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It should be noted that the following discussion addresses the merits of projects on a conceptual <br />level only. Virtually all new water supply development projects will have some level of project - <br />specific environmental and recreational impacts. Identification or discussion of such project - <br />specific impacts is beyond the scope of this document, but we assume that all projects will meet <br />the conditions of the Platte River Cooperative Agreement and the Colorado River Recovery <br />Implementation Program. <br />1. Arkansas Basin <br />There are several commendable aspects to the Preferred Storage Options Plan (PSOP) process in <br />the Arkansas basin, as conducted by the Southeastern Colorado Water Conservancy District and <br />water users within the District. From an in -basin perspective, the process has been open and <br />inclusive, it has taken into account the effects of some level of water conservation, and its <br />analysis of structural alternatives has generally been sensitive to environmental, recreational and <br />agricultural values. The storage options that have emerged from the process are focused on re- <br />operation of existing Frying Pan - Arkansas project reservoirs and enlargement of Pueblo <br />Reservoir rather than construction of new reservoirs. <br />However, the total identified storage need of 122,000 acre -feet appears to be significantly <br />overstated for several reasons. First and foremost, this amount of storage need is based on <br />growth projections and associated water demands that were described in the PSOP itself as <br />"high" and "optimistic" even in the context of the late 1990's economic boom when they were <br />made. No analysis was made of storage need based on more realistic projections, and it is likely <br />that a realistic storage need would be much smaller. Second, 15,000 acre -feet of this total <br />122,000 acre -foot amount is earmarked for meeting a mixture of agricultural needs and <br />facilitating interruptible supply arrangements between farmers and cities. The agricultural need - <br />based portion of this 15,000 acre -feet storage volume is questionable on economic grounds, <br />while the municipal portion appears to be duplicative of cities' individual storage needs, which <br />comprise the remaining 97,000 acre -feet. Third, the PSOP modeling analysis did not justify <br />29,000 acre -feet of the 97,000 acre -feet of the new storage individual cities claim to need. Thus, <br />almost one quarter of the `need' warrants further scrutiny. Finally, the PSOP should be <br />expanded to incorporate Aurora's need to maximize the delivery of its already acquired Arkansas <br />basin irrigation rights to its service area. While Aurora may be seen as an "outsider" from the <br />Arkansas basin's internal perspective, this view does not justify the risk of increased expenditure <br />of public resources to build duplicative facilities. <br />Additional transfers of water from agriculture to cities are likely to continue given the large <br />disparity between the values of water for agricultural versus M &I use, and the increased <br />financial pressures placed upon both sectors. However, additional transfers should focus on <br />cooperative arrangements with farmers and farming communities that reasonably mitigate local <br />economic impacts, even in the case of outright acquisitions. <br />2. South Platte Basin — Southern Portion <br />It is clear that the southern portion of the metro Denver area should not grow in population from <br />200,000 to over 600,000 while continuing to rely almost exclusively on groundwater pumped <br />44 <br />