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<br />, <br /> <br />, <br />, <br /> <br />3454 <br /> <br />Mr, Hal D Simpsol1, Colorado State Engineer <br />October 6, :2000 <br />Page 2 <br /> <br />Our understanding of this program is that NCWCD views it as a means of <br />spreading the "be::teiits" or the C-BT Project to water users that may nor have <br />allotmel1t cOl1traets but suPPOrt the Project through property taxes. [11 descnbil1g the <br />11011-charge program to the Colorado River District Board, Eric Wilkinsol1 stated that <br />the program is carefully managed so that non-charge water is only delivered to <br />places where there is a "hole" or "dry spOt" in the river, and that the local water <br />commissiol1ers are responsible for identifying the dry SpOt and delivering the water <br />to those locations for benefiCIal use, However, discussions between my staff and <br />Division 1 personnel lead us to believe that there are no good state records on where <br />or how the 110n-charge water is being delivered or used and that deliveries or use or <br />this water may not be monitOred at all by Divisiol1 I offielals <br /> <br />[n a separate letter to the Bureau of Reclamatiol1, the River Distriet has <br />outlined, in detail, its concerns with specitle operations of the C-BT Project, The <br />River District's cOl1sultants, Helton & Williamsen, investigated the C.BT non-charge <br />program and analyzed available data to determine whether this water was being <br />consumptively used, A detailed report was prepared which concludes that up to <br />40% of all non-charge deliveries between 1983.-1998 were nOt diverted for <br />consumptive uses within Colorado, Preliminary calculations indicate that these <br />unused and unnecessary West Slope diversions may average as much as 15,000 aere <br />feet annually You will receive a copy of our letter to Reclamation and the Helton & <br />Williamsen report, <br /> <br />Another example of our coneerns is the accounting used to traek diversiol1s <br />through the Independence Pass (Twin Lakes) Tunnel into [he Arkansas River Basin. <br />[n this ease, we have found that several different organizations (the Twin Lakes <br />Company, the Bureau of Reclamation and a conservancy district) all have different <br />and complex accounting systems with no offieial "eoloring" or tracking of <br />transmountain water by Division of Water Resources offieials, Consequently, <br />Colorado River and native Arkansas River water in storage in Twin Lakes is being <br />exehanged to Turquoise Lake and is being booked over as Homestake Project water, <br />openi'ng the opportunities for violations of water right decrees and project <br />authorizations, <br /> <br />Yet another example is the operation of the Vidler Tunnel, a [lnv and simple <br />transmountall1 diversion out Ot- the headwaters or' the Blue River, The avatlable <br />reeords suggest that Vidler water is beil1g diverted from Water Oivlsiol1 5 (District <br />