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Mr. Russ Zigler and South Platte Task Force 28 June 2007 via e-mail to Mr. Zigler -- For public comment to the Task Force 29 June 2007 Meeting Dear Ladies and Gentlemen: With thanks for your service on this Task Force, I am writing because the briefing document posted on internet suggests that important potential responses to the South Platte problems may not be considered. The Statewide Water Supply Initiative groups and others ha ve moved steadily toward identifying and improving the conditions in which water markets function well. There is substantial scholarship and increasing numbers of new transfers and markets (e.g., a dozen st ates are described in a 2004 report by Clifford et al. for Washington Department of Ecology; <http://www.ecy.wa.gov/biblio/041 1011>). In Colorado, substantial efforts are underway to organize a rotational fallow program, as discussed by Peter Nichols Esq. at the January 2007 Colorado Water Congress. Leading Colorado water economists whose work has been influential world-wide in water management have contributed to marketing literature, including Professor Robert Young, retired from Colorado State, Professor Ari Michelsen, formerly Colorado State and still active, and Professor Charles Howe, Emeritus but still active at U. of Colorado. In essence, the economic logic and desirability of better water transfer mechanisms are clearly shown. Among the compelling reasons for taking these alternative forms of transfer seriously are the potential for dramatically reduced social impacts and damage to rural communities, and the increased support for maintenance of long-term agricultural productivity and capacity. Included in those benefits, functioning water markets would also enable easier and smoother transitions and re-allocations among agricultural users as well as from agriculture to other uses. Howe and Goemans (Journal of the American Water Resources Association, 2003) found that farm-to- farm water transfers in the Northern Dist rict were almost 1/4 of the water transferred by volume in the study period, but such transfers are limited to "C-BT" water. Therefore, I am writing to urge addition of the alternative forms of water transfer to your list of issues to be considered. One clear need that em erged in the SWSI Technical Roundtable discussions was lack of adequate information about water markets, both as potential institutions and about the markets that do exist in Colorado – all markets function best with adequate information. And an important gap in understanding is careful city costing of the alternatives, which involve different financial techni ques (e.g., no bonding for water acquisition) and changed obligations (e.g., no revegetation and long-term management obligation, but need for development of new contracts and education of all parties). The Task Force could ma ke an additional contribution by seeking full costing to further assess the alternatives. And, the Task Force may be uniquely suited to soliciting expressions of interest on the part of those who are affected indirectly by the South Platte problems – those who benefit from some conditions may be willing to contribute to their maintenance. The concern with "mitigation" is real and could be partly expressed in markets. With fully functioning markets, and application of the technology already available and some additional investment in identification of presumptive factors for transferable fra ctions of the existing water rights, the increased flexibility would allow willing sellers and willing buyers to reallocate water at much lower costs, and temporarily to meet situational needs. Meanwhile, with recognition of climate change added to the scarcity identified by the SWSI study itself, competition for water is surely greater than ever. Water tr ansfers are not public knowledge until a filing is made in Water Court; we do not know what is happening. But, we do know there is enormous pressure for institutional reform. We use private property and markets, so we should use well-functioning markets. Sincerely, John D. Wiener (Writing solely as an individual) <John.Wiener@Colorado.edu> following: "one-pagers" on alternative forms of wate r transfer and institutional design and "permanence".