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1815 direct diversion water during the growing seas'on. Because winter stored water can be kept for use at any time, it is not interchangeable with direct diversion water which is usable only during the time of diversion. Under the water bank operation, some of the tater which FLCC participants have leased to the water bank would be stored in AdobelHorse Creek Reservoirs, along with the non.. participants' share of the FLCC winter store~ water. Subsequently, during the following winter season, part of the water in AdobelHdrse Creek Reservoirs would be exchanged to Pueblo Reservoir and stored until released to water bank renters. Non-participating shareholders' use of AdobelHorse Creek Reservoirs must not be reduced by water bank operations. Except in very wet years, cotnpetition would be unlikely between non- participating shareholders' use of the reservoirs and water bank use of the reservoirs. C. FryingPan-Arkansas Project (Fry-Ark) Watei: The FLCC has historically purchased water from the Southeastern Colorado Water Conservancy District to supplement its decreed water rights, The purchases, made annually, have ranged from zero to over 69,000 af. Because the water is provided by a United States Bureau of Reclamation Project, and is usedifor irrigation purposes under the FLC, it is subject to the United States Reclamation IReform Act, as amended, and its lengthy regulations. The Reclamation Reform Act p~ohibits water application to certain lands and can cause additional costs for water used Qn certain other lands. Enforcement of the Reclamation Reform Act is unique within the Southeastern Colorado Water Conservancy District boundaries because of peculiar aspects of the Southeastern District's contract with the Bureau of Reclamation. The FLCC has a Reclamation Reform Act compliance plan on file with the Southeastern District. ' Fry-Ark water cannot be resold or leased b}\ purchasers. Thus, Fry-Ark water cannot be considered to contribute to the water supply ~hich creates the historic consumptive use of water bank participants. Further, the dryup ofIands eligible for application of Project water will likely result in the FLCC receiving less water in allocations (because of the practices of the Southeastern District in the allocation of Project water). Therefore, FLCC shares participating in the water bank cannot obtai~ FryArk water. The non-participating share holders can receive their Fry-Ark water as u$uaI. ! I i Alternatives for Storage A. Adobe Creek and Horse Creek Reservoirs (pwned by FLCC): , i These reservoirs, capacity 87,000 af and ~,OOO af respectively, hold relatively junior priorities. In some years neither of these st1re water under its priorities except during the winter storage period. During the winter stqrage period, either or both store water under the decreed winter storage program. Permission from the FLCC is necessary to use the 7-10