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11 '\ Mr. Steve Gunderson August 7,2007 Page 2 The EIS for the Chatfield Reservoir Reallocation Project is scheduled to be issued in September 2008. The Division is urging, and the Water Quality Control Commission ("Commission") has scheduled, a rulemaking hearing to update the total maximum annual load ("TMAL") for phosphorus and/or chlorophyll a for the Reservoir. This rulemaking hearing is scheduled for November 2008, merely two months after the anticipated issuance of the EIS. Chatfield water quality standards and the TMAL are directly related to, and dependant upon, the amount of flow into and out of the Reservoir. The Chatfield Reservoir Reallocation Project will significantly alter flows and operations of the Reservoir. Therefore, the TMAL should not be updated until these components are deternlined. Further, if new nutrient criteria are adopted for the Reservoir two months after the EIS is issued, a Supplemental EIS will likely need to be prepared, at significant additional expense and time, in order to reevaluate the water quality affects of the Reallocation Project. Roxborough, and other water users involved in the EIS process, do not have the luxury of additional time and the Colorado Water Conservation Board, The U.S. Army Corps of Engineers, and the water users have already expended considerable sums preparing the EIS. Additional water supplies are needed immediately; any additional delay in the process will impair Roxborough's development of alternative water supplies for its community. Moreover, the Colorado Water Conservation Board and u.S. Army Corps of Engineers are overseeing the redevelopment of water quality modeling for Chatfield Reservoir to determine whether the proposed changes to reservoir elevations, water flow fluctuations, etc., will impact water quality. No existing models for Chatfield Reservoir were adequate so a new model is being developed. As a director of the Chatfield Watershed Authority, we have worked with Chatfield reallocation team to assure that a new model would be adaptable for our water qilality planning and modeling needs. Therefore, after the Chatfield Reallocation Model is completed, it would be appropriate to evaluate using that model for revising water quality standards and regulations. While updating the TMAL in November 2008 will significantly impact Roxborough's ability to develop water supplies for its residents, it will not significantly improve the quality of water in the Chatfield Reservoir. The Reservoir has never exceeded the chlorophyll a goal, even in years when the phosphorous load to the Reservoir was exceeded due to forest fires. Therefore, there appears to be no immediate environmental concern which would justify updating the TMAL and reallocating phosphorus loads at such a critical time for the water users to complete the Reallocation Project EIS. The Chatfield Watershed Authority and Reallocation Project have invited, and encouraged Division representatives to participate in the Chatfield reallocation evaluations, especially water quality modeling and investigations. The opportunity for collaboratively evaluating water quality in Chatfield remains open and by working together on one process, the state will avoid costly duplication of modeling efforts and delays to water storage projects. :D0459624.1]