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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 inflexible, singre-basin uses, and adverse <br />environmental impacts. ' <br /> <br />3. Disadvantaaes of Southern Deliver System 80S is economicalJy and <br />environmentally inferior, because this piperine pumping concept has no way to offset <br />escaJating_ energy costs over the Ijfe of the -project. If Colorado Springs had conducted <br />a preliminary seoping comparison of Union Park with Homestake II, SDS and, Pueblo <br />Reservoir Enlargement alternatives, as required by NEPA, it would have confirmed <br />Union Park's major economic and environmental advantages. With Union Park's <br />flexible gravity deliveriesj Co~orado Springs and other east and west slope water users <br />can expect assured water supplies with sign~ficant cost reductions, instead of <br />increases, throughout the new millennium. <br /> <br />44 50S is local. not reQional Colorado Springs claims its SOS pipeline proposal is a <br />regional water supply project, because it includes the City of Fountain and Security <br />Water District. In reality, SOS 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 water1" 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 all related cumulative actions in an EIS. The proposed <br />Pueblo Reservoir enrarg'ement is an integral and necessary part of the 8DS pipeline <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 />fJood~ earthquake, and structural risks for down stream lives and properties. Union <br />Park's much stronger concrete dam for up to 1.2 minion 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 construction 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 Cororado Springs' proposal for another pipeline from an enlarged Pueblo <br />Reservoir. These recently acquired municipal effluent reuse rights would further <br />deplete the seriousry overappropriated Arkansas River. Although legal, these <br />excessive depletion rights are similar to the environmental realities that eventuaUy <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 Coloradofs <br />undeveloped and wasted Aspinall 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. Co!orado's Supreme Court recently reconfirmed these <br />overlooked rights, when it ruled Arapahoe County IS Union Park AppUcation for new <br />water rights duplicated the unused Aspinall rights, that already exist for development of <br />high. multi-basin storagel In fact, the Bureau has patiently waited since1957 to <br />2 <br />