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<br />Task 1 <br /> <br />Page 1, Paragraph 1: <br /> <br />The techniques of storm transposition, maximization and envelopment were used by both <br />the NWS and the Board of Consultants (BOC), There was no disagreement between the <br />NWS and the BOC on the basic principles of storm transposition, maximization and <br />envelopment. <br /> <br />Page 1, paragraph 2: <br /> <br />The principal and fundamental disagreement between the Deerfield studies produced by <br />the BOC and the NWS involved different concepts for most prudently specifying what <br />the values of storm-centered PMP should be in areas beyond the explicit transposition <br />limits of particular storms in a comprehensive regional study ofPMP. If the NWS had <br />used different transposition assumptions (such as in HMR 33) as a starting point, there <br />would have been considerably less difference (only about 12 percent rather than <br />29 percent) between the BOC and NWS results for Deerfield. <br /> <br />While recognizing that the BOC made a sincere effort to develop an estimate ofPMP for <br />the Deerfield drainage, and that their interpretation of data is defensible (letter from E. M, <br />Hansen to Ronald A. Corso, Director, Division of Inspections, Federal Energy Regulatory <br />Commission, July 14, 1987), the NWS disagreed with the BOC's belief on what is <br />"appropriate conservatism" which they expressed in section 2C of their response to the <br />April 15, 1987, NWS review of the BOC's study. The NWS continues to assert that the <br />positions it took in its Deerfield study were correct and fully justified as Mr, Hansen's <br />letter to Mr. Corso on April 17, 1987, originally indicated, <br /> <br />The Fec!eral Energy Regulatory Commission asked the National Science Foundation to <br />look at methods for evaluating PMP. In 1994, the National Science Foundation <br />concluded; "There is no compelling argument for making immediate widespread changes <br />in either PMP methodology or the NWS assessments ofPMP, and the Committee <br />recommends its continued use," The committee did recommend increased research <br />aimed at incremental improvements, <br /> <br />Page 1, paragraph 3: <br /> <br />This paragraph misinterprets the NWS study despite acknowledgment of the NWS <br />approach in the following paragraph. In preparing the 1995 estimates, the NWS did <br />follow guidelines for non-orographic regions (as noted in paragraph 3), The NWS then <br />adjusted the results to account for the specific orography of the Cherry Creek Basin (as <br />noted in paragraph 4 but not in paragraph 3). <br /> <br />4 <br />