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<br />DEIS as reasons for eliminating alternatives G and H as <br />uneconomical, again proving that this is a serious economic <br />problem. I suggest the Bureau require the sponsors to put up a <br />bond between 5 and 10 million dollars, or more, before the <br />operation begins. The danger is that if damage is too high, <br />Mitex will pullout, leaving the water users liable. Then their <br />rates will go up, not down. <br /> <br />I question why the DEIS was released with preliminary and <br />inadequate information. The 1976 law requires a full-scale study <br />of all environmental, social, and economic impacts to be <br />presented for public review. I question if the Bureau of <br />Reclamation glossed over these potential problems to speed up the <br />report so as to meet .the sponsor's deadline for producing <br />electricity, based on its contract with Public Service Company. <br />The Bureau has public responsibility and depriving the public and <br />other agencies and institutions of adequate information to <br />evaluate the project in order to meet deadlines for profit is <br />unethical, amoral, and illegal. The only solution is to rewrite <br />the DEIS when studies are complete. <br /> <br />RESPONSE: For information on the differences between modeled <br />flows and actual gauged flows, please see the RESPONSE to <br />COMMENT 20 at the Montrose Public Hearing. The modeled flows do <br />not show a typical "V" pattern during runoff periods, primarily <br />because the model includes upstream regulation of runoff by <br />Aspinall Unit Reservoirs. This storage tends to moderate runoff <br />peaks. <br /> <br />The logarithmic presentation of flow data has been mentioned by <br />several commentors as confusing. The best way to compare flows <br />with and without development is to compare the flow tables in <br />chapter 3 that provide average monthly flows throughout the study <br />period. Additional information on the Uncompahgre River flows is <br />provided in the EIS in chapter 3 including more detail on return <br />flows. <br /> <br />The efficiency of the powerplant is less than 100 percent because <br />the plant would not receive a 100 percent water supply. Minimum <br />flow and irrigation commitments receive priority and naturally <br />occurring periods of low flows exist. <br /> <br />Project power sales are covered under the PURPA Act; further <br />information is found in the RESPONSES to COMMENTS OR-l through 3, <br />and F-6. A new contract would be negotiated at the end of <br />15 years. Selling hydropower energy upon debt repayment has not <br />been a problem in the United States, primarily because a fuel <br />cost doesn't exist as a cost does with coal-fired powerplants. <br />See RESPONSE to Ce>>oa:NT OR-45. <br /> <br />The lease of power privilege and water rights considerations <br />would prevent hydropower diversions under the name of irrigation <br />diversions. Monitoring flow requirements are described in the <br />EIS. <br /> <br />P-19 <br />