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-.,x <br />1'a~e 2 <br />~~~ <br />provided for the costs of a project attributable to traditional water supply, tlhe financing <br />mechanism should be a reimbursable loan under a separate, existing CWCB program. <br />Regardless of what non-traditional value of statewide concern the CWCB is financuig, <br />there should be a requirement that all projects that receive financing under Policy 1 E. have <br />a demonstrable benefit for the environment and that such benefit outweighs any adverse <br />environmental, social or economic impacts of the project. Further, Policy 18 should. <br />require mitigation for any adverse environmental, social or economic impacts of projects, <br />if not measures beyond mere mitigation, such as active restoration of an environmental <br />value or interest. <br />• If the local proponent of the water development is a municipal water provider, there <br />should be a requirement that the provider has achieved a predetermined per capita water <br />usage target. The per capita target, which might vary depending on the character or <br />location of the population being served, would be intended to assure that the provider has <br />achieved conservation goals and is using water efficiently. <br />• Before providing financing for a project under Policy 18, the CWCB should require that <br />the local pxoponent examine the feasibility ofrehabilitating or expanding Amy existing <br />water supply projects. If rehabilitation or expansion of an existing project is feasible, <br />Policy 18 dollars should only be available to the new project if it has less f;nvironm~ental, <br />social or economic impact than rehabilitating or expanding the existing project. <br />In addition to these conditions on the CWCB's expenditures of Policy 18 dollars, there <br />should be a dollar figure limitation on the amount of funds available under Policy 18 each ;year. <br />Currently, the policy provides that the CWCB could set aside 20% of annual Sevf:rance Tax <br />Perpetual Base Account ("STPBA") revenues for Policy 18 expenditures. For Fri' 2007-08, <br />projected STPBA revenues are approximately $80 million. Our concern is not so much that $16 <br />million annually is excessive for Policy 18, but rather that this figure could increase dramatically <br />as STPBA revenues rise. Therefore, we would suggest an annual limitation on Policy 18 <br />expenditures of $16 million. If the program proves to be successful, we could be supportive of <br />increasing this (imitation in the future. <br />Finally, we suggest that financing under the policy should not be limited to traditional, <br />structural water supply methods. Rather, the policy should provide financing to, and <br />affirmatively promote, other methods of addressing water demands, such as interruptible supply <br />agreements, dry year leases, joint operating agreements and the like. These nonstructural tools, <br />which could be used independently or in combination with a structural project, tend to meE;t <br />water demand with fewer financial costs and adverse environmental, social and economic <br />impacts. <br />The undersigned wish to highlight that we view Policy 18 as an exciting opportunity to <br />finance and promote projects with broad, diverse values and with multiple beneficiaries. 7:'he <br />existing draft of the policy, however, does not accomplish this goal. We look forward to <br />working with you to craft a policy that will truly benefit all of Colorado. <br />