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<br />i <br /> <br />.- management and integration of existing systems and the implementation of efficiency and reuse. <br />The fact that the lists of mid and long-term alternatives selected by SWSI often do not appear to <br />be feasible options for satisfying unmet demands (for example, in the Colorado River Basin, the <br />four projects listed are not likely to be suitable options for meeting the needs of Garfield and <br />Mesa Counties that make up the gap) illustrates the limitations of state-wide planning. <br /> <br />In addition, the fact that-the CWCB's SWSI team has shied away from tackling the most <br />contentious issues of new transbasin diversions, notwithstanding the legislative suggestion that it <br />should forge a state-wide consensus on projects, also reflects the problems with having a state <br />agency attempt to referee this type of dispute in the name of planning. <br /> <br />ll. Key Areas of Concern with the SWSI process <br /> <br />1. Inflated Demand Numbers: <br />SWSI needs to more thoroughly address the potential for implementation of cost effective water <br />conservation measures. If the demand projections do not accurately include adequate measures <br />of conservation and efficiency, the demand numbers will be exaggerated and unreliable for <br />planning purposes. For example, SWSI appears to be underestimating the potential of "active" <br />conServation programs, perhaps asa result of its reliance on cities" 1991 conservation plans, <br />many of which are inadequate and need to be strengthened due to their cost effectiveness, <br />renewed public interest in response to the drought and also as a result of new legislation. <br />Western Resource Advocates sent a letter to CWCB staff and consultants in April setting out the <br />information and analysis that supports this concern. <br /> <br />2. Satisfying Environ-mental and Recreational Demands: <br />Environmental and recreational interests believe that, at least by the time of the most recent <br />South Platte Roundtable meeting, we were finally beginning to communicate better with the <br />SWSI team on the issue of how to satisfy instream demands" For much of the SWSI effort to <br />date, there has been a misunderstanding between our conununities and the CWCB staff and <br />consultants. For the most part, we are not interested in having new single purpose projects built <br />to satisfy environmental needs.. Rather, we support integrated resource planning to incorporate <br />conservation, protection and restoration of healthy flow regimes in our rivers and streams into <br />the operations of existing and new projects built to satisfy other demands. Because instreatn <br />demands are non-consumptive,. in general it should be possible to achieve this goal by re- <br />operating as opposed to re-allocating water supplies. Identifying and promoting such <br />opportunities could be a valuable SWSI outcome. <br /> <br />3. Inclusion of environmental and recreation data and information: <br />Environmental and recreational interests, both on their own and through roundtable participants <br />have submitted significant information including: sources of data, documents, maps, proposed <br />frameworks for analysis, the ''CPR action planu delivered during the most recent roundtable <br />meetingst the Smart Supply and Smart Storage criteria and the Smart Water analysis from <br />Western Resource Advocates~ recent report of the same name.. While recently the consultants <br />have begun to reflect this information in their PowerPoint presentations and included these <br />proposals for discussion at the roundtable meetings, there are still- instances where this <br />information would be useful and should be included. We hope that inclusion will become the <br />standard in the future and look forward to seeing how our submissions will be incolporated into <br />the further analyses of options and alternatives. We are hopeful that our CPR action plan and <br /> <br />2 <br />