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.V. <br />Brown, Rick <br />From: Alan Berryman [aberryman @ncwcd.org] <br />0 ent: Wednesday, July 10, 2002 3:10 PM <br />o: Brown, Rick; David Little (E- mail); Deb Freeman (E- mail); Dick Stenzel (E- mail); Don Ament <br />(E- mail); Eric Wilkinson; Hal Simpson (E- mail); Howard Propst (E- mail); Jon Altenhofen; Kent <br />Holsinger; Kevin Urie (E- mail); Mcneill, Grady; Thomas Blickensderfer; Wendy Weiss <br />Subject: RE: NAS AND Flow Recommendations Documents <br />Rick, Here are my comments on the FWS instream flow recommendations. <br />I think the document provides some clarity to the FWS' interpretation of <br />the instream flows; however, I think there is still confusion with <br />respect to the application of those flows in evaluations of WAP projects <br />and new depletions. For example, the last sentence in section (4) on <br />page 7 states that "presumably, the project will be approved only if its <br />positive effects relative to meeting Program target flows (species + Uf•'P <br />annual pulse flows) outweigh any negative effects relative to <br />maintaining peak flows." What does "outweigh" mean and will that <br />judgement be subject to changes in interpretation depending on which FWS <br />employee is doing the review? The states should know more about this as <br />it has a huge impact on the possible WAP projects. <br />In the next section (5), the second paragraph contains language that <br />impacts of the proposed project on all pulse flows, including peak <br />flows, will be an important consideration. That is, substantial <br />reductions in the magnitude and /or frequency of peak flows resulting <br />from the proposed project may be considered a basis for determining that <br />the project is not covered by any state or federal depletion plan." <br />What is "substantial "? At one time, Mark led us to think that only a <br />"super- large" project on the order of two -forks would cause a problem to <br />*eak flows. (although most of the water for that project would have <br />ome from another basin). The language in the FWS document does not <br />appear to be as broad as we've had in some previous discussions. It <br />seems we need to find out more about this "test ". Also, in the near <br />future we may want to run a "test case project" through our future <br />depletions model and examine the results to get our own idea of the <br />magnitude of the impact to peak flows caused by a medium sized new <br />reservoir located along the front range. <br />The last paragraph on page 9 is also troubling. They emphasize the <br />premier importance of peak flows and state that their objective is to <br />(1) minimize reductions in the frequency and magnitude of the highest <br />peak flows and (2) improve the long -term running average annual peak <br />flow magnitudes in the central Platte River. This would seem to go <br />against allowing new projects to utilize the peak flows. This also <br />dismisses the findings by Parsons in the sed -veg studies that seemed to <br />show that less reliance on peak flows is warranted and efforts should be <br />focused on annual pulse flows. <br />In summary, it appears they are now saying that peak flows won't allow <br />new storage projects (especially on- stream) to go forward, but may allow <br />some smaller diversions to occur. When we originally put the water <br />components of the Program together, I think we thought that we would be <br />able to develop a large part of the peak flows. <br />My recommendation would be to send the document to the water committee <br />to discuss the ambiguites and find out more about the specifics of their <br />"tests" and how they might affect the WAP projects and also reservoirs. <br />e'll need to know that prior to getting into a program. That request <br />an be sent prior to the GC meeting or at the GC meeting, but more <br />discussion is needed and hopefully the FWS' document can be altered. <br />- - - -- Original Message - - - -- <br />