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<br /> A. Applicants’ Position: Applicants believe that the conservative nature of the LFT will more than make up for any additional irrigation water that will be applied to a field after <br /> it is dry-land farmed. In other words, the LFT underestimates HCU credits, so Applicants will be over-replacing water to the river when they are operating the Pilot Project. According <br /> to the Division Engineer’s Office, the soil moisture issue was considered when the Criteria and Guidelines were drafted, and the parties creating the Guidelines concluded that no rules <br /> regarding soil moisture were required due to the conservative nature of the LFT. Moreover, in this Pilot Project, land will only be fallowed or dry-land farmed for up to three years, <br /> rendering this term and condition even more unnecessary. <br /> [Nonetheless, Martin and Wood Water Consultants has conducted an analysis of the soil moisture issue, and determined that…. Craig?] <br /> B. LAWMA’s Position: LAWMA believes that water within the soil moisture profile will be depleted when a fallowed parcel of land is dry-land farmed and that this depletion will cause <br /> the Catlin Canal to divert additional water during the next irrigation year to replace the depleted soil moisture reservoir on the dry-land farmed parcel resulting in injury to Arkansas <br /> River water rights. The Applicant’s assertion that because the LFT is conservative such that Applicant’s use of the LFT will result in downstream water rights receiving more water <br /> during fallowing operations does not address the potential for injury to other water rights during the following year when irrigation takes place. LAWMA has identified that the depletion <br /> of the soil moisture reservoir due to dry-land farming of a parcel during a fallow year could be up to 116 acre-feet in a single year if all of the land dried-up is dryland farmed with <br /> winter wheat (1994). This is a result of winter wheat consuming the water within the soil profile from March to June at a monthly PET amount determined by Dale Straw of the SEO in <br /> 2011 for the Rocky Ford climate station and the lower effective monthly precipitation amounts for the year. <br />LAWMA doesn’t believe that a potential 116 acre-foot depletion amount is insignificant and, therefore, LAWMA recommends that if any parcel is dry-land farmed or is tilled in a manner <br /> that could increase the loss of soil moisture to control soil erosion, then Super Ditch should provide a water budget analysis that establishes the end of the year soil moisture volume <br /> prior to dry-up and after dry-up. If this analysis shows that the soil moisture volume has decreased, then this depletion amount should be replaced by Applicants as a return flow obligation <br /> during the upcoming year. <br />2. Whether lagged deep percolation factors should be calculated according to the Criteria and Guidelines, or according to the analysis in Case No. 12CW94. <br /> A. Applicants’ Position: Applicants believe that it is appropriate to utilize the process outlined in the Criteria and Guidelines to calculate lagged deep percolation factors. The <br /> purpose of the Criteria and Guidelines, LFT, and pilot project program in general is to streamline leasing and fallowing projects to make them less onerous and undesirable for participants. <br /> The purpose of HB 1248 pilot projects is also to test the streamlined process to determine if it is viable. In order to test this aspect, Applicants need to use the process in