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<br />Concerning the impacts of ice in the Gunnison River, historically <br />the river froze so that one could ice skate up into the canyon. <br /> <br />The EIS overestimates irrigation season flows in the Gunnison <br />River under the no-action alternative. This is because the <br />models do not reflect the increased use of the Gunnison Tunnel <br />for irrigation in recent years. The DEIS exaggerates impacts on <br />the Gunnison River during the irrigation season. In the summer, <br />flows are not going to change because the tunnel will only carry <br />so much water. Flow changes will occur in early spring, fall, <br />and winter. <br /> <br />The minimum payment to Water Users from the project is $150,000 <br />and those projections go up to a conservative estimate of <br />$1 million. It will pay $400,000 to $800,000 in taxes in <br />Montrose County. <br /> <br />There is a need for the power as shown in Public Service Company <br />forecast s. <br /> <br />RESPONSE: It is recognized that rapid growth in the rafting <br />industry on the Gunnison River occurred during a period of high <br />flows. These flows will, of course, not be available in many <br />years, even under the no-action alternative. Flows in the 1988 <br />and 1989 rafting season have been below normal. The industry can <br />expect variable flow levels in the future because of differences <br />in precipitation levels. <br /> <br />As the comment indicates, ice formation in the Gunnison River is <br />a natural occurrence; however, ice formation above Delta has been <br />reduced greatly over the last 25 years due to the Aspinall Unit <br />reservoirs. The hydrology for the EIS was based on long-term <br />historical tunnel diversions; recently, diversions have <br />increased. If these higher diversions continue, impacts to the <br />river during the irrigation season may be overstated. As stated <br />in the EIS, the project hydrology superimposes historic <br />irrigation practices upon simulated releases from the Aspinall <br />Unit for the 32-year study period. <br /> <br />The commentator is correct in stating that recent irrigation <br />practices have led to more irrigation diversions than would have <br />been predicted by simply extending the historical averages. <br />Tunnel work since the late 1970's has resulted in the capacity of <br />the Tunnel increasing from about 1,000 ft'ls to 1,135 ft'/s. In <br />addition, during the past several years, the UVWUA has generally <br />run the Tunnel at or near its new capacity for longer periods <br />than it did previously, subject to flow availability in the <br />Gunnison River. <br /> <br />If this trend continues, for the peak irrigation season, the <br />Black Canyon flows under the no-action alternative during the <br />32-year study period would actually be slightly lower than are <br />predicted. This results in hydroproject impacts being <br />exaggerated in the EIS, since the difference between postproject <br />and alternative A flows would be less. For the peak irrigation <br /> <br />P-2l <br />