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<br />... --0- ..L .........L .J <br /> <br />o <br /> <br />Gilbert, Hanna <br /> <br />From: David Nickum IDNickum@tu.org] <br />Sent: Friday, December 12, 2003 4:40 PM <br />To: SWSI (Statewide Water Suppfy Initiative) <br />Cc: rick.brown @ state.co.us <br />Subject: South Platte comments <br /> <br />General comment I remain interested in seeing what other advisors have to say in their comments and in <br />knowing what studies they submit for review on demands, projects, etc. ..... it w~1I be easier to reach understanding <br />of different points of view. and hopeful~y find some common ground, if there is a greater exchange of info among <br />the roundtable than just one meeting every three months. Perhaps some sort of listserv program would work to <br />allow materials to be shared across the roundtable as a whole, or comment summaries can be developed and <br />d istri b uted. <br /> <br />I will be able to attend the February meeting. <br /> <br />OBJECTIVES <br />On the objectives, I suggest that either water demands are a~llumped together (i.e., "Sustainably Meet M&I, <br />Agriculturalt Recreational, and Environmental Demands") if there is a compelling need to treat it as a single <br />objective or e~se that each be fisted individually.... with an objective for meeting M&I demands, one for ag, one for <br />rect and one for environment (I think the latter approach makes more sense, since the nature, timing, and <br />elasticity of demand are quite different for each of the four types of use). Either way, each demand shou1d be <br />described in parallel Janguage. I'm concerned that environmentaJ water is described in terms of "leaving" <br />adequate water when and where needed, while other uses are descrjbed as "meet demand" or "provide waterU~ <br />Words mattert and the current wording seems to reflect a mindset of environmental demands being constraints <br />rather than being uses that benefit Colorado and its citizens) like any other uses. In some cases, it may be <br />possible for a project to provide water to meet environmentaf demands through operations and not just by <br />uleaving't water for the environment. And of course, water that is being delivered for other uses can also serve <br />environmental purposes while on its way to lts ultimate destination. I suggest that you change the wording on <br />these objectives so that each are described in parallel language - along the lines oft "provide water to meet <br />(AG/MUNI/REC/ENV) demands when and where needed". <br /> <br />Under the first objective, is it not important to meet M&I demands in normal and wet years - not just in drought? <br />Also, by Umeet M&I demands during drought'J do you mean to suggest that this would be done with no demand <br />management programsJ which municipafities generally use as part of their drought response? If that is the intent, <br />it should be changed. <br /> <br />Under the environmental objective, I would again urge you to drop the word "newu in the second subobjective~ <br />Since we are looking at goals (this isn't a regulatory process}J it makes sense to consider opportunities to reduce <br />or mitrgate impacts of existing projects as well as new projectst especially since the two will often be interrelated~ <br />Just because some impacts are already happening doesn't make jt any less desirable to address them where we <br />have opportunity to do so. <br /> <br />Under cost effectivenesst I'm concerned about uachieve benefits at lowest cost,t - sometimes the best course may <br />not be the cheapest one. If by "cost" you mean the full range of costs (direct financial costt environmental costs, <br />opportunity costs, etc.) this is more palatable, but lt should not be based on financial costs alone. Also, the <br />subobjective to "mitigate for third-party economic impacts" should be rephrased to "mitigate for third-.party <br />impacts" - not all impacts of concern are economic. <br /> <br />I was pleased to see the encouragement for conservation, reuse and wise use of existing supplies under objective <br />2~ The phrase "non-beneficial consumptionU may be poor wording for the concept of water efficiencYI however. <br />For examplet wetlands vegetation consumes water and is not a beneficial use under Jaw - but we certainly don't <br />want to (nor could we legally) make a statewfde campaign to eHminate aU wetlands. Or did you mean to address <br />non-beneficiaf diversion, rather than consumption? And it would be nice to see the word "efficiencyU somewhere <br />in the objective, since that ;s the underlying concept. UOptimizeU is not a clear term since we do not define what <br />"optimumtt conditrons are. <br /> <br />3/8/2004 <br />