NonBasicSpecificComments12

• Title: Comments 12
• SWSI - Doc Type: Comments

is and whether or not it should be analyzed in this process. A less subjective means is
essential in determining the Tier status of a project if this ranking is to have any,
credibility.
For example, in the Arkansas RT, it appeared that every water project sponsor will take
as Iowa tier category (lor 2) as possible to minimize public debate on the projects they
are supporting/pu.shing. The Roundtable should question the rankings and the process by
which rankings are done. Sponsors must be required to demonstrate the validity of their
category proposals~ "
Having CWCB board members and the CWCB-designated basin advisors submit their
own weighting of options is at odds with th~ CWCB's proclamation that SWSI is a
"bottoms up" process based on local interests. In some basins, their inclusion will
potentially sway the results in favor of big storage projects and state led water policy.

Technical issues

Instream flows

. The SWSI must incorporate flows necessary to preserve and restore aquatic
ecosystems and instream recreati~n opportunities in" all-alternatives.
. The Conservation Board (CWCB) says it will use existing instrearn flow decrees as
their environmental demand, but from our perspective these flow designations are not
adequate. The most economical way to, ensure that the SWSI properly incorporates.
ecosystem demands would be for the CWCB and its contractor to use the Colorado
Water Trust (CWT) maps. Existing CWCB instre~m flow and Recreational In-
Channel Diversion water rights are insufficient. The data underlying the CWT maps,
along with the other data that environmental and recreation SWSI advisors and others
suggested you use, can supplement the maps themselves, and in some cases (e.g.: for
the Upper Colorado River Basin region) will include quantified flow needs~
. Any new projects incorporated into SWSI alternatives, including Tier 1 projects, must
incorporate protective instream flows. Where the projects as proposed do not do SQ,
CWCB J S contractor must add that component as part of its optionS4
. CWCB and the SWSI Advisors should consider riparian issues in addition to fish-
...-- .'.'-related issues in identifying instream-flow needs -----. - u___ -----~ --

Other issues

. Municipal and Industrial demands should be dealt with separately from agricultural
demands.
. Conservation must be con~idered i~ all alternatives and be incorporated into
Municipal & Industrial demands to be determined by local interests, SWSI Advisors
and CWCB.
. Projected urban/suburban per capita water consumption rates should:
( 1) Be based on Department of Local Affairs (DOLA) population projections (not on
a mix of otner sources, e~g., 1997 Farm Bureau estimates which'sought to
maximize the potential for urban growth);