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<br />To implement the various studies and <br />recommendations, the Colorado General Assembly <br />authorized the Director of Natural Resources <br />to prepare a comprehensive recodification of <br />the state's water laws, although not necessar- <br />ily in accordance with the recommendations <br />made by this Board.. <br /> <br />I <br /> <br />In our review of the proposed legisla- <br />tion we find that there are many concepts with <br />which we are in agreement. The legislature <br />has directed the preparation of legislation <br />to 'provide for integrated administration of <br />all diversions and uses of waters within the <br />state, protect all vested water rights, and <br />permit full utilization of ground waters in <br />the state'. The task of carrying out this <br />directive is incredibly complex and difficult. <br />Since the staff of this Board has not been <br />able to come up with a satisfactory solution, <br />we believe that the proposed legislation is <br />the best that has been offered to date. We <br />reluctantly conclude, however, that the pro- <br />posed legislation is deficient in two major <br />areas as follows: <br /> <br />1. It dOes not provide sufficient detail <br />or legislative policy for the integrated <br />adjudication and administration of surface <br />and ground water rights. <br /> <br />2. It fails to recognize the accumu- <br />lated problem in the South Platte and Arkansas <br />Valleys. It is our opinion that the division <br />engineers who, by the proposed legislation, <br />are given the primary responsibility for <br />accomplishing the necessary changes, will be <br />unable to accomplish any effective integra- <br />tion of ground and surface waters in these <br />areas (the South Platte and the Arkansas) on <br />the piecemeal basis as contemplated by the <br />proposed legislation. We believe that a <br />special adjudication board must be estab- <br />lished for both the South Platte and the <br />Arkansas valleys to accomplish the integra- <br />tion and adjudication of wells with surface <br /> <br />I <br />