ArkansasComments33

• Basin: Arkansas
• Title: Comments 33
• Date: 9/1/2004
• SWSI - Doc Type: Comments

Biological issues, comment to SWSI, August 2004

1

Biological Considerations for Water Transfer Planning
A comment to the SWSI, August, 2004 .
John Wiener [e-mail]; 303.492.6746; Campus Box 468, University of
Colorado, Boulder, CO 80309.0468), writing solely as an individual.

The reason for these comments (3 pages of notes; annotated references following):

It is not apparent to an outside observer than anyone is charged to take an overview of the range
of potential consequences of the coming large.scale water transfers. It is an historical outcome
that water policy based in market allocation and traditional water law has resulted, so far, in
Ksegmentation of analysisK. That is. when a broad policy is implemented in small increments,
analysis of any given increment may overlook cumulative and synergistic impacts resulting over
time and in summation. The simple example is environmental impact analysis of only a mile of
road at a time, where there will be a network of many miles and many roads in tota!. Because
transfer has been by markets in private property, no planning or evaluation criteria have been
generally developed or accepted. Encountering critical thresholds of cumulative impact can be
expensive and responses can be slow (Platte River Recovery Program DE IS, Freeman 2003).

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Therefore, it is my intent to .put some issues on the table", without intent to disparage the work
done and underway. Rather, I hope this will help the SWSI groups with their discussion, and
perhaps help the Water Conservation Board consider further staff and interagency investigations
of these issues. And, I hope that public interests may be better identified and better served,
perhaps through opportunities for private contributions, and perhaps targeted support for
contributions such as conservation easements. Private support for public benefits may be
surprising, and should certainly not be sought only from the agricultural and rural people most
likely to be impacted by the coming water transfers; everyone, including the urban and suburban
population, benefits from externalities now provided by water distribution. The Water
Conservation Board staff will surely take the lead in these issues, given its role and evolution of
expertise with in-stream flow issues, and it is hoped that this comment will support such work.

Since the social and economic issues involved with moving water from agricultural uses have
been raised, this comment is directed to support of a "biological alternativeK, in which the
productivity of the environment is the thing to be maximized. Such an alternative would be
valuable to help avoid inadvertently or unknowingly reaching some critical threshold, and to know
how well this alternative matches other alternatives. These comments do not duplicate previOUS
comment on other subjects.

These comments are in three parts: (1) Two pages of very brief discussion of themes that
emerged from a survey of scientific literatures; (2) the bibliography from the survey; and (3) a set
of annotations on the references, for interested readers, and a few additional remarks.
The following 'hemes. emerged from survey of some of the literature. The annotations provide
explanation of sources.

Theme: The Big Picture is Missing

Too much has been changed already in the Eastern Plains of Colorado to presume we know
much now. or can easily foresee consequences of more dramatic change from changes in water
management, agricultural pOlicy. or crmate variation. Extreme losses of wetlands, drastic
declines in plains fishes and birds, loss of native grasslands, and a great deal of research at
scales of better value to science than management leave us in a difficult position. There are
continental scale estimates, and micro-scale research, but regionally, little in the way of a .big
picturen helpful for identifying thresholds, avoiding problems, or anticipating consequences.
Agriculture accounts for well over 85 percent of consumptive use of water, but there is almost
nothing on ditches and canals as part of the environment, or as partial substitute for converted
and drained riparian and wet lands of all sorts. This is especially problematic for Colorado since
there is regional research on the few remaining prairie potholes to the north, and the few
remaining playas and depressional features to the south; in the middle, there are rivers and
distributional features, beyond the foothills, and research on the natural but not much on the