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<br />the model lines a straight line? Actual flows for real years <br />show a V going up and down. There is a big problem with the <br />model numbers, in terms of adequacy of the DEIS. <br /> <br />Presentation of logarithmic graphs in the DEIS is not straight <br />forward--it makes the project look better than it is. Not enough <br />detail is shown for critical periods. There is also inadequate <br />flow information presented on the Uncompahgre River flows-only <br />averages are given. You don't account for return flows and <br />irrigation in the summer. <br /> <br />The project reflects a concentration on money, not efficiency; <br />the average operating capacity of the powerplant is only between <br />66 and 70 percent. <br /> <br />Project economics are now based on artificial price supports in <br />the form of the PURPA Act; these price supports may not be there <br />in 15 years when the current contract expires. It is likely <br />there will be pressure to use more water from the Gunnison, by <br />building these large-scale projects, is inefficient, in the <br />course of time. <br /> <br />I am concerned the Uncompahgre Valley Water Users Association <br />could violate the 300 ft'/s flow on the Gunnison in the name of <br />irrigation by ignoring the Uncompahgre flows, and then using the <br />excess irrigation diversions for hydropower. There needs to be a <br />better, more complete monitoring system. The above scenario <br />would represent a waste of water under Colorado water law and the <br />water users would be subject to losing water rights. <br /> <br />We doubt that the Uncompahgre River bank protection measures will <br />work. The DEIS has no assessment of potential loss of wetlands <br />due to riprap and other measures. However, the DEIS lists <br />5,000 acres of wetlands along the river. Congress has stated a <br />no loss of wetlands policy. Section 404 permit regulations <br />require acre-for-acre replacement of wetlands. This is a gaping <br />hole in the DEIS. There is also no mention for rights-of-way <br />agreements for bank stabilization work or compensation for <br />landowners for impacts to their property. Failure to address <br />this impact of riparian habitat and wetlands is a possible <br />violation of the Clean Water Act, the National Environmental <br />Policy Act, and the Threatened and Endangered Species Act. <br /> <br />While the DEIS claims increased flows in the Uncompahgre will <br />replace lost habitat on the Gunnison, for species such as the <br />federally endangered bald eagle and the endangered river otter, <br />the DEIS also states that the speed of flow in the river will be <br />too great to support fish and wildlife. Those are the prey <br />species that eagles and otters depend on. These are <br />contradictory statements, and what we call disinformation. <br /> <br />The proposed sinking fund to monitor and continue bank <br />stabilization does not list specific amounts in that fund. <br />cost of bank stabilization and erosion control were listed <br /> <br />The <br />in the <br /> <br />P-18 <br />