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Stephen Ell is August 11, 1980 Page 2 I' which shows population projections without the project. The Division feels that it is extremely unlikely that 2,400 persons (1980 population estimate of 1,600) will move into an area with insufficient water, so we assume that the Service feels there is already sufficient water for the population it projects for "rural LaPlata Service Area." If this is true, why is the additional 1,000 acre feet necessary? Finally, as the EIS notes (page C-14), LaPlata County has no future land use plan at this time. It is therefore unclear how population distribution and other aspects of the EIS and the prGject itself are "based on... local planning." 2. The EIS's and the Division's,1990 and 2000 projections for LaPlata County and Durango (from Table J3""l) ,are I\ssentially the same. However, the EIS projects a 1990 population for Bayfiel~\of 3,983,without the project. The Division of Planning projects~a 199()\,pop~1ation for that community of only about 1,000 persons. The reasons for'this very.substantial difference remains of concern. We feel that ~ four-fold di~ference rests on more than the inclusion by the EIS of land beyond tre city limits of Bayfield in this projection. In any'case, the Division feels that the assumptions inherent in the population projections for Bayfield should be made explicit. 3. The perception by the Service of the "regional planning office," which we presume to be either the San Juan Regional Commission or the Animas Regi ona 1 Pl anni ng Commi ss i on, 'as a State agency is a seri ous mi sconcepti on which we would like to clarify. Neither of these two agencies is in any way a State agency, nor have they ever been. The San Juan Reg;onal Com- mission is a local organization of five counties which does no planning but acts as an umbrella organization for other State, Federal and locally funded activities in the five county region. The Animas Regional Planning Commission is a cooperative planning agency whose members include LaPlata County and the municipalities of Durango and Bayfield. The State plays no role in either of these organizations. 4. The Final EIS perpetuates the error in the Draft EIS by stating (on page B-16) that "Colorado Senate Bill 35 (1972) extended the definition of 'subdivision' to include practically any new development." This over- generalization ignores the point of our comment that subdivisions with lots over 35 acres in size are not subject to regulation under either State or county land use regulations in Colorado. Thus, the statement on page B-16 of the Final EIS that a 13 unit tract of 40 acre parcels "must meet provisions of State and county land use legislation" is not correct. In fact, the large number of subdivisions exempt from regu- lation because of lot size over 35 acres is an increasing problem in Colorado because of their very land consumptive nature.