapprova 1 of the Tri n i dad Project on the 1961 and 1964 Studi es and the 1964 Irrigation Report. In our opinion, it is rather late for Kansas to change their position and insist that the Trinidad Project be operated to prevent depletions on anannua 1 bas is, particu 1 ar ly cons i deri ng the total absence of evi dence that the Kansas water users will suffer a damage from project operations as con- templated in these reports and in House Document 325. It is our conclusion that eva 1 uat i on of project operati on and proposals for amendments to the Ope rat i ng Principle should continue to be based on the average annual impacts, provided that there is not a general trend of depletion to the inflow to John Martin Reservoir during dry years. The studies run on the operation during the 1979-84 review period do not provide a sound basis for assessing the future impacts that would be caused by transfer of water out of the Model Right and storage of winter water under the direct flow rights. These studies are also not useful for evaluating proposed amend- ments to the Operating Principles because the full project acreage was not i rri gated duri ng the revi ew period, these studi es are not representati ve of expected future conditions. Since the studies on the review period do not com- pare actual operat i on to a "without proj ect" cond i t i on, they cannot be used to determine what, if any, injury the Project may have on downstream water users. The studies run over the 1925-57 period do provide a sound basis for assessing future impacts and evaluating proposed amendments. Kansas has objected to the use of the 1925-57 studies for this review., Considering that the 1979-84 review period is not representive of future conditions and therefore not useful for .developing amendments to the Operating Principles and further considering ~he "...and the Principles amended as necessary" phrase in Kansas Condition 4, Kansas' objection seems unwarranted. The Kansas objecti on also confl i cts with the comment by Davi d L. Pope, Kansas Ch i ef Engi neer and Di rector of Di vi s i on of Water Resources, made in the 'first paragraph on page 6 of his February 28, 1986 letter to Raymond H. Willms that "an appropriate analysis would be to apply the actual operating practices, as documented above, to the 1925-1957 study peri od and compare the resu lts of thi sana lys is to the ori gi na 1 ope rat i on studies." The array of studies run on the 1925-57 period show the impacts of the practices of transferring water out of the Model Right and storing winter water under the direct flow rights. The studies also show the impacts of various levels of over irrigation, project operation with a 39,000 acre- foot joint-use pool (instead of the 19,500 acre-foot pool used in the 1961-64 studies) and several levels of bypass to Ninemile and Highland. The studies show the impacts of individual practices and conditions and various combinations of practices and conditions. A description of the various studies was displayed earlier in this section on pages 17 through 20, and the results are shown in Table 5 and Table 6. Tables 5 studied, and the 6 show that under most of the inflow to John Martin Reservoir is practices and conditions larger than that which 28