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;~;. - <br />RICHARD D. LAMM <br />`i OYernOf <br />1 <br />• <br />r 111111111lII11111111 j <br />JERIS A DANIELJVIV <br />State Engineer <br />1 <br />OFFICE OF THE STATE ENGINEER <br />DIVISION OF WATER RESOURCES <br />1313 Sherman Street-Room Bib <br />Denver, Colorado 80203 <br />(303)866-3581 <br />February 19, 19B? <br />DiED1oRAIJDUPI <br />T0: 6lined Land Reclamation, Attention: Bob Liddle <br />FRODS: Hal D. Simpson, Assistant State Engineer <br />SUBJECT: Coors }:eenesburg D1ine - Permit Application <br />e.. , t. <br /> <br />Col c. Det. 01 i~d;Lfoi FC;7'J:C"; <br />Ir. response to your request for comments regarding the Coors response to your <br />stipulation concerning water rights, we are proti•iding the following comments <br />for your consideration: <br />1. The applicant claims credit for return flows totaling 25.4 <br />acre-feet by virtue of irrigation application to reclamation <br />parcels. By claiming these return flows, the amount of water <br />that must be replaced is reduced to 50.1 acre-feet the first <br />year and during subsequent years will decrease to 10.1 acre- <br />feet. hle cannot accept any analysis based on Blaney-Criddle <br />as the basis for calculating the amount of water that will <br />return to the system. In addition, it appears that the <br />Blaney-Criddle analysis as presented in their response seri- <br />ously underestimates the consumptive use that will occur. <br />We feel that the evaluation should not be based on irrigated <br />native pasture grass consumptive use factors or include any <br />adjustment factor based on percent of month irrigated. It <br />is very possible that almost all of the water applied will be <br />consumed after irrigation efficiency is taken into considera- <br />tion. The State Engineer's Office takes the position that <br />once water is used for irrigation, even if the source of this <br />water is non-tributary wells, any resultant seepage and waste <br />water that should occur has co-mingled with tributary water <br />and can't be identified; therefore, they have lost dominion <br />over the water- They must be able to measure and identify <br />return flows from the irrigation water used fox reclamation. <br />-. 19e would want water released £or augmentation through GASP based <br />on estimate of consumptive use for the coming year and an annual <br />report furnished in February of each following year to cbnfirm <br />