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<br />Dam must ~e free of frazil ice, as it will flow directly to <br />the Foothills Treatment Plant." This factor was clearly <br />recognized in the FES which stated, with respect to the low <br />dam and upstream alternatives, "winter icing problems would <br />cause this diversion structure to be operative for only <br />seven months of the year and necessarily change the Foothills <br />treatment plant operation strategy." (FES 8-13) The change <br />in strategy, as noted at page 8-12 of the FES, would require <br />the plant to be operated as a peaking rather than a ~ase <br />load plant as it has been designed to operate. <br /> <br />In response to questions posed at the USBR ~riefing on <br />its official memorandum, officials of that agency, notwith- <br />standing the opinions of their own experts, asserted that <br />they disagreed with the FES and believed that year-round <br />operation was feasible so that the use of small diversion <br />structures could be feasible. Those same officials admitted, <br />however, that they gave no consideration to the fact that <br />the filter plant could not handle ice-laden water. <br /> <br />The fact is, no competent utility engineer would attempt <br />to make a filter plant accommodate ice conditions 1 instead, <br />the universal industry practice is to design and locate <br />filter plants so as to avoid ice in the water to be treated. <br />A comprehensive description of the extraordinary pro~lems <br />ice-laden water could cause in the Foothills Treatment Plant <br />is contained in Exhibit 10, prepared by the noted water <br />utility consulting engineering firm of CH2M Hill. If any <br />Federal decision-maker doubts the validity of the conclusions <br />stated by the USBR Ice Research Management Team in Exhibit <br />9, a perusal of Exhibit 10 should dispel those doubts in <br />the mind of any reasonable individual. <br /> <br />Apparently the USBR took the position that the frazil <br />ice pro~lem was merely one of avoiding conditions which <br />would plug up the diversion structures; representatives <br />speaking for that agency at the briefing on their report, <br />asserted that they could solve the "problem" by heating the <br />trash rack and raising the crest of the originally designed <br />diversion dam by fifteen feet. <br /> <br />Such an incredibly shallow assessment of the pro~lem is <br />shocking when made by one who is assumed to be a responsible <br />public official. This is so ~ecause of the extraordinary <br />nature of the problem which does exist and which cannot <br />really ~e understood unless one has actually observed the <br />conditions which occur in the Canyon. <br /> <br />Because the ice problem is so poorly understood by <br />those who are not regularly confronted with solving it, <br />Denver employed the services of an internationally-famous <br />snow and ice expert, Mr. Walter U. Garstka, to evaluate the <br />problem from his vast experience and to report on it so that <br />the Federal decision-makers might gain a clearer insight <br />into the pro~lem. His report (Exhibit 11) and an addendum <br /> <br />-12- <br />