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in the formulation of any administrative plan for controlling groundwater overdraft in the Closed <br />Basin. <br />The Association is concerned about the long-term viability of the Closed Basin Project. <br />Mechanical problems continue to plague the project, reducing its benefits to Colorado and the Rio <br />Grande. From time to time, there have been suggestions from New Mexico and Texas that the <br />Closed Basin Project should be used to alleviate water shortages or to solve environmental <br />problems in those states. The Association opposes the use of Closed Basin Project water for <br />anything except assisting Colorado to meet its Compact obligations. <br />With respect to the confined aquifer, the Association believes that there is a great lack of <br />knowledge about this aquifer and its connection, if any, to the surface flows of the Rio Grande <br />and the Conejos River. The extent and location of stream depletions to the Rio Grande and <br />Conejos Rivers from confined aquifer diversions is a very contentious issue that was laid aside by <br />the agreement allocating the yield of the Closed Basin Project. If allocation of those depletions <br />between stream systems is made an issue in the RGDSS, then the cooperative nature of and <br />public support for RGDSS may be lost. <br />The Association believes that helpful but limited new information about the confined aquifer will <br />be obtained from the RGDSS drilling program. Therefore, the Association believes the RGDSS <br />modeling effort must recognize these data limitations and not make assumptions that are not well <br />supported by site-specific data. This is particularly important for the extent and location of <br />connections between the confined aquifer and surface streams. Until a good deal more data is <br />collected, there is simply not be enough data to make an accurate assessment of the exact location <br />of that connection and the quantity of any resulting stream depletions. The data gathered from <br />the RGDSS, however, should enable the water-user community to assess the magnitude of impact <br />of substantial new groundwater development from the confined aquifer, and decide if such <br />development is feasible without injury to other water users. <br />The Association's experience with models makes it skeptical about the accuracy and reliability of <br />surface and groundwater models in the San Luis Valley for administrative purposes. Part of this <br />is due to the inexact nature of modeling, part is due to the lack of sufficient data to accurately <br />model the system, and part is due to the continued repackaging of past models into new, but no <br />more reliable, models. The Association would rather see no model than a model using <br />undocumented or poorly documented assumptions that could profoundly change groundwater <br />administration throughout the San Luis Valley. <br />The Association is participating in the technical subcommittee for the RGDSS and has hired <br />highly respected consultants to help it evaluate and provide input on the accuracy and reliability <br />of both the underlying data and the modeling done for the RGDSS. The Association wants the <br />RGDSS to result in a useful tool for better decision making for water resources in the Rio Grande <br />Basin. The Association does not believe, however, that sufficient data is currently available or <br />will be generated by the current RGDSS findings to allow the RGDSS to be used for any water <br />rights decision making requiring a high degree of site-specific accuracy. Accordingly, the <br />Association recommends that the RGDSS be considered as an evolving tool, not aone-time <br />product. Until more data is collected, the RGDSS should be viewed as a means to help make <br />basin-wide assessments and decisions. As more data is gathered for specific areas, the use of the <br />RGDSS can be refined accordingly. <br />The greatest threat to the success of the RGDSS is that its reliability will be overstated and its <br />results will be misused. To avoid this, the inherent limitations of the RGDSS must be recognized <br />C:Acdss\RGWUA3.doc Rio Grande Water Users Association Interview June 21, 1999 -Page 6 of 9 <br />