SouthPlatteComments04

• Basin: South Platte
• Title: Comments 4
• Date: 10/31/2003
• SWSI - Doc Type: Comments

October 31, 2003

To~ Rick Brovm, Susan Morea
From: David Nickum, Colorado Trout Unlimited - South Platte Environmental Roundtable Rep
Re: Objectives and subobjectives

This comes in response to your request for feedback on the objectives and subobjectives for
SWSI in the South Platte basin by October 31. In preparing these comments, I've given the draft
document a good bit of thought and gotten input from a few other South Platte basin conservation
interests~ If you have any questions regarding the comments, please call me at 303-440-2937
x12. Thanks for the opportunity to participate~

(1) Reliably Meet Demands~

While the general thrust of this objective is clear, what it means in practice is not. What level of
reliability is needed and under what hydrologic conditions? For example, the mention of
minimizing restrictions on urban use begs the question: is the goal to have sufficient water supply
to weather a 300-year drought like the one we've just been through (and may still be in) without
any use of demand management strategies? If so, that would require an enormous amount of new
development with major economic and environmental costs. In reality, the degree of reliability
sought must be balanced with the economic and environmental costs associated with the facilities
that would be needed to provide supplies in the relatively infrequent severe drought periods. And
different uses will have different acceptable levels of reliability. Basic domestic use needs a very
high level of reliability. Lawn irrigation can accept a lower level of reliability~ Of course, there
n1ust be contingency plans for severe drought periods - but those can and should rely on
measures to reduce demand, to shift water through interruptible supply agreements, etc.

I have the same concern with the "reliably meet ~.. agricultural water demands" subobjective, and
would emphasize that this objective actually runs counter to one measure that may make a great
deal of sense for the South Platte - interruptible supply agreements between agricultural and
urban users. Such agreements would not meet ag demands in a drought, but instead would
redirect water to urban uses during drought periods in exchange for cash payments~ This
approach offers promise as a strategy for addressing dry~year shortages of urban water without
having agricultural land removed permanently from production, as has happened in many areas.

The more general objective of providing water "for agriculture and recreation" should be
broadened to also include "environmental needs" (such as fisheries, riparian habitat, etc.) While
the environment is mentioned under another objective~ I think it is important to address it
alongside other water demands. I think the SWSI process will work best if it factors in the
environment as a demand element just as urban and ag and recreation are considered. That may
open up many great possibilities for creative "win-win" efforts that would be overlooked if the
environment is considered only in terms of how it might constrain water development.

Identifying and quantifying environmental demands will be a critical task within the SWSI For
consideration, I attach letters (from Bob Weaver and John Gerstle and from Jennifer Pitt)
outlining some reasonable approaches for that effort.

I was pleased to see you include the reference to sustainability as a subobjective. While
non tributary groundwater can and should be part of responsible water development, it IS not a
replacement for sustainable water supplies.