Final Environmental Impact Statement Volume II Appendix K, Part 2

Home Browse Search

COMMENTS OF U.S. ENVIRONMENTAL PROTECTION AGENCY existing flows that is the subject of the FERC relicensing. Based on the difference between baseline conditions and DOI'S target flows for species recovery, additional flow will be needed proportionally from each federally - licensed or permitted project in the Platte River Basin. Such additional or new water could be appropriately obtained from water conservation and /or managed use of the ground water mound created by the projects' operations rather than curtailment of existing irrigation. In applying a formula for developing interim measures for federal permit applicants in Colorado, the FWS intends to achieve the recovery target flows continuously. Since there is a projected annual stream flow shortfall of 386 thousand acre -feet (KAF) in the Platte River below that needed to meet target flows at all times, each applicant for a federal permit or license is to provide either water or funds to provide a percentage of the total of 386 KAF of new water needed. Based on prior court action for the Colorado River RIP, it is our current interpretation that projects will be required to provide flow rather than have the option of funding FWS to purchase water. P� Under FERC's preferred alternative, the lack of a specific goal for a water conservation program, the short -term definition A of what is economically feasible, and limiting the costs of supplemental measures could preclude meaningful water conservation results. Our review of the Lidstone Report regarding water conservation leads us to conclude that 15 percent is a reasonable conservation goal and that such conservation should be achieved as a priority supplemental measure. The Lidstone report, which was developed by the National Audubon Society and submitted to FERC, concludes that about 50 cfs of net gain in the Platte River could be obtained by lining the E -65 and E -67 canals and improving on -farm efficiency in these irrigated areas. The total gain for the year 2010 was predicted at 52 cfs less 2 cfs in reduced ground water return flow. The predicted change in the height of the ground water mound was only 3 feet. This work used the MODFLOW program developed by the USGS and shows that a significant net gain in stream flow can result from effective water conservation for the reach studied. It would be appropriate prior to the final EIS, ROD, and issuance of final license conditions for FERC to provide consistency with DOI'S Platte River Basin recovery implementation plans. Specific water conservation savings, dedicated to instream use, should be established and made a key supplemental EPA -16 Imeasure and license condition. The license condition should specify: • Based on the current delivery efficiency of the projects being only 50 percent (page 4 -30, RDEIS), additional water should be attained by specifying a 13 RESPONSES TO U.S. ENVIRONMENTAL PROTECTION AGENCY EPA -16 With the exception of a specified amount of water savings, we concur with the thrust of EPA's suggestions. We see a conflict between specifying a minimum amount of water savings, while also specifying a cost limit. The measures contained in the Reasonable and Prudent Alternative essentially address all of the concerns listed by EPA. The conservation plan will be filed with the Commission within two years of license issuance.