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<br />ODiJG95 <br /> <br />Burec A2 Comments <br /> <br />COMMENTS ON <br />DRAFT <br />PHASE 2 COORDINATED FACILITIES <br />WATER AVAILABILITY STUDY FOR THE <br />ENDANGERED FISHES OF THE UPPER <br />COLORADO RIVER <br />DATED JANUARY 2003 <br /> <br />. <br />1) The Executive Summary should clearly acknowledge the limitations ofthe modeling effort. <br />Specifically, that the period of record modeled does not include a long term drought period or <br />even one as long as we are currently experiencing nor does the model accurately depict the <br />exchanges between reservoirs. Additionally, the limitations that using a monthly model, with <br />perfect hind sight and operational response, attempting to analyze an operation that requires <br />changes and responses on a daily basis lends a much more positive picture of what reservoirs <br />could do than reality bears out. In actual practice operators are going to be much more <br />conservative with releasing water for peak flow augmentation and will be looking for assurances <br />from forecasts, and perhaps an insurance pool, that they will be able to recover water released for <br />peak flow augmentation before they do so. As a result of this, the reality is that the estimates in <br />the evaluation of all ofthe different alternatives lead the reader to believe that much more can be <br />done with the existing systems than will be the case. <br /> <br />This should also be reflected in the Conclusions and Recommendations chapter. <br /> <br />~1 <br /> <br />Time period for study was agreed upon by all involved at the start of the study, as well as <br />the selection of StateMod. We believe that the tools and data used in this analysis <br />adequately determines the feasibility of supplying the 20,000 acre-feet. The final <br />recommendation and "rules" governing CFOPS should have drought provisions, but the <br />findings of this study clearly indicate that enhancement of peak flows, during wet years, is <br />feasible. <br /> <br />2) Executive Summary, page 5, second paragraph under "feasibility of Efficiencies . . ."; <br />"Analysis ofthis alternative indicated that diverting to storage under the Green Mountain refill <br />priority was a more efficient way to replace the 20,000 acre-feet supplied...". It is unclear what <br />measure of "efficiency" is being judged here. 'Suggest the term "efficiency" be replaced with <br />"less costly" or something that more accurately defines a real measureo This comment also <br />applies to the body ofthe report and the Conclusions and Recommendations chapter. Noted. <br />Revision will be made to be more clear about what the measure of efficiency is meant by here. <br /> <br />I <br /> <br />3) Section 1.3.1, page lO, second bulleted paragraph, 1 st line: Suggest replacing "occurring" <br />with "accruing". Noted - correction will be made. <br /> <br />4) Section 1.3.1, page 11, first bulleted paragraph, 3rd line: "0. opursuant to the Ruedi <br />Reservoir Round II Water Sales Biological Opinion." Noted - correction will be made. <br /> <br />P:\Data\GEN\CWCB\19665\Report Phase 2\Technical Memorandum No. 12\Appendix B"doc <br /> <br />3 <br />