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Basin Project's production continues to decline. Accordingly, the Association continues to be concerned that the burdens and benefits of Compact administration be fairly allocated between the Rio Grande and the Conejos River. On the interstate Compact issues, the Association is very concerned about the changes in type and time of use of water under the Rio Grande Project in southern New Mexico and northwestern Texas. Change in the time or quantity of water used under the Rio Grande Project can have a substantial effect on the benefits secured to Colorado under the Rio Grande Compact, and in turn, on the amount of curtailment suffered by the Association's members. Accordingly, the Association continues to speak out about the proposed changes in operation of the Rio Grande Project and the damaging effect of those proposed changes on its members. The Association is also concerned about the proper interpretation of the Rio Grande Compact. The Association believes that the Compact's restrictions on storage in post-Compact reservoirs do not apply to the re-regulation ofpre-Compact water rights stored in apost-Compact reservoir such as Platero Reservoir on the Conejos River. Likewise, the Association believes that Colorado is only required to secure its Compact debt in excess of 100,000 acre-feet in post-Compact reservoirs, and that the original 100,000 acre-feet of allowable debt need not be secured by post- Compact storage. Finally, the Association is concerned that the modeling for the RGDSS not include assumptions about the operation of the Rio Grande Compact are adverse to the Rio Grande or the State of Colorado as a whole. Instead, any modeling done for the RGDSS, beyond recognition of the separate delivery obligations of the Rio Grande and Conejos River, should limit the number of assumptions that it makes about Compact requirements to the bare minimum. Surface Water Administration The Association's concerns regarding surface water administration are simply to ensure that the maximum amount of water is distributed in priority on a daily basis consistent with the Rio Grande's obligations under the Compact and the decree in Case No. 91 CW29, Application of Tres Rios Ranches (described below). This is a difficult task given the frequent fluctuations in the stream flow. The Association, however, has and will continue to work with the Division Engineer to refine the daily administration of water rights. The Association also believes that increased use of direct flow storage ofpre-Compact water rights in Santa Maria, Continental, and Rio Grande Reservoirs can help water users make more efficient use of their limited water supplies. While direct flow storage is a topic of some controversy, the Association believes that if properly implemented, it is a good water management tool. The Association is concerned that any RGDSS computer model of the surface water system of the Rio Grande be accurate, but that it not be used as a substitute for human judgment and experience in the administration of the Rio Grande. The wooden application of any model, no matter how sophisticated, will result in errors in administration and injury to water users. The Association also believes the RGDSS must acknowledge the limitations on new appropriations contained in the decree in Case No. 91CW29, Application of Tres Rios Ranches. That decree prevents diversions by new appropriations tributary to the Rio Grande except when: (1) Elephant Butte Reservoir has spilled or, in the judgment of Colorado's Commissioner on the Rio Grande Compact Commission, is certain to spill and under Article VI of the Compact no credits and debits will be calculated for Colorado under the Compact for that year; or (2) Colorado has obtained or, in the judgment of Colorado's Commissioner on the Rio Grande C:Acdss\RGWUA3.doc Rio Grande Water Users Association Interview June 21, 1999 -Page 4 of 9