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<br />As a comparison, most traditional dams on rivers were built with only 2 to 1 benefit..cost <br />expectations, because of their limited and inflexjbleJ single-basin uses, and adverse <br />environmental impacts. <br /> <br />3.. Disadvantages of Southern Deliver System 80S is economically and <br />environmentaJly inferior, because this pipeline pumping concept has no way to offset <br />escalating energy costs over the Ijfe of the -project. If Colorado Sprjngs had Qonducted <br />a preliminary seoping comparison of Union Park with Homestake III SDS and, Pueblo <br />Reservoir Enlargement alternativesJ as required by NEPA, it would have confirmed <br />Unton ParkJs major economic and environmental advantages. With Union Park's <br />flexible gravity deliveries, Colorado Springs and other east and west slope water users <br />can expect assured water suppries with significant cost reductjons, instead of <br />increases, throughout the new millennium. <br /> <br />4. 50S is local, not regional Colorado Springs crajms its SDS pipeline proposal is a <br />regional water supply projectl because it includes the Cay of Fountain and Security <br />Water District~ In reality, 80S is an insuJar concept that excludes consideration of the <br />renewable water needs of EJ Paso County, South Metro Denver, east slope farming, <br />Kansas, Nebraska; endangered species! etc., as required by NEPA. In contrast, Union <br />Park is an integrated statewide and regional water,' power, and drought insurance <br />project. It can efficiently assure low cost water and power supplies, and high quality <br />drought insurance, for city, farm, and environmental stakeholders throughout both sides <br />of the Divide. <br /> <br />5. Pueblo Reservoir enlaraement and dam safety concerns NEPA regulations require <br />concurrent evaluations of aJl related cumuJative actions in an EIS. The proposed <br />Pueblo Reservoir enlarg'ement is an integral and necessary part of the SDS.pip-eline <br />proposal. Recent Bureau of Reclamation and Black and Veatch Engineering studies <br />indicate Pueblo Dam can not be modified to safely pass the probable maximum flood <br />(PM F). Additional studies may find Pueblo's enlargement would increase its existing <br />flood, earthquake, and structural risks for down stream lives and properties. Union <br />Park's much stronger concrete dam for up to 1.2 million acre-feet of storage courd help <br />extend the life of Puebro Reservoir and other marginal storage facilities that are unsafe <br />under today)s construction standards (see enclosed Ueblacker Associates letter to <br />Governor Owenst dated October 20, 2003)~ Pueblo Reservoir's enlargement and <br />safety problems must be included in the SOS EIS to avoid a serious violation of NEPA <br />rules. <br /> <br />6. Comparison of water riahts Environmentarly unsound water"rjghts are the driving <br />force behind Colorado Springs' proposal for another pipeline from an enlarged Pueblo <br />Reservoir. These recently acquired municipal effluent reuse rights would further <br />deplete the seriously overappropriated Arkansas River. Although legal, these <br />excessive depletion rights are simifar to the environmental realities that eventually <br />defeated Two Forks and Homestake II for Denver, Aurora! and Colorado Springs. In <br />contrast, Union Park participants can purchase up to 300,000 acre-feet of Colorado's <br />undevelope9 and wasted AspinaU Pool entitlements from the Bureau of Reclamation for <br />a nominal fee. Congress authorized the Aspinall Pool water rights in 1957 for <br />Colorado's statewide needs. Colorado's Supreme Court recently reconfirmed these <br />overlooked rights, when it ruled Arapahoe County's Union Park AppHcation for new <br />water rights dupljcated the unused Aspinall rights, that already exist for development of <br />highj multi-basin storage. In fact, the Bureau has patiently waited since1957 to <br />2 <br />