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,. . . . , The water user concern that appears to be most difficult to resolve is the "equity" question raised on behalf of the Colorado River Water Conservation District. The District concludes that: Proceeding with the 15MR PBG without first defining and agreeing to a clear plan for the other basins' significantly increases the regulatory risk to the other basins, " The District suggests that the 3,000 acre-foot "sufficient progress" threshold will be reduced in the future and that the Department, this Board and other water users won't be as motivated to assure fair treatment for water users in these other basins after the 15- Mile Reach PBO is in place, We have not established clear plans to provide similar protection in the Yampa or Gunnison basins yet, and the rationale for FWS' s objections to the District's proposed resolution is still difficult to understand, We have not exhausted our opportunities to conclude this effort at the staff level and we need to emphasize this priority, We have strong support from the Department to establish a fair approach for the other basins and the greatest distraction is our continuing dedication to the IS-Mile Reach precedent. RECOMMENDATION On this basis, I recommend that the Board endorse the draft PBO as a significant improvement in defining the terms for succesS with the Recovery Program ,\md continue to commit key staff to the future application of this general precedent for t11'e benefit of water users in other river basins, Our staff should submit comments to the PM'S within the November 30 deadline indicating this endorsement and recommending revisions identified in consultation with the water user representatives, Furthermore, the FWS and Recovery Program need to provide similar protection for existing supplies and future opportunities in the other subbasins, We sho Id maintain our ongoing efforts to meet directly with FWS representatives, to raise cone at the Recovery Program Management Committee meetings and, if necessary, to quest the direct assistance of the FWS Regional Director to establish a clear plan d schedule) by the next meeting of the Recovery Program's IIllplementation Comini e, I also recommend that we contact the Division of Wild I , ivision of Parks and Outdoor Recreation, the Department of Corrections and any other Colorado agencies with water rights covered by the proposed PBO and urge that they enter into a recovery agreement as quickly as possible, The Division V Engineer could assist in identifYing other appropriate agencies, xc: Orlyn Bell Henry Maddox Tom Pitts Dan Luecke L:/WCTRANSlBoardmeinlNov99120g 15MR PBO BdMem , The CRWCD letter of November 12,1999 indicates concern with respect to the Yampa and Gunnison River basins, but this assessment would logically extend to the White, Dolores and San Juan Rivers, as well,