ALP 4

P
Animas -La Plata Operation, Maintenance and Replacement
Association
Comments of Animas -La Plata Operation, Maintenance and Replacement Association on
the State Engineer's Draft Protocol for Administration of the ALP Project
The Animas -La Plata Operation, Maintenance and Replacement Association (the "Association ")
has reviewed the State Engineer's Draft Protocol for Administration of the ALP Project ( "Draft
Protocol "). As we have stated previously, we appreciate the thoroughness and thoughtfulness of
the Draft Protocol and are generally pleased with the overall scheme. We do, however, have a
few comments, outlined below. Individual members of the Association may have additional
comments and concerns.
Organizational Clari ty: The Association suggests that the sections of the protocol be
reordered as follows:
Intro
I. ALP Decrees
A. 1966 Decree (current I)
B. Change Decree (current II)
C. Basin Creek Decree (new)
II. Tribe's Decrees (current IV)
III. Project Facilities (current III)
IV. Project Allocations (current V)
V. Water Administration
A. Definitions (new, discussed below)
B. Measuring Direct Flow Rights (current VII)
C. Measuring Storage Rights (current VIII)
D. Minimum Bypass (current IX)
E. Accounting for and Delivering Non - stored Allocations (current VI)
(1) General Limitations (this should be clear that non - stored
allocations are accounted against the direct flow rights, not storage
entitlements)
(2) Tribal allocations
(3) Navajo Nation and SJWC allocations
(4) Other Non - stored Allocations (e.g. Durango taken at DPP; La
Plata West, Lake Durango Water Authority and Durango taken
directly out of reservoir)
F. Reuse