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<br />o 1'1 <br /> <br />Natural Energy Resources Company <br />P. O. Box 567 Palmer Lake, CO 80133 <br />(719) 481-2003 Fax (719) 481 ~3452 <br /> <br />RECEIVED <br />NOV 1 9 2003 <br /> <br />Oclorado Wa1er Conservation Board <br /> <br />'-, Novem'bero13, 2003 <br /> <br />USBR~Eastern. Colora~_o Area Office <br />11056 W.'Co~nty"Rd.o18E <br />Loveland, Colorado 80537 -9711 <br />Attn: Mr. Pat Mangan, EIS Coordinator <br /> <br />Subject: Request for stay of Southern Delivery System <br />Environmental Impact Statement Development <br /> <br />Dear Mr. Mangan: <br /> <br />Natural Energy Resources Company (NEeQ) requests a stay of the proposed Southern <br />Delivery System (80S) Environmental Impact Statement (EJS) for Colorado Springs. <br />National Environmentar Policy Act (NEPA) regulations require early identification and <br />correction of seoping fraws in the EIS processl The following fatal seoping flaws justify this <br />stay request: <br /> <br />1. Union Park alternative oversiaht Colorado's Union Park high altitude pumped- <br />storage water and power alternative was first proposed for both slopes by NEeO in <br />1986 (see Union Park Reconnaissance Evaluation Study by the major Ebasco a"nd <br />Black and Veatch engineering firms dated October 1986). U nfortunately ~ this superior <br />state and regional water and power arternative has been improperly uoverlookedt' by <br />local, state, and federal entitiesr because of misguided institutional and political <br />constraints. <br /> <br />Union Park will pump some of CoJorado's undeveloped Colorado River Compact and <br />Aspinall Pool losses into high! off-river storage from the Bureau of Recramation's <br />existing Tayror Park and Blue Mesa collection reservoirs during heavy runoff years. <br />These conserved high quality flood waters will then be available for guaranteed <br />deliveries by gravity, when and where needed, throughout five Southwestern river <br />basins (Gunnison, Colorado, Platte, Arkansas, Rio Grande) during variable drought <br />conditions. <br /> <br />2~ Benefit-Cost Advantaaes of Hiah Altitude Reservoirs As a pilot high altitude <br />storage project that protects multiple basins, Union Park has major environmental and <br />socja-economic advantages of national sjgnificance~ In fact, this advanced pumped- <br />storage drought insurance concept can be applied to substantially increase the <br />productivity and quality of water and power resources from any high mountain western <br />area that has glacier-carved reservoir sites and heavy snowfalls. <br /> <br />Low value surplus power can be used to fill high, off-channel storage's'ites during heavy <br />spring flood months. Valuable peaking power revenues from rev~rsjb]e pUfYlP- . <br />generators during high demand summer, fall, and winter months will off-set spring filling <br />costs. Pumped-storage can also increase the efficiency and safety of traditjonal river <br />dams throughout the West Union Park~s unprecedented 10 to 1 benefit-cost <br />expectations will be especially valuable for protecting and enhancing Western farms, <br />environments, and recreation interests that are threatened by explosfve urban growth. <br />