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<br />, , <br /> <br />.'" <br /> <br />O~.'t!J <br />(J.4. .il. .;. 't <br /> <br />., <br /> <br />Comment: Reclamation has selected the wrong baseline-the baseline should have wllter <br />excess to MVIC's needs accruing to the river. The manner in which MVIC uses their water has <br />changed since the Dolores Project; only the post-Dolores Project period should be used. <br />Response: The manner in which MVIC uses water has changed with the advent ofth\3 <br />Dolores Project. Effects of this change on the reservoir and downstream reaches of the Dolores <br />River were eval'uated in the Dolores Project final environmental impact statement, The EA <br />recognized that the water involved in the Carriage Contract belongs to MVICand is diverted. <br />from the Dolores Basin when. needed, Because water is not diverted from the reservoir every. <br />year does not indicate that it is not being used, One purpose of the reservoir is to store water. <br />over a period of years so that water will be available during drought periods. <br /> <br />Asswning a "post-Dolores Project" situation that did not include MVIC water being diverted <br />would not be reillistic. The Dolores Project final EIS assumed full use ofMVIC water and <br />impacts on the Dolores River were based on this, <br /> <br />Comment: While MVICdiversions would remain capped at 150,400 acre-feet; the EA <br />acknowledges that MVIC will come closer to using their full allocation more often-more <br />specifically these proposed changes will increase MVIC's use of supplemental Dolores Project <br />water as they re~locate their base water rights for use on additional lands. That expanded use <br />will have perhaps significant impacts on McPhee Reservoir levels and on downstream flows, <br />Response: The Dolores Project final EIS evaluated impacts on the reservoir and <br />downstream flows with MVIC using their full water supply allocation-this is part of the Dolores <br />Project Plan. Continued use under the Carriage Contract-not expandeduse-ofthis water will <br />have impacts consistent with the EIS. <br /> <br />Comment: Salt and selenium loading projections used in the EA are outdated-there isa <br />need for current, credible scientific information on the likely salt and selenium loading, <br />Response: Currently available information was utilized, Soil quality information used is . <br />from the Dolores Project studies, .and soil qualities would not change over the short'period since <br />those studies were completed. More recent studies by the U.S. Geological Survey and Fish arid <br />Wildlife Service. on selenium were used in the EA, Reclamation believes that the EA analysis is <br />appropriate. Monitoring of selenium is included in the Carriage Contract plan. <br /> <br />Comment: There are concems with Reclamation's interpretation of salinity control <br />program requirements-programs should reduce salinity concentrations in the Colorado River,not <br />maintain a status' quo. The need for salinity reduction, not maintenance is supported in <br />legislation and related contracts. Reclamation is obligated to demonstrate that the proposed new <br />irrigation will not lead to any material increase in salinity inflows. Even if Reclamation's analysis <br />were correct, it does not show how Reclamation would ensure that only good quality soils <br />receive the irrigation water. . <br />Response: The goal of the salinity control program is to maintain the flow-weighted <br />average annual salinity at or below the numeric criteria of the salinity standards, The program is <br />not in any way irttended to prevent the state of Colorado from using its existing or future water <br /> <br />9 <br /> <br />-J <br />, <br />.~ . "4 <br />:1 <br />;f <br />':t <br />1 <br />_1 <br /> <br />,- ~:,,_~o,--__, <br /> <br />