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<br />=- - 2013 <br />CAZIER, 1~~IcGO~ti'A~T & ~tiTALKER <br />OF PROFESSIO\ ~L CORPOR~TIO\S <br />62495 L.S. HIGHN"aY 40 EAST <br />P.O. BOX 5(30 <br />GR~'~BY; COLORADO 80446 <br />ROD\~- R ~icGO~ti ~\, P.C. <br />TELEPHO'_~"E (970) 88i-3376 <br />Jol~ti D. ~c~R. P c. <br />FAX (970) 887-9430 <br />May 15, 2008 JOIE L. &aI~R, P.C. <br />OF COl \SEL <br />Ms. Jennifer L. Gimbel, Director <br />Colorado Water Conservation Board <br />1313 Sherman Street, Room 721 <br />Denver, Colorado 80203 <br />Re: Middle Park Water Conservancy District's Comments on Proposed Revisions to <br />"ISF Rules" -Rule 8e - De Minimis Rule <br />Dear Ms. Gimbel: <br />I just received on behalf of Middle Park Water Conservancy District a copy of the <br />proposed revision to the Rule. As far as Middle Park is concerned, I believe it is not a <br />clarification, it is an actual change to the Rule. The intent has always been to allow <br />these very minor applications. Rule 8f was intended to kick in after the one percent was <br />exceeded. <br />I believe that is how most people had read the Rule, including a number of <br />Division Engineers, and many other people. <br />Accordingly, if you want to clarify the Rule the appropriate clarification would be <br />to state that CWCB won't place a call when it is less than one percent of the flow. The <br />other approach would be to state that this "change" in the Rules would be applicable to <br />future applications. <br />SWC:cs <br />pc: Duane Scholl <br />• <br />