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Natural Energy Resources Company P. O. Box 567 Palmer Lake, CO 80133 (719) 481~2003 Fax (719) 481':'3452 RECEIVED NOV 1 9 2003 (j) . " Colorado Water Conservation Boara November" 13, 2003 ", ., . USBR~Eastern Colorado Area Office 11056 W. County Rd..18E Loveland, Colorado 8053 7 ~9711 Attn: Mr. Pat Mangan, EIS Coordinator Subject: Request for stay of Southern Delivery System Environmental Impact Statement Development Dear Mr. Mangan: Natural Energy Resources Company (NEeO) requests a stay of the proposed Southern Delivery System (SOS) Environmental Impact Statement (EIS) for Colorado Springs. National Environmental Policy Act (NEPA) regulations require early identification and correction of scoping flaws in the EIS process. The following fatal scoping flaws justify this stay request: 1. Union Park alternative oversight Colorado's Union Park high altitude pumped- storage water and power alternative was first proposed for both slopes by NEeO in 1986 (see Union Park Reconnaissance Evaluation Study by the major Ebasco and Black and Veatch engineering firms dated October 1986). Unfortunately, this superior state and regional water and power alternative has been improperly "overlooked" by local, state, and federal entities, because of misguided institutional and political constraints. Union Park will pump some of Colorado's undeveloped Colorado River Compact and Aspinall Pool losses into high, off-river storage from the Bureau of Reclamation's existing Taylor Park and Blue Mesa collection reservoirs during heavy runoff years. These conserved high quality flood waters will then be available for guaranteed deliveries by gravity, when and where needed, throughout five Southwestern river basins (Gunnison, Colorado, Platte, Arkansas, Rio Grande) during variable drought conditions. 2. Benefit-Cost Advantaaes of Hiah Altitude Reservoirs As a pilot high altitude storage project, that protects multiple basins, Union Park has major environmental and socio-economic advantages of national significance. In fact, this advanced pumped- storage drought insurance concept can be applied to substantially increase the productivity and quality of water and power resources from any high mountain western area that has glacier-carved reservoir sites and heavy snowfalls. Low value surplus power can be used to fill high, off-channel storage sites during heavy spring flood months. Valuable peaking power revenues from reversible punip- generators during high demand summer, fall, and winter months will off-set spring filling costs. Pumped-storage can also increase the efficiency and safety of traditional river dams throughout the West. Union Park's unprecedented 10 to 1 benefit-cost expectations will be especially valuable for protecting and enhancing Western farms, environments} and recreation interests that are threatened by explosive urban growth.