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<br />JUL-lS-SS 10,12 FROM' COLO RIVER UJ~T~l~T <br /> <br />I D, S7I!JfFi 5B-l~~ <br /> <br />t"'A'--.c "~ <br /> <br />AL~XANDRA DAVIS <br />LINnA BASSI <br />ASSISTANT ATTORNEYS GENERAL <br />PAGE 2 <br /> <br />The CWCB's ISF hearings will "adjudicate" the existence of propcrty rights ofa s[1"cific <br />party, the CWCB, which will then eliminate or limit the opportunities 0 r others to appropriatc water. <br />The fact that the CWCB acts on behalf of the people of the State and considcrs "policy" isslICS docs <br />not change the fact that it will be adjudicating its own property rights. Any city councilor special <br />district board also acts pursuant to statute or charter on behalfof its citizens nnd must consider policy <br />issues in making decisions abQut appropriations to meet those citizens' watcr needs. Neverthekss. <br />upon water rights adjudication those "local" decisions arc subject to full judicial evaluation. The <br />CWCB's "policy role" is exaggerated as ajustification to trWlcatc the proof process lor ISF rights. <br /> <br />These are my views for you to consider as you continue your informal process of preparing <br />rule revisions for the CWCB's consideration later this month. I appreciate being included in your <br />informal discussion group and am providill@ these written comments now, in addition to my <br />JWle 29 memo, since you wanted comments for distribution to the Board this week. Thc River <br />District's Board meets next week, and I will seek their input. I then will be ab)" to presenl the <br />Board's position as the rulemaking process unfolds. <br /> <br />Sincerely. <br /> <br />~~/~ <br /> <br />David C. Hallford <br />General COWlsel <br /> <br />DC1bb <br />pc: Scoo BaIoDInb, E5q. <br />MAe Calli. Ellq. <br />CyatU. C~lI. f.s.q <br />......-..... <br />"'""'w_...... <br /> <br />, <br /> <br />.. <br /> <br />e <br /> <br />e <br /> <br />e <br />