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implementation of the proposed RICD Rules without such guidance, would exceed costs <br /> stemming from the proposed RICD Rules. For the same reason,the probable benefits of the <br /> proposed RICD Rules exceed the probable benefits of inaction. <br /> (V) A determination of whether there are less costly methods or less <br /> intrusive methods for achieving the purpose of the proposed rule <br /> The Staff does not believe that there are less costly or less intrusive methods for this <br /> process because an applicant's provision of information to the CWCB is voluntary. Further;the <br /> CWCB must follow the directive of SB 216 to hold a hearing on a RICD application if requested <br /> by any party. <br /> (VI)A description of any alternative methods for achieving the purpose of <br /> the proposed rule that were seriously considered by the agency and the <br /> reasons why they were rejected in favor to the proposed rule <br /> The CWCB considered requiring applicants to submit a significant amount of <br /> technical and legal information on proposed RICDs to assist the CWCB in making its <br /> findings and recommendations. In response to public comment, the CWCB revised the <br /> proposed RICD Rules to make submission of such information voluntary. <br /> Submitted this 2nd day of November 2000. <br /> KEN SALAZAR <br /> Attorney General <br /> /‘1'04 <br /> NDA J. BASSI, :* <br /> First Assistant A General <br /> Natural Resources and Environment Section <br /> Attorneys for Staff of Colorado Water Conservation <br /> Board <br /> 1525 Sherman Street, 5th Floor <br /> Denver, Colorado 80203 <br /> Telephone: (303) 866-5047 <br /> FAX: (303) 866-3558 <br /> *Counsel of Record <br /> 2 <br />