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001SZ2 " Public Scoping Comments, Gunnison River Contract, conI. ,/:\C.:.. ", ,. ... ,..;, .. 22. CRWCD; pl,'1. This letter is the first in a continuing series of comments on the Federal decision-making process which has at its core the January 15, 1992, "Preliminary Working Draft" of an Aspinall Unit Water Service Contract as proposed by Reclamation (USBR) and the National Park Service (NPS). These comments are intended to supplement the remarks made by Colorado River Water Conservation District (River District) staff at the public meetings scbeduled by USBR in May 1992, and do not supersede or replace those remarks. The River District expects to remain involved throughout the process of negotiating this contract and any proposals to adjust Aspinall Unit operations under provisions of the Endangered Species Act, and reserves the right to make additional comments as opportunities arise. 3b. CRWCD; pI', '2. I. The River District sh;;"es the concern expressed by the public that this process is proceeding without a nfocal point" in the form of a suggested operation scenario or recommended hydrography for the Black Canyon of the Gunnis!,>n National Monument (BNM). NPS has had years to study and form opinions concerning the needs of BCNM for the purpose of quantifying its Federal water right, but no disclosure of the NPS findings has been made prior to or during this scoping process. If the purpose of this contract is to supply NPS with sufficient water to satisfy the needs of BCNM, NPS must disclose its draft report containing that information. 21. CRWCD; p2,'1L 2. We have received your lette~ of June 12, 1992, which serves notice that the River District and other parties to the 1975 Exchange Agreement are being denied the opportunity to be parties in these negotiations. We are disappointed in your response, and still believe that the Colorado Water Conservation Board is unable to fully represent the River District's and other Gunnison River Basin water...users' interests during the negotiations. We hereby re-state our request to obtain party status and to be considered as a signatory to the contract, based on our contractual relationship with USBR for Aspinall Unit water rights and our standing as party to the 1975 Exchange Agreement. ..".. . ~,..,:......:, <~~:~[.~:;) 22. CRWCD; p2,'2. 3. The proposed contract for downstream water service under a changed release scbedule represents a major operational change for the Aspinall Unit, and will likely have negative impacts on power revenues and recreation opportunities. Con;apliance with the National Environmental Policy Act (NEPA) is necessary to properly identify alternatives to this Federal action, and to assess and disclose impacts to ihe environmental and local economy. If an Environmental Impact Statement is to be prepared, the River District wishes to be given the opportunity to participate as a Cooperating Agency. 3a. CRWCD; p2, '13. 4. This scoping process has been noticed to the public and to statellocal agencies as necessary prior to initiating negotiations on the contract referenced above. The contract must be limited to serving the legitimate needs of BCNM. While it is appropriate to consider the requests of the U.S. Fish & Wildlife Service (FWS) for flows to augment endangered fish habitat on tbe lower Gunnison Rive during the process, it must be recognized that the amounts of water requested by NPS and FWS require separate and distinct justifications. 8. CRWCD; p2, '13. 4. This scoping process has been noticed to tbe public and to statellocal agencies as necessary prior to initiating negotiations on the contract referenced above. The contract must be limited to serving the legitimate needs of BCNM. While it is appropriate to consider the requests of the U.S. Fish & Wildlife Service (FWS) for flows to augment endangered fish habitat on the lower Gunnison Rive during the process, it must be recognized that the amounts of water requested by NPS and FWS require separate and distinct justifications. .' ..t.. 44