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<br />As a comparison, most traditjonal dams on rivers were built with only 2 to 1 benefit...cost <br />expectationst because of their limited and infJexiblet single-basin uses~ and adverse <br />envjronmentaJ impacts. <br /> <br />3. Disadvantaaes of Southern Deliver System SDS is economically and <br />environmentally inferior, because this pipeline pumping concept has no way to offset <br />escalating energy costs over the life of the .project~ Jf Colorado Springs had conducted <br />a preliminary seoping comparison of Union Park with Homestake I r J SDS and I Pueb'lo <br />Reservoir Enlargement alternatives, as required by NEPA, it wourd have confirmed <br />Union Park's 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 expec~ assured water suppries wjth significant cost reductions, instead of <br />increases, throughout the new millennium~ <br /> <br />4. 50S is local. not regional Colorado Springs claims its 8DS pipeline proposal is a <br />regional water supply project, because it includes the City of Fountain and Security <br />Water District. In realitYJ 80S is an insular concept that excludes consideration of the <br />renewable water needs of EI 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 stakehoJders throughout both sides <br />of the Divide. <br /> <br />5. Pueblo Reservoir enlaraement and dam safety concerns NEPA regulations require <br />concurrent evaluations of all related cumulative actions in an ElS. The proposed ' <br />Pueblo Reservoir enlarg"ement is an integral and necessary part of the SDS,pip.etine <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 />(PMF). 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 />Parkts much stronger concrete dam for up to 1 ~2 million acre-feet of storage could help <br />extend the life of Pueblo Reservoir and other marginal storage facilities that are unsafe <br />under today's constructjon standards (see enclosed Ueblacker Associates letter to <br />Governor Owens, dated October 20, 2003). Pueblo Reservoir's enlargement and <br />safety problems must be included in the 80S EIS to avoid a serious violation of NEPA <br />rules. <br /> <br />6. Comparison of water riahts Environmentally unsound water'rights 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 legall these <br />excessive deple~ion rights are similar 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 />undeveloped and wasted Aspinall Pool entitlements from the Bureau of Reclamation for <br />a nomin?ll 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 AppJication for new <br />water rights duplicated the unused Aspinall rights; that already exist for development of <br />high, multi-basin storage. In fac~, the Bureau has patiently waited since1957 to <br />2 <br />