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South Platte Task Force Comments 070628 <br />P. Andrew Jones <br />Lind, Lawrence & Ottenhoff, LLP <br />Windsor, CO <br />970-674-9888 <br />paj@llolaw.com <br />1. Understand the Watershed : fund a study <br />a. System wide analysis <br />b. Assemble, summarize existing studies, data. <br />c. Compare GW levels before wells and after wells <br />d. Compare surface water diversions before wells and after wells <br />e. Study recharge from large storm events <br />f. Study amount of well usage offset by reductions in GW level and <br />phreatophytes <br />g. TWO QUESTIONS <br />i. What is the real, physical impact of well pumping on surface <br />flows? (as opposed to the le gal impact, where injury is assumed ). <br />ii. What is the sustainable yield of the South Platte aquifer and its <br />various subparts? <br />2. Encourage Conjunctive Use <br />a. Alluvial aquifer is 8-10 million acre foot reservoir <br />i. Current system forbids drawdown, us e of the reservoir - requires <br />all users to keep reservoir perpetually full to overflowing <br />ii. Aquifer should be managed, used to maximize use - drawn on in <br />times of shortage, and repl enished in times of excess <br />b. Augmentation plans <br />i. Past pumping: clean slate - remove post pumping depletion burden <br />c. Groundwater diversions for surface rights <br />i. Subsidize <br />ii. Allow abbreviated application pr ocess- allow w/d of historal <br />diversions without need of water court application <br />d. Recharge/retiming <br />i. Funding for additional recharge s ites, retiming wells, pipelines, <br />reservoirs <br />e. Sustainable yield of watershed: allow all parties (including seniors) to <br />achieve via wells <br />3. Increase State Engineer Discretion <br />a. SE Discretion: river cannot run on autopilot <br />b. Winter administration: <br />i. No replacement of well depeletions <br />