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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, single-basin uses, and adverse <br />environmental impacts. <br /> <br />3. Oisadvantaaes of Southern Deliver System SOS 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. If Colorado Springs had conducted <br />a preliminary scoping comparison of Union Park with Homestake II, 80S 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 deliveries, Colorado Springs and other east and west slope water users <br />can expect assured water supplies with significant cost reductions, instead of <br />increases, throughout the new millennium. <br /> <br />4. 50S is local, not reaional 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, 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 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 E18. The proposed <br />Pueblo Reservoir enlarg"ement is an integral and necessary part of the SOS pipeline <br />proposal. Recent Bureau of Reclamation and Black and Veatch Engineering studies <br />ind icate 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 />Park's 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 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 SOS EIS to avoid a serious violation of NEPA <br />rules. <br /> <br />6. Comparison of water riahts Environmentally unsound watenights 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 legal, these <br />excessive depletion 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 nominal 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 Application for new <br />water rights duplicated the unused Aspinall rights, that already exist for development of <br />high, multi-basin storage. In fact, the Bureau has patiently waited since1957 to <br />2 <br />