BOARD01879

• Board Meeting Date: 7/13/1998
• Description: WSP Section - Colorado River Basin Issues - Paradox Valley Unit Augmentation Operations
• Board Meetings - Doc Type: Memo

July 9, 1998

To: Colorado Water Conservation BoanI
From: David Nickwn, Trout UnlimilOd
Re: Item 26(&). Paradox Valley Unit AUlIDentatlon Operation.

I regret thal I cannOl attend the 1uly board meeting both to hear the presentation on this issue and to share
Trout Unlimited's concerns. Since I will DOt be at Telluride, these comments address issues thal r
anticipate may arise during the discussion about augmentation for the Paradox Valley project. Thank you
far the opportWlity 10 comment

I. 1'IIou&II lu&rnenlallon waler bas nol b~n provided In Ihe past, II could be In Ibe future.

ro recognizes that the CWeB has limited resources, and as a n:sult on-the-ground enforcement of instream
flaw rights may sometim~ "slip through the eracks." This is the very reason we joined with the CWCB on
a pllot volunteer monitoring project. However, failures of enforcement in the past should not prevent the
Board from protecting iu insueam flow now lhat the issue has come 10 light. We believe it is vital for the
credibility of the instream flow prognun thaI the Bun:au provides augmentation water to ensure that iu out-
of -priority use at Paradox Valley does nOl injure the Board's right. A fQSOnable estImalC or augmenwion
needs can be generated by R\liewing historical recorcls, along with some analysis of lrolnSitlo&se5 belween
MePhee Reservoir and Paradox Valley. ICthen: is nOl sufficient augmentation water available from
McPhee, the Bureau should curlall its usc at Paradox so as to avoid injury.

.

2. Water quality ImprovementJ from Ibe project do not ellmlnale or reduce Ibe need 10 auzment.

Whlle the Paradox salinity eonlJlll project may have some benefits in tcnns ofwaler quality, this docs nol
diminish the Bureau's responsibility to avoid injury to the senior instream flow right. The objective should
be to ensure adequate water quantity and quality. not to trade one oft' against the ather.

3. TU IUppOrtJ Inleuatlnslhe auzmentallon waler wllh Ibe DRIP proUam.

Tbe Dolores River Instream-flow Partnership (DRIP) provides importanl flow benefiu to the trout fishery
below McPhee Reservoir and to the river ecosystem genc:llllly. IC augmentation water can be I15Cd 10
enhance the DRIP program while still meeting augrncnWion needs, ro wboleheartedly suppons thaI
approach. Sueh coordination should BIlow bOth DRIP and the Instream flow progrnm 10 work more
effec;tively In protecting the Dolores River. When augmentation water is available in excess of that needed
to protect the inSl1eam flow below Panldo,," thai water could be uscd through DRIP to benefit the fishery
(ancllor the wetlands being created as part of Dolores project mitigation). We emphasize that coo,dlnatlon
between these two pools of water is appropriate, insofar as multiple benefits can be obtained from the same
water. However, augmentation water must still be managed 10 ensure no Injury from the Paradox project.
and fish pool water must be used to maximize fishel)' habital below McPhee. As with the water quality
concern discussed above, the approach here should be 10 address the needs of both progrnms, nOllO trade
one oft' against the otber.

.

T,oll' Ulfllmit6tl: Ameru.-.... L,tltlllf# CoIdwttter Flslterl,. COM,,,,,,,iolf O'#tI"lr.arlolf
Colorado Offiee: 190 E. Ninth Avenue, Suite 120, Denver, CO 80203
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