1600 West 12th Avenue
Denver, CO 80204-3412

November 9, 2016

Ms. Barbara Biggs, Chairperson
Mr. Sandy White, Chairperson
Mr. Joe Frank, Chairperson
Colorado Water Conservation Board
1313 Sherman Street, Room 721
Denver, Colorado 80203
Re:

Phase II(a) WSBRT Risk Study - Colorado River

Dear Ms. Biggs and Messrs. Frank and White,
On behalf of the members of the Front Range Water Council (“FRWC”), I am writing to
express our collective concern with the Development and Curtailment Risk Study of the West Slope
Basin Round Tables (“WSBRT”) for the Colorado River.
FRWC members include Denver Water, Northern Water, the City of Aurora, Pueblo Board of
Water Works, Colorado Springs Utilities, Southeastern Colorado Water Conservancy District, and
the Twin Lakes Reservoir and Canal Company. The FRWC represents the interests of front range
Colorado River water users, and the members of the FRWC collectively serve approximately 80% of
the State’s population.
We are interested in and support the investigation of collaborative and voluntary means for
addressing Colorado River compact issues. This includes the various ongoing drought contingency
planning efforts being undertaken in the Basin. We believe these investigations are best conducted
in a statewide or upper basin manner with all interested water users represented, rather than by
particular sub regions or individual roundtables.
Not only does the proposed Phase II study represent a local assessment of basin-wide, multistate concerns, the Phase II study proposes to assess various involuntary compact curtailment
alternatives that could be imposed on existing uses, which is not consistent with the study’s objective
of providing information to address Principle 4 of the IBCC Conceptual Framework:
Principle 4: A collaborative program that protects against involuntary curtailment
is needed for existing uses and some reasonable increment of future development in
the Colorado River System, but it will not cover a new TMD.

 South Platte, Metro and Arkansas Roundtables
November 9, 2016
Page 2

Some of the proposed involuntary curtailment alternatives in Phase II potentially favor limited special
interests. Again, administrative actions that the State of Colorado might undertake to involuntarily
curtail water uses to meet its compact obligations are best led by the State in consideration of the all
of the States interests and obligations to other states.
We are also concerned that the assumptions used in the Phase I modeling study may be
creating biased impressions regarding the amount of the remaining developable water under the
compacts. Already we understand that the Phase I study may be viewed by some outside of Colorado
as representative of the State of Colorado’s position on remaining developable water. We think the
State should be responsible to lead studies of administrative actions the State might take to limit new
developments of Colorado River water. We also conclude that CWCB funds should not be used for
studies like this that do not represent statewide interests. A more detailed discussion of modeling
assumptions and results is provided in the attached letter from Grand River Consulting.
In conclusion, we appreciate the WSBRT Group’s efforts to study risks posed to Colorado
River water users and allowing East Slope interests to review study results, but believe this is a topic
best led by the State of Colorado in the interests of all water users. For the reasons addressed above,
the FRWC has decided not to participate in Phase II of the study. The FRWC encourages the East
Slope Roundtables to oppose the WSBRT Group’s request for funding for Phase II(a) and to urge the
State of Colorado to lead Colorado River modeling efforts related to risk management and compact
compliance and administration issues.
If we are unsuccessful in convincing the State to assert its leadership role in modeling
Colorado River Compact administration issues, the FRWC may undertake its own independent
modeling effort and ask the three East Slope Roundtables to help contribute funding. However, we
would do so reluctantly as modeling by regional interests may only serve to further divide the State.
If you have any questions regarding the contents of this letter or would like to discuss the
FRWC’s concerns further, please do not hesitate to contact me. We thank you for your consideration
of the concerns raised in this letter.
Sincerely,

James S. Lochhead
President, Front Range Water Council