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Memorandum <br /> <br /> <br />To: Linda Bassi <br /> Colorado Water Conservation Board <br /> <br />From: Mark Pifher <br />Da te: September 15, 2008 <br />S ubject: ISF Rules <br /> <br /> <br />On May 30, 2008, the Front Range Water Council p rovided comments to you on the proposed <br />ISF Rules. I appreciate your considera tion and incorporation of many of those comments. <br /> <br />I would like to supplement those comments with the following observations on the current draft <br />of the rules dated September 8, 2008. Prior to making any specific comments, however, I would <br />th <br />note that the following provisions from the May 30 memo do not appear to be adequately <br />th <br />addressed in the September 8 draft: <br /> <br />Section C, subsections (iv), (vii), (vii i ) and (ix). <br /> <br /> <br />Section E, parts (i), (ii) and (iii). <br /> <br /> <br />Section F, part (ii), (iii) and (iv). <br /> <br /> <br />With spec ific reference to the September 8, 2008 draft, I provide the following supplemental <br />comments: <br /> <br />1. Proposed provision 6 . or loaned water <br />will improve the natural environment to a reasonable degree or will be used as a basis for <br />an increase is confusing. It <br />would seem that all ISF rights are based upon protecting or improving the natural <br />environment. What is meant by that clause? <br /> <br />2. Proposed Sectio n 6 . <br />or <br />confusing. Read in its entir ety, this paragraph references two choices , i.e. , purchase or <br />donatio <br />one. <br /> <br />3. Proposed paragraph 6 . calculate the amount of <br />compensa tion paid <br />? <br /> <br />4. Proposed section 6 . by the Board of the <br />historical consumptive us <br />certain items must be considered. However, a s noted in the preface to 6 . h, that future use <br />future use by an y of these entities be taken into consideration? <br />