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Comments for the April 11, 2002 Program Document <br />• Submitted by Rick Brown, Colorado Water Conservation Board <br />Section III.A.3.b.1. — The documents referenced by footnote 6 are inconsistent with <br />the text. The referenced documents are unclear in the use of the terms pulse and peak <br />flows, and they do not define species flows. This creates confusion and makes it <br />unclear what the program flow improvements are intended to accomplish. It is <br />recommended that an attachment be included in the program water plan that clarifies <br />these issues and the attachment be referenced here. To be consistent with program <br />objectives and target flow calculations, the attachment should include only the species <br />and annual pulse flows. <br />2. Section III.B.1.C. - The current language does not reflect the principle that the <br />Program's "effects" will not be imposed on non - program landowners. <br />3. Section III.C. Lb — Similar issue to the point raised in comment 1 above. The 1994 <br />information is dated and should be revised to reflect the current information from <br />Murphy, Randle, and Simons. Also note that the first reference is to May August <br />1994 and the second is to August. <br />4. Section III.D.l.d. - The change is still unclear. Perhaps adding the following to the <br />fifth line from the bottom would help "....the Program shall only pay or provide for <br />• the payment of real property taxes or an equivalent amount for land held by the land <br />ownership entity". <br />5. Section III.D.3.a and b. - This section should be rewritten so that it is clear what <br />lands are currently in the program/been acquired under section 7 or are linked to the <br />program via FERC license requirements. For example it is unclear what additional <br />lands are included from Project 1835 -013 and it is unclear how the provisions for <br />Project 1417 -001 Article 417 regarding 1200 acres below J -2 relate to the program or <br />how the provisions of Article 418 relate to the program. <br />6. Section IV. - The information in the last 5 sentences of the first paragraph appears to <br />create an inconsistency for ESA compliance for water related activities below Grand <br />Island. <br />• <br />