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'. '/0i}~::) :".- .'~ . .....-... ,........ :1 .'0" \.;..~:}.~~:.... n01S~7 Gunnison River Contract Scooin2 - SORTED Comments c) Would AB Lateral Project developers or others be allowed to contract for all or part of the 300,000 acre-foot Aspinall Unit Water Supply for diversioD through the GunnisoD Tunnel? .'" d) If DODe of the 300.000 acre-foot Aspinall Unit Water Supply were Dot available to the Park Service under the proposed contract, how often would the Monument receive more than Ute 187,500 acre-foot minimum annual supply provided for in the January 1992 draft.coDtract? d) How does subtractioD of the 300,000 acre-foot Aspinall Unit Water Supply affect the quantity and timing of releases to ihe NatioDal MODumeDt UDder the proposed contract? 8. GREENO+; p6,'1. (Issue D. Endangered Fish Recovery, cODt) The COD tract and EIS should clearly state the relatioDship betweeD the flows provided for eDdangered fish as a result of the current DegotiatioDs and any past agreements. Mitigation of the Dolores and Dallas Creek Projects included agreements by the Bureau of ReclamatioD to make releases totalling 148,000 acre-feet (annually?) from the Aspinall Unit for the beDefit of endangered fish. These releases should be: (a) specifically accounted for in the contract and (b):included in tbe discussion of environmental impacts and assessmeDt of water supply in the EIS. 8. MONTECON; p3, '5. 5. National Park Service cODtrol of the GUnniSOD flows - The National Park Service appears to have the most if not all of the say in how the water under the proposed COD tract would be released. If the State were to ultimately divert or cODsumptively use its 300,000 acre-feet, theD the NatioDal Park Service will cODtrol essentially all the water that is left in Aspinall. While many of the NatioDal Park Service's goals are certainly admirable, they may Dot totally reflect what the community sees as environmentally beneficial. For example, the National Park Service may want to enhance eDdemic fish, poteDtially at the expeDse of the trout in the gold medal fishery. Or the National Park Service may want to enhance some resource within the Black Canyon (their mission), :8t the expense of another resource in either the downstream Gunnison Gorge or Dominguez Canyon. such as rafting or the upstream fishery within the Aspinall Unit. In essence, the NatioDal Park Service is oDly concerned with what happeDs within the Black Canyon, but its decisioDs will affect the river all the way to Grand Junction. Since the proposed contract is "in perpetuity" we are concerned about giving the NatioDal Park Service exclusive cODtrol of GunnisoD flows. a. If the State ultimately develops its 300,000 acre-feet, and the NatioDaI Park Service COD trois all the rest of the Aspinall releases, is there any opportunity for the community to get involved in release priorities? b. Shouldn't releases be cODtrolled by an eDtity with a broader perspective than the National Park Service, both environmental and otherwise? . c. "In perpetuity" is a long time; is it possible to limit the contract to say, 10 years, after which time it could be reevaluated giveD changing circumstances? 8. MONTPART; pl,'3. L Hvdrol02ic Analvsis - At preseDt, the only informatioD we have is geDeral formulas that will set the maximum amount of water the NPS can cODtrol in any given year. To complete any worthwhile review or analysis of the contract, it is critical that the equations be reduced to a month by mODth, or week by week hydrology format similar to that developed for the AB Lateral NEPA documents. OthelWise it will be virtually impossible to gage the eDvironmental or economic impacts of the agr~ment. 8. NONFED75; pl.'2. 1) We do Dot agree that Colorado Water ConservatioD Board (CWCB) should be the only non-federal entity designated as a party to the cODtract. CODsidering the existing agreements with local GUnniSOD Basin eDtities regarding the Aspinall UDit water-right decrees and operations under the 1975 Agreement (nODe of which involve the CWCB), we feel it would be appropriate to add our organizations as parties in the negotiations. 24