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<br />Comments to the Proposed Rule and the Environmental Assessment for Proposed Rule Making <br />for Off stream Storage of Colorado River Water and Interstate Redemption of Storage Credits in <br />the Lower Division States <br /> <br />~.. ~on 4 I 4. I of the Rule, last part of first paragraph beginning "When unused apportionment <br />is intentionally created......with Article Il(B)(6) of the Decree." This sentence is very difficult to <br />I follow and should be simplified. A similar sentence appears in Section 414.4, middle of second <br />para., and should also be simplified. <br /> <br />I ~~ate~banking could cause a lot of problems that aren't obvious now - Arizonajust <br />began large-scale recharge projects and any possible impacts/problems aren't known at this time. <br />It makes sense to do this with our own water apportionment, but should Arizona take chances of <br />r being "shortdlanged" in some way by ha-'1dling Nevada's water. <br /> <br /> <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br /> <br />l <br />I <br />I <br /> <br />'tl03627 <br /> <br />It seems like the whole purpose for this rule is so Nevada can store its unused apportionment in <br />Arizona for the next 5 or so years, after which they will be using their whole apportionment. - Why <br />doesn't Nevada develop its own recharge program, and recharge within its state? It would seem <br />that the development of recharge basins in Nevada would cause fewer environmental problems <br />than those in Arizona. Or why doesn't Nevada make a deal with California, such that California <br />consumptively uses Nevada's unused apportionment but must "pay this back"in future years? <br /> <br />Another problem is that several of the new recharge basins in Arizona have no pumps, so in order <br />to get its exchange water, Arizona will have to pump from aquifers that are not being recharged, <br />or install new pumps in the newly recharged aquifers. <br /> <br />3. Recharged water may be very difficult to recover, so this exchange may be very inequitable for <br />Arizona. The 95 percent number is probably nowhere near sufficient to account for lossjls - <br />evaporation alone in the recharge beds in the Arizona desert will be great. Also, you never know <br />for sure where that water will end up that you are putting in the ground - it may move off to an <br />irretrievable location. If the off stream storage is in reservoirs, there will be evaporative and <br />seepage losses. The problem is, a good number for accounting for losses may be difficult if not <br />impossible to come up with - another reason not to make interstate exchanges of this sort. <br /> <br />4. Why should Arizona do this? To be good neighbors to Nevada? By "sticking it" to <br />California? California took some of Arizona's apportionment for years but that's no reason for <br />revenge now - Nevada should work out its own methods for obtaining its full apportionment. <br /> <br />5. Page 4, I" para.: The accounting method for Colorado River water is confusing. The water <br />diverted and stored Off stream in Arizona should be accounted for as being consumptively used in <br />that same year in Nevada, because Arizona is currently using all of its apportionment. If the <br />purpose of all this is for Arizona to store Nevada's water and not use all of its own <br />apportionment, the result will be that California will be getting Arizona's apportionment instead <br />of Nevada's for the next five or so years. I assume that the purpose of all this is so Arizona can <br />store Nevada's unused apportionment as well as all of its own apportionment. If that is the case, <br />then the consumptive user should be Nevada for the year the water is stored, and Arizona would <br />