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<br /> <br /> <br /> <br />Discussion : <br /> <br />This proposed program reflects and ambitious and well research ed effort to address agricultural water <br />transfer issues in the Arkansas Basin. The applicant and the program have clear ly spent significant resources <br />to outline a program that addresses their interests and needs. However, in designing/conceiving the program <br />they raise several difficult issues which ar e identified and described in the Issues/Additional Needs section. <br />Staff was not able to fully determine if Threshold Criteria b (consistency with Section 37 - 75 - 102 Colorado <br />Revised Statutes i.e., water rights protection) was met. <br />Staff acknowledges and c oncurs with some of the concerns raised in the letter from Mr. Terry Scanga. <br />Specifically, concern was expressed over using state funds to produce work products that may require other <br />water users to use private funds to analyze and/or refute the work prod ucts . Staff believes. The applicant <br />has done a reasonable job addressing this issue in Task D of the proposed scope of work. <br /> 6 <br />