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I offer the following comments and concerns regarding Functional Areas 26& 27. The River District cautions against universal application of any recommendation to selectively assign operations and maintenance responsibilities (Functional Areas 26 and 27) to water user beneficiaries of Reclamation projects. Specifically, the River District is extremely concerned with a proposal emerging from the Managing for Excellence program to transfer operations and maintenance responsibilities for the federal Colorado-Big Thompson (?C-BT?) project to the Northern Colorado Water Conservancy District (?Northern?). The C-BT project is a complex project with multiple beneficiaries. Because the C-BT is a transmountain diversion project, beneficiaries include parties on both sides of the Continental Divide. These parties have unique and often conflicting interests in project operations. Consequently, assignment of O&M responsibilities to one project beneficiary in this circumstance would be an unacceptable assignment of Reclamation?s responsibilities. The authorizing legislation for the C-BT project requires that the Project be operated in conformance with Senate Document 80. The "Manner of Operation" section of Senate Document 80 opens with an assurance that the C-BT is intended to preserve "the rights and interests dependent on this water, which exists on both sides of the Continental Divide in Colorado." It continues with a recitation of primary project purposes and a requirement that "in order to accomplish the listed purposes that the project be operated by an unprejudiced agency in a fair and efficient manner equitable to all parties having interests therein." (Emphasis added.) We do not believe any single project beneficiary qualifies as an unprejudiced agency for this project. The River District fully understands and supports the operational efficiencies and cost-savings sought by such transfers. However, given the tensions among this project's beneficiaries concerning project operations, we strongly urge Reclamation to remain the "unprejudiced agency" responsible for project operations as required by Senate Document 80 for this and any similarly situated Reclamation project. Furthermore, the River District is concerned with any "compromise effort" that officially reserves final operational decision-making authority to Reclamation but nevertheless seeks to realize cost and operational savings by reducing Reclamation staffing to levels effectively unable to conduct meaningful and authoritative decision-making. This too would be an unacceptable abdication of Congressionally-mandated Reclamation responsibilities. The complete title of Senate Document 80 is Synopsis of Report on Colorado Big Thomson Project, Plan of Development and Cost Estimate, prepared by the Bureau of Reclamation, Department of the Interior, 75th Congress, First Session, June 15, 1937.	10/27/2006

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I offer the following comments and concerns regarding Functional Areas 26& 27.
The River District cautions against universal application of any recommendation to selectively assign operations and maintenance responsibilities (Functional Areas 26 and 27) to water user beneficiaries of Reclamation projects.

Specifically, the River District is extremely concerned with a proposal emerging from the Managing for Excellence program to transfer operations and maintenance responsibilities for the federal Colorado-Big Thompson (?C-BT?) project to the Northern Colorado Water Conservancy District (?Northern?). The C-BT project is a complex project with multiple beneficiaries. Because the C-BT is a transmountain diversion project, beneficiaries include parties on both sides of the Continental Divide. These parties have unique and often conflicting interests in project operations. Consequently, assignment of O&M responsibilities to one project beneficiary in this circumstance would be an unacceptable assignment of Reclamation?s responsibilities.

The authorizing legislation for the C-BT project requires that the Project be operated in conformance with Senate Document 80*. The "Manner of Operation" section of Senate Document 80 opens with an assurance that the C-BT is intended to preserve "the rights and interests dependent on this water, which exists on both sides of the Continental Divide in Colorado." It continues with a recitation of primary project purposes and a requirement that "in order to accomplish the listed purposes that the project be operated by an unprejudiced agency in a fair and efficient manner equitable to all parties having interests therein." (Emphasis added.) We do not believe any single project beneficiary qualifies as an unprejudiced agency for this project.

The River District fully understands and supports the operational efficiencies and cost-savings sought by such transfers. However, given the tensions among this project's beneficiaries concerning project operations, we strongly urge Reclamation to remain the "unprejudiced agency" responsible for project operations as required by Senate Document 80 for this and any similarly situated Reclamation project.

Furthermore, the River District is concerned with any "compromise effort" that officially reserves final operational decision-making authority to Reclamation but nevertheless seeks to realize cost and operational savings by reducing Reclamation staffing to levels effectively unable to conduct meaningful and authoritative decision-making. This too would be an unacceptable abdication of Congressionally-mandated Reclamation responsibilities.

* The complete title of Senate Document 80 is Synopsis of Report on Colorado Big Thomson Project, Plan of Development and Cost Estimate, prepared by the Bureau of Reclamation, Department of the Interior, 75th Congress, First Session, June 15, 1937.

10/27/2006