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<br />U.S. Fish and Wildlife Service <br />January 30, 1996 <br />Page 2 <br /> <br />that is available to meet downstream demands. Reservoir <br />evaporation is also tabulated as a depletion, but reservoir storage <br />and releases, whether the reservoir is on-stream or off-stream, do <br />not enter into the computation of depletions, with the exception <br />that water exported from a river basin for storage is counted as a <br />depletion in the basin of export. <br /> <br />The term "net" when used as a modifier to depletion is <br />unnecessary and only introduces confusion unless it is intended to <br />denote a different computation and, if so, it should be fully <br />explained. <br /> <br />Figure 21 of Appendix A to the draft illustrates some of the <br />confusion resulting from the terms used in the draft. Apparently <br />the modeled annual depletions as plotted on the chart of Figure 21 <br />reflect the operation of Ridges Basin Reservoir. Stage A of the <br />Animas-La Plata Project (ALP) is to be operated to provide water <br />for municipal and industrial demands. These demands and the <br />depletion associated with the water used do not vary greatly from <br />year to year, albeit there are minor variations caused by changes <br />in the weather and normal minor fluctuations in demand. However, <br />the values plotted on the chart in no way resemble the actual <br />depletion resulting from operating the project to meet the <br />municipal and industrial demands associated with Stage A. As an <br />example, the "annual depletions" plotted for 1934 and 1977 are <br />about 22,000 and 28,000 acre-feet respectively. Such depletions <br />would indicate annual shortages of more than 50% in those two <br />years. The report by the Bureau on Stage A of ALP states that the <br />municipal and industrial demand will be met without shortage. The <br />two years cited above are the extremes but serve to illustrate some <br />of the problems and confusion contained in the draft. <br /> <br />Moreover, all of the other depletions referred to in the draft <br />including Table 2 are, to the best of our knowledge, average annual <br />depletions computed as described above by water management agencies <br />which do not reflect reservoir operation other than reservoir <br />evaporation. <br /> <br />We strongly recommend <br />reflect depletion as the <br />beneficial consumptive use <br /> <br />that the draft be revised <br /> <br />term is generally used <br />of water. <br /> <br />to correctly <br />to describe <br />