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E <br />RPI Inc. <br />rr� <br />l� <br />February 2, 2007 <br />Cathy Metz <br />City of Durango Parks and Recreation <br />2700 Main Ave. <br />Durango, CO 81301 <br />Rebuttal Report for City of Durango RICD Water Right Application <br />Evaluation Summary <br />PO Box 2692 <br />Durango, CO 81302 <br />(970) 382 -9886 <br />RPI has received the Expert Report for the Opposers prepared by Steven C. Harris ( "Harris <br />report ") and has evaluated portions of it using the best available demographic, economic, and <br />land use data and employing accepted methodologies. The evaluation summarized in this <br />report focuses on the justification for the conclusion in S. 1.3 (pg 15) that suggests a carve -out <br />from the Durango RICD water rights of at least 30,000 acre feet (AF) for future uses. The <br />justification for this conclusion rests on 7 assertions and RPI would like to address the first 2 <br />assertions, a) and b). Following are statements a) & b) contained in the Harris report followed <br />by RPI's conclusions. <br />"a) The amount is the minimum necessary for compact depletion suggested by the 1995 Report" <br />RPI's Opinion: The 1995 Report was a large- scale, generalized report and is not the most <br />appropriate information resource for evaluating future water rights above Durango's RICD <br />reach. Even if it were the best resource, the calculations in the Harris Report to support a <br />30,000 AF carve -out based on the 1995 Report are based on invalid assumptions. <br />"b) The amount is within the range shown in Table D (pg 13 Expert Report for Opposers)" <br />RPI's Opinion: The Summary of Potential Future Uses summarized in Table D concludes that <br />future uses could result in diversions of between 7,200 AF and 66,000 AF. The origin of the <br />assumptions underlying Table D are described in a cursory manner in 3.1.1 of the Harris <br />report, but Mr. Harris offers few citations, derivations, or methodology for arriving at the <br />components of Table D. Where data for evaluating Table D. was available from La Plata <br />County, US Wildlife Federation, Bureau of Economic Analysis, Metcalf & Eddy, and other <br />resources, RPI found that Table D substantially over - estimated the demand for water <br />diversions resulting from future land uses. <br />