2008-03-03_REVISION - M1988112 ‎(21)‎

• Permit No: M1988112
• IBM Index Class Name: REVISION
• Doc Date: 3/3/2008
• Doc Name: Objectons
• From: Town of San Luis
• To: DRMS
• Type & Sequence: AM3
• Email Name: WHE
• Media Type: D
• Archive: No

Objection to BMRI's AM-03
Page 15 of 23
February 22, 2008
which Battle Mountain Resources, Inc., expects to operate
the irrigation pivots at the Salazar Ranch with West Pit
water. The following sections describe these processes and,
ultimately, the results of expected. downgradlent
concentrations of fluoride in the valley fill aquifer. (Lytle
Report, p. 1-2)
Here, Mr. Lytle contends that MODFLOW coupled with MT3DMS can provide an
analysis of ground water flow as the two systems can provide the fate and transport of
constituents in that ground water flow.
Mr. Lytle states that he chose MODFLOW for this small subpart in the southern
part of Costilla County since MODFLOW was utilized by the State Engineer's Office as
part of the overall study by the RGDDS.
Mr. Lytle notes that MODFLOW was chosen:
Because the State Engineer's Office has recently completed the Rio
Grande Declining Support System (RGDSS) which includes the RGDSS
ground water flow model constructed using MODFLOW. Therefore, many
of the parameters for the model were obtained from an existing regional
model.
The RGDSS ground water model was recently addressed by the water oourt for
Water Division III in Case No. 2004CW24 dealing with rules and regulations for the
confined aquifer in the San Luis. Valley. (Exhibit F) Judge John Kuenhold, in his
November 9, 2006, opinion, accepted the use of the RCDSS ground water model
known as MODFLOW, but only for purposes of evaluation of the ground water issues of
the San Luis Valley as a whole for purposes of that case. The Court noted that:
The Court reiterates, however, that there.are areas in the
Valley, in particular the Costilla Plain, where the model does
not perform as it does in other areas of the Valley and where
it would be a ,great idea to improve the model. Thus, the
State Engineer must use particular care in the application
and interpretation of the model's results in that area and in
other areas in the Valley where the ground water model still
has unresolved problems. Likewise, the Court understands
that the State Engineer intends. to continue to work to