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2 2. Federal Purcbase Of Umised Gunnison Water Rights The Bureau's extensive Gunnison - Arkansas studies in the 1950's concluded that up to 450,000 acre feet could be exported from the Upper Gunnison without adversely impacting the basin's environmental and economic future. Since then, federal and state census data shows Upper Gunnison irrigated acreage has declined more than 30%. This continuing trend, coupled with water saving technology, indicates many senior water rights are now vulnerable to the use-it-or-lose-it laws of Colorado and the Colorado River Compact. Instead of farmers eventually losing their underused rights, the federal government should consider partial water right purchases to enhance endangered fish, Blue Mesa Reservoir levels, and Black Canyon flows. Participating Gunnison farmers and ranchers could use the funds to purchase modern irrigation systems that would conserve water and save their land from salt leaching with traditional deep irrigation methods. This water purchase alternative may also help solve the Colorado River salinity problem. 3. San Luis Valley Groand Water Senator Robert Pastore and others claim San Luis property owners are planning to pump non-tributary ground water into the Gunnison Basin for sale to California and Arizona cities. If the institutional hurdles could be overcome, this Gunnison River augmentation could help endangered fish and lower basin growth needs - without contributing to permanent loss of Colorado's renewable compact entitlements. 4. Colorado Aqueduct Return Protect (CARP) Under the CARP alternative, Colorado's unused Gunnison compact waters would flow uninterrupted to the Colorado state line. These waters would then be pumped via pipeline to Front Range growth areas. Although the concept would be a major consumer of energy, would have no carryover storage, and would be subject to shut down during droughts it should be evaluated as the alternative preferred by the locally influential Gunnison activist group called POWER (People Opposed To Water Export Raids). Invalid Sopping Process It appears your EIS scoping process is not valid under NEPA rules, because your specific Blue Mesa Reservoir release schedules for endangered fish are not available for public evaluation. To assure a valid EIS, I strongly recommend deferral of the formal scoping until the desired Gunnison flow regime is sufficiently defined for detailed analysis. On the surface, if one or more of the above alternatives are not used, a return to Gunnison native flows would destroy Colorado's compact rights and the Upper Colorado Basin's ability to meet Lower Basin calls in droughts. Thank you for your considerati n. S' cerely Dave Miller Western water strategist ADM/bm cc: Secretary Lujan, Governor Roy Romer, U.S. Fish and Wildlife Service, Upper Gunnison River Water Conservancy District, Colorado River Water Conservation District, Colorado Congressional Delegation, Colorado legislators, Arapahoe County.