SouthPlatteComments04

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

(2) Maximize Efficient Use of Existing Supply~

This is an important objective, though it too has some limitations (for example~ the needs of those
who rely on irrigation return flows for their water supply must be addressed if those irrigation
uses are made more efficient and return flows reduced). That said, demand and supply side
measures to improve efficiency should be an important component of water planning for the
South Platte~

It may be worth mentioning under the subobjectives the idea of reducing "unaccounted for water"
in municipal systems (perhaps included with the evaporation and conveyance loss subobjective).
Colleagues at Western Resource Advocates advise me that UFW rates range from 5 to 15 percent
in Colorado, so there is meaningful potential for savings.

It may also be worth mentioning some examples of best management practices under the final
subobjective. Examples could include incentive programs such as rebates, water rate structures
that encourage conservation, water use audits, etc.

(3) Enhance Use of Existing System Assets.

The subobjective to maximize operations of existing facilities makes sense, but should be coupled
with a recognition of the range of goals for which operations can be made beyond traditional
water uses. For example, it may be desirable to maintain reservoir levels for boating use at
certain times, or to time releases to help fisheries at key periods. As an example, Denver Water
and Aurora have worked with the Division of Wildlife and conservation interests to develop a
plan for flow management on the South Platte below their major water supply reservoirs
(Spinney, Eleven Mile, Cheesman). A copy of this plan - which also should be considered in
looking at environmental demands on the South Platte River - is attached with this message.

(4) Maximize Implementability.

I'm not convinced that maintaining compliance with Compacts should be an objective. It is non-
discretionary, a "given" for anything that might be proposed and in that sense falls into a different
category from the desired conditions reflected by other objectives.

(5) Support Recreational Needs.

I would suggest modifying this objective to something along the lines of "support and enhance
recreational opportunities". Just as demands for urban water will grow over time, so too will
demands for water-based recreational opportunities. We should actively seek opportunities to
enhance recreation and not just support existing recreational uses~

(6) Provide for Environmental Protection.

Similarly to #5, this objective should be broadened to address environmental protection and
enhancement, and the first subobjective should look for ways to protect and enhance aquatic life.
Many waters in Colorado have experienced habitat loss and degradation, and where it is possible
to help restore some of what has been lost we should seize those opportunities. Because these
issues can inter-relate with existing projects as well as new projects, I would drop the word "new"
from the second subobjective~ I would also add the concept of mitigation (i.e~~ "Minimize and
mitigate environmental impacts associated with projectsn). While it is basically duplicative of my
suggestion under objective #1, I would suggest mentioning water supply specifically under this