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<br />WCM that would cause peaks in the Gunnison River at Delta, Colorado to exceed 10,000 cfs. Flows <br />of 10,000 cfs have the potential to cause erosion and begin to inundate Confluence Park at Delta. <br />While flooding in excess of 10,000 cfs can and will occur as demonstrated in 1983,1984 and 1995, <br />there is no reason for dam operations to be planned to deliberately create such conditions. <br />Therefore, we encourage the U.S. Department ofInterior and the U.S. Army Corps of Engineers to <br />provide some additional guidance concerning any planned operations ofthe Aspinall Unit that <br />deviate from the WCM and would result in peak flows in the Gunnison River at Delta of 10,000 cfs <br />or more. We see no need to change the WCM, however, some additional guidance with respect to <br />planned deviations that would prohibit the Aspinall Unit from planning operations that would create <br />peaks in excess of 10,000 cfs when hydrologic conditions do not dictate and such would otherwise <br />be avoidable seems appropriate given the context of the settlement discussions. We believe such <br />guidance could be provided without changing the WCM and done in concert with the provisions for <br />planned deviations. We simply do not believe that it is appropriate to create even minor flood <br />problems for the City of Delta when such is not necessary. Existing data from the NPS does not <br />fully consider the combined impacts of large peaks on all resources in the Canyon (e.g. high flows <br />are generally detrimental to the trout fishery in the Canyon) nor downstream. <br /> <br />We ask that you consider this information and hope that you will issue appropriate supplemental <br />guidance. <br /> <br />~e:J[ <br /> <br />Rod Kuharich <br />Director <br /> <br />Attachment <br />Cc: <br />CWCB Members <br />Kent Holsinger - EDO <br />Dan Merriman - CWCB, ISF Section <br />Linda Bassi - Colorado Attorney General's Office. <br />Bob Comer - DOl <br />Carol DeAngelis - USBR Grand Junction <br />Chuck Pettee - NPS Fort Collins <br />Sandy Raly - USACE, Colorado Service Center <br />Richard Sales - City of Delta Community Development Director <br />Marc Catlin - Manager, Uncompahgre Valley Water User Association <br />Eric Kuhn - Manager, Colorado River Water Conservation District <br /> <br />o <br /> <br />Flood Protection. Water Project Planni11g2ftnd Finance. Stream and Lake Protection <br />Water Supply Protection' Conservation Planning <br />