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<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 />(3)- <br /> <br />, ~ <br /> <br />OoJorado VVat!r ConseJVation Boare <br /> <br />, - November" 13, 2003 <br /> <br />USBR~~astern, Colora~o Area Office <br />11056 w. Co~nty..Rd.,18E <br />Lovelarid, Colorado 80537~9711 <br />Attn: Mr. Pat Mangan, EIS Coordinator <br /> <br />.~ ~ . ~... <br /> <br />Subject: Request for stay of Southern Delivery System <br />Environmental Impact Statement Development <br /> <br />Dear Mrll Mangan: <br /> <br />Natural Energy Resources Company (NECO) requests a stay of the proposed Southern <br />Delivery System (80S) Environmental Impact Statement (EIS) for Colorado Springs. <br />National Environmental Policy Act (NEPA) regulations require early identification and <br />correction of seoping flaws in the EIS process. The foUowing fatal scoping flaws justify this <br />stay req uest: <br /> <br />1. Union Park alternative oversight Colorado's Union Park high altitude pumped- <br />storage water and power alternative was first proposed for both slopes by NEeD in <br />1986 (see Union Park Reconnaissance Evaluation Study by the major Ebasco a-nd <br />Black and Veatch engineering firms dated October 1986)~ Unfortunately, this superior <br />state and regional water and power alternative has been improperly 'loverlooked" by <br />local, state, and federal entitiest because of misguided institutional and poUtical <br />constraints. <br /> <br />Union Park will pump some of Colorado's "undeveloped Co~orado River Compact and <br />Aspinall Pool losses into high, off-river storage from the Bureau of Reclamation's <br />existing Taylor Park and Blue Mesa collection reservoirs during heavy runoff years. <br />These conserved high quality flood waters will then be available for guaranteed <br />deHveries by gravity, when and where needed, throughout fjve Southwestern river <br />basins (Gunnison, Colorado, Platte, Arkar1sas, Rio Grande) during variable drought <br />conditions. <br /> <br />2. Benefit-Cost Advantaaes of High Altitude Reservoirs As a pilot high altitude <br />storage project, that protects multiple basins, Union Park has major environmental and <br />socia-economic advantages of national significance~ ]n fact, this advanced pumped- <br />storage drought insurance concept can be appJied 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 snovvfalls. ' <br /> <br />Low value surplus power can be used to fiJJ high, off-channel storage's"ites durin'g heavy <br />spring flood months. Valuable peaking power revenues from reversible pu_mp- . <br />generators during high demand summer, faIt and winter months will off-set sprfng filling <br />costs. Pumped-storage can also increase the efficiency and safety of traditional river <br />dams throughout the West. Union Park's unprecedented 10 to 1 benefit-cost <br />expectations wiJl be especially valuable for protecting and enhancing Western farms, <br />environments, and recreation interests that are threatened by explosive urban growth. <br />