Case No. 02CW038 Statement of Opposition (2)

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Added Note For Colorado Leaders Suggest similar actions as a public service for current and future generations. DISTRICT COURT, WATER DIVISION 4, COLORADO •&A-11 Case No. 02CW038 STATEMENT OF OPPOSTION CONCERNING UPPER GUNNISON RIVER WATER CONSERVANCY DISTRICT APPLICATION FOR SURFACE WATER RIGHTS FOR RECREATIONAL IN- CHANNEL USES IN GUNNISON COUNTY 1. Name, Mailing Address, Telephone Numbers of Obiector: Natural Energy Resources Company c/o Allen D. (Dave) Miller, President P. O. Box 567 Palmer Lake, Colorado 80133 (719) 481 -2003, Fax (719) 481 -3452 2. Facts as to why the Application should not be granted or why it should by granted onlv in part or on certain conditions: a. The minimum in- stream flow amounts requested for Applicant's Gunnison River Whitewater Boating Course are excessive for a reasonable recreational experience; b. The proposed recreational flow volumes would impair Colorado's ability to store its unused Colorado River entitlements at high altitude during wet cycles for flexible gravity distribution to Gunnison, Colorado, South Platte, Arkansas, and Rio Grande River Basins, when needed during the destructive drought cycles; c. The largely untapped drainage area above the Gunnison Whitewater Boating Course is Colorado's largest and highest undeveloped Colorado River water source; d. The near and long -term opportunity costs associated with loss of Colorado's Upper Gunnison High Altitude Reservoir Capability (HARC), could amount to many billions of dollars, as compared to the state's alternative Colorado River development alternatives; e. Implementation of Applicant's proposed boating decree would seriously damage Objector's conditional 82CW340 right to fill and refill the Union Park Reservoir site for hydropower and river regulation purposes. (The river flow regulations in 82CW340 were set by local Upper Gunnison interests to enhance local fishing, boating, and irrigation needs during flood and drought conditions);