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001246 STATE OF COLORADO - Colorado Water Conservation Board Department of Natural Resources 721 Centennial Building 1313 Sherman Street Denver, Colorado B0203 Phone: 13031 866.3441 FAX: (3031 866.4474 STATE OF COLORADO WATER CONSERVATION BOARD COMMENTS ON DEPARTMENT OF THE INTERIOR U.S. BUREAU OF RECLAMATION PROPOSED 43 CFR PART 414: OFFSTREAM STORAGE OF COLORADO RIVER WATER AND INTERSTATE REDEMPTION OF STORAGE CREDITS IN THE LOWER DIVISION STATES Roy Romer Governor James s. lochhe.ld Executive Director, DNR DariesC. Li!e, P.E. Director, eweB Submitted April 3, 1998 The mission of the Colorado Water Conservation Board is to promote the protection, conservation, and development of Colorado's water resources in order to secure the greatest utilization of those resources for the benefit of present and future generations, and to minimize the risk of flood damage and related economic losses, One of the Colorado Water Conservation Board's major responsibilities is protection of Colorado's interstate compact apportionments, The Colorado Water Conservation Board appreciates the opportunity to review and comment on the proposed rule as published by the Department of Interior and the U, S. Bureau of Reclamation in the Federal Register on December 31, 1997 at "43 CFR Part 414: OFFSTREAM STORAGE OF COLORADO RIVER WATER AND INTERSTATE REDEMPTION OF STORAGE CREDITS IN THE LOWER DIVISION STATES," Reclamation is to be commended for its efforts to facilitate the resolution of some of the difficult issues facing Colorado River water users in the Lower Basin, The Colorado Water Conservation Board is very supportive of the proposed rules general framework that allows the Lower Division states of the Colorado River Basin to make more efficient use of their apportionments through the use of interstate water storage agreements. The interstate water transactions that will occur after promulgation of this rule will provide important benefits within the Lower Division States. However, these transactions must be carefully defined and appropriately administered in a manner that fully protects the rights of all Colorado River water users, be they in Lower or Upper Colorado River Basins, It is absolutely critical that this proposed rule in no way impact the basic elements of the "Law of the Colorado River." We believe it is the intent of this rule to facilitate transactions that are already allowed under the Page 1 of 7