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<br /> <br /> <br /> <br />December 14, 2018 <br /> Via email to Rebecca.Mitchell@state.co.us & Lauren.Ris@state.co.us <br /> <br />Rebecca Mitchell, Director <br />Lauren Ris, Deputy Director <br />Colorado Water Conservation Board <br />1313 Sherman Street, Suite 721 <br />Denver, Colorado 80203 <br /> <br />Re: Tri-State’s Comments re CS-U Pilot Project Proposal for Selection <br /> <br />Dear Ms. Mitchell and Ms. Ris: <br /> <br />Thank you for the opportunity to provide comments regarding the November 16, 2018 <br />proposal (“Proposal”) filed by the Lower Arkansas Valley Super Ditch Company, Inc. (“Super <br />Ditch”) and the City of Colorado Springs, acting by and through its utility enterprise (“CS -U” <br />and collectively, “Applicants”) for an H.B. 13-1248 pilot project involving shares in the Catlin <br />Canal Company, Fort Lyon Canal Company and/or Rocky Ford High Line Canal Company <br />(“CS-U Pilot Project”). I am writing on behalf of Tri-State Generation and Transmission <br />Association, Inc. (“Tri-State”) to submit comments on the Proposal for consideration by the <br />Colorado Water Conservation Board (“CWCB”) pursuant to section II.A of the CWCB’s Criteria <br />and Guidelines for Fallowing-Leasing Pilot Projects dated November 19, 2013 and amended on <br />January 25, 2016 (“Criteria”). <br /> According to the Applicants, the CS-U Pilot Project will rotationally or intermittently <br />fallow parcels of land irrigated by the Catlin, Fort Lyon, or Rocky Ford High Line canals and <br />transfer up to 5,000 acre-feet per year of consumptive use water to Colorado Springs Utilities in <br />Pueblo Reservoir. Super Ditch intends to use a forthcoming decree in Case No. 10CW4 <br />approving appropriative rights of exchange to transfer consumptive use water from the historical <br />irrigation locations to Pueblo Reservoir. The proposed CS-U Pilot Project would operate from <br />January 1, 2020 through December 31, 2029. <br /> <br />Tri-State owns water rights that divert from the Arkansas River in the vicinity and <br />downstream of the proposed CS-U Pilot Project, including shares in the Fort Lyon Canal <br />Company, Amity Mutual Irrigation Company, and Buffalo Canal Company; other well and <br />surface diversion water rights; conditional exchange, groundwater, and storage water rights <br />decreed in Case No. 2007CW74; and shares in the Lower Arkansas Water Management <br />Association. Tri-State is participating in the Pilot Project process to ensure that its water rights <br />are protected from injury and to assist the CWCB and Applicants in demonstrating the viability <br />of non-injurious alternative methods to transfer water rights from agricultural to municipal uses. <br />Tri-State has previously participated cooperatively with Super Ditch in the Catlin Pilot Project