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<br />Stephen Ellis <br />August 11, 1980 <br />Page 3 <br /> <br />5. To the Division's comment on the Draft EIS that the proposed project <br />would result in increased pressures for subdivisions of land, the <br />Service responded that the project will increase the value of the <br />agricultural lands watered by the project. The Oivision does not agree <br />with this response. We believe it will provide domestic water to rural <br />areas making subdivision more attractive. <br /> <br />The last 30 years in Colorado have demonstrated that the presence of <br />adequate agricultural water is no proof against subdivision--witness <br />the continuing residential, commercial and resort development in virtually <br />every major irrigated mountain valley in the State. <br /> <br />The statement in the Final EIS (page 1-90) that "The Dry Side is too far <br />from employment centers to attract much development" is, unfortunately, <br />an oversimplification. Development or, more accurately, its predecessor-- <br />subdivision of land--has occurred and continues to occur in many areas of the <br />State well removed from employment centers. Many examples of this fact <br />exist in Park and central Las Animas County where hundreds of 40 acre <br />1- parcels have been sold for retirement and speculative purposes although <br />few jobs exist within 50 miles. <br /> <br />6. The Oivision remains concerned about the possible future conflict between <br />the agricultural activities promoted by the project and development of the <br />area's coal resources. The Division believes it very possible that <br />future events could result in much of the project water going to industrial <br />uses rather than the planned-for agricultural uses. The Division of Planning <br />does not advocate either use over the other, but it does believe that this <br />possibility should be explicitly taken into account in planning the project. <br /> <br />The Final EIS stated (page 1-91, comment #6) "Conversion of agl icultural <br />land to real estate development is unlikely since the project water is <br />available only for agricultural purposE',..." Taken as stated, this sentence <br />is clearly incorrect since 41,700 acre feet of a projected annual total of <br />143,000 acre feet is already allocated to non-agricultural uses (Table A-l). <br /> <br />In summary, the Division of Planning feels that the rural residential land use <br />implications of the proposed project have been given only cursory and inadequate <br />treatment in the Final EIS, that some of the logical and predictable secondary <br />effects of the project are directly contrary to State policy, and that insufficient <br />attention has been given to the possible negation of the agricultural benefits of <br />project by both development of energy resources and increasing subdivisions of <br />land. The Division of Planning strongly recommends that these issues receive <br />more attention before the Project proceeds. <br /> <br />PHS/btm <br />