Laserfiche WebLink
<br />:..; <br /> <br />SWSI Comments For the San JuanIDolores Basin <br />11/3/03 <br />Peter Butler, Ph.D" <br /> <br />My comments are broken into five short sections: <br />o Representation <br />o Methodology <br />o Coal-Bed Methane Production Water <br />o SWSIObjectives <br />o SWSI Basin Fact Sheet <br /> <br />Representation <br /> <br />I am dismayed that nobody appointed to the round table represents boating (rafting, <br />canoeing, and kayaking) interests. There are four rivers in our basin that are <br />commercially rafted: the Animas, San Juan, Piedra, and Dolores4 The Animas River is <br />the third most commercially rafted river in the state. Only the Arkansas and the Colorado <br />see more traffic. The Cache la Poudre is a close fourth to the Animas. (See the attached <br />file from the Colorado Outfitters Association.) There are at least a dozen commercial <br />rafting companies in the basin. In addition to the approximately 30,000 commercial <br />rafting days on the Animas, the Bureau of Reclamation estimates in their Animas-La <br />Plata EIS that there are 40,000 to 80,000 private user days on the river. (A-LP FSEJS Jury <br />2000 ?g 3-180 (in section 3.11 on recreation impacts)) <br /> <br />Out of the hundreds or maybe thousands of boaters in the Basin, I cannot believe that not <br />one of them was appointed to the round table4 (I know of one very qualified person who <br />was nominated but not appointed~) This is a gaping hole in your representation structure. <br /> <br />Methodology <br /> <br />As I'm sure you've heard from other commentators, using current decreed in-stream <br />flows underestimates the environmental demand. There are a number of rivers and <br />streams that have no decreed in-stream flows that are dried up by diversions~ The lack of <br />an in-stream flow right doesn't mean that there isn't any environmental demand to keep <br />at least some water in the stream. In addition, there is no accounting for the <br />environmental demand of occasional large flushing flows+ <br /> <br />Your methodology further compounds the problem of underestimating the demand for in- <br />stream flows by assuming this demand will remain constant in the face a growing, <br />amenity-driven population4 At the same time, your methodology assumes that <br />agricultural demand will remain constant over the next thirty years) yet much of the <br />agricultural land in the Basin will end up sub-divided to acconunodate population <br />growth. <br />