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<br />The Structure Design section of the REP Report does not provide any information or analysis of <br />the minimum flow necessary for a reasonable recreation experience, nor any level of experience. <br /> <br />SECTION 2.C. NECESSARY FLOWS <br />The REP Report (pages 34 - 41) describes the "necessary flows" for various types of boating <br />experiences. Tables 1 and 2 (pages 34 and 35) of the REP Report provide what is listed as <br />"Minimum flow regime for the upper structures (Table 1) and lower structures (Table 2) of the <br />Durango Boating Park to provide for the intended use." Just because a table is entitled <br />"minimum", does not demonstrate that the listed flows are actually the minimum because the <br />REP Report has not provided any information nor analysis to determine what the minimum flow <br />necessary for reasonable recreation experience might b(:. <br /> <br />The flows in Tables 1 and 2 were not selected based on the actual design of the U-Structures but / <br />on water availability, as described (Page 37): V <br /> <br />"Available flows: The flows selected were chosen such that ample flow could be <br />available for other users and such that ample flow would be provided for the <br />intended purpose listed in Table 1." <br /> <br />This statement clearly describes that the selected flows were not based on the minimum amount <br />needed for the intended purposes but on "ample flow" lor the intended purpose. <br /> <br />While the REP Report uses the word "minimum" to describe the selected flows, it does not <br />provide any basis for concluding that the RICD water right is the minimum flow necessary for a <br />reasonable recreation experience; in fact, clearly states the flows were selected to be ample. <br /> <br />SECTION 3 <br />SUMMARY OF REASONS THE RICD APPLICATON SHOLD BE DENIED <br /> <br />The REP Report is deficient in providing technical information to support the Durango RICD <br />water right application for the following reasons: <br /> <br />1) The design criteria for the three boating user groups do not describe the minimum flow <br />necessary for a reasonable recreation experience. <br /> <br />2) The U-Structures to control, capture and divert the mlmmum flow necessary for a <br />reasonable recreation experience are not specific designs, but only approximate designs. <br />Such structures need to be designed first, with the water rights application based on that <br />design. Durango's approach was to determine flows based on water availability and <br />ignore the important relationship of the structure design to flows. <br /> <br />3) Tables 1 and 2 do not provide supporting information to demonstrate that the listed flows <br />are the minimum necessary for a reasonable recreation experience for each boating <br />category. For instance, could 800 cfs provide just as good a recreation experience at <br />structure #5 as 1,400 cfs in June? No such analysis exists in the REP Report. <br />