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Home My WebLink About841169.tiff ENT- Op "'"' °z ° DEPARTMENT OF THE ARMY 44. yes z OMAHA DISTRICT CORPS OF ENGINEERS ❑1 p 6014 U.S. POST OFFICE AND COURTHOUSE OMAHA, NEBRASKA 68102 REPLY TO o I1 'p ATTENTION OF August 15, 198`} Planning Division RESCOPING ALTERNATIVES AND ISSUES SUMMARY Dear Systemwide EIS Participant : I have enclosed a summary of the alternatives and issues that you presented during the rescoping meetings of the Systemwide EIS and our responses to them. More than 300 of you participated in the nine rescoping meetings and 139 of you sent letters with comments. About 100 issues were raised and considerable guidance on the selection of alternatives was provided. I am grateful for the high level of participation, the useful comments, and the constructive presentation that you have provided. You have added a great deal to the quality of the Systemwide EIS by your participation. The list in Section 3 of the summary represents a consoli- dation of the issues that you raised. In the process of consolidation, some issues may have been unintentionally omitted or misinterpreted. If you find any omissions or errors, please notify us at our Omaha address or at the Entercom office noted on the front of the summary by August 30, 1984. My team is currently working with our contractor, Engineering-Science, to develop a Scope of Work for study of the alternatives and issues. Any new comments that you make will be noted during the development of the Scope of Work. You can also make your views known by contacting your representatives on the EIS Coordinating Committee. The EIS Coordinating Committee, the Cooperating Agencies, and the Corps will work together to redraft the Scope of Work, which I anticipate will be completed in final draft form by September 28 , 1984. You will receive a notice with information on how you can review the Draft Scope of Work at that time. The next steps will be to negotiate contracts and to begin our site-specific studies. In the meantime, the systemwide analyses will continue--most particularly for the development and evaluation of the alternative scenarios. 841169 -2- Your assistance is requested in helping us maintain an up-to-date mailing list. Our current list contains over 1 ,700 names. If you have any name or address changes, deletions, or additions, please indicate them on the enclosed MRO Form 1793 and return it to us. The instructions are included on the form. If you know of anyone who is not currently on the list but is interested in receiving future mailings, please include their names and addresses also. Let me thank you in advance for your assistance in this continuous effort. Thank you again for your excellent contributions. You have greatly improved the quality of the Systemwide EIS studies. Sincerely, Ah8 Q. IttPlir. a s , Colonel , Corps of Engineers District Engineer Enclosures I I U.S. ARMY CORPS ENTERCOM, INC. US Army Corps OF ENGINEERS 426 S. CHERRY STREET of Engineers 6014 U.S. POST OFFICE SUITE 200 AND COURTHOUSE DENVER, COLORADO 80222 Omaha District OMAHA, NEBRASKA 68102 Systemwide EIS Metropolitan Denver Water Supply Systemwide/Site-Specific EIS Alternatives and Issues Summary This information is printed and distributed for the Metropolitan Denver Water Supply Systemwide Environmental Impact Statement process by Engineering-Science and ENTERCOM,Inc.under contract with the U.S.Army Corps of Engineers,Omaha District. The Corps of Engineers is managing a third party systemwide EIS for the Denver Water Board and Metropolitan Area Water Providers. For more information,or to be put on the public information mailing list,write:Systemwide EIS,c/o ENTERCOM,Inc.,425 S. Cherry St.,Suite 200,Denver,CO 80222,or call(303)393-7514. U.S. ARMY CORPS OF ENGINEERS OMAHA DISTRICT SYSTEMWIDE EIS METROPOLITAN DENVER WATER SUPPLY SYSTEMWIDE/SITE-SPECIFIC EIS ALTERNATIVE AND ISSUES SUID1ARY TABLE OF CONTENTS Page 1. Introduction 1 Background 1 Public Participation in Rescoping 2 2. Water Sources and Alternatives 3 Site—Specific Sources 3 South Platte Storage 3 Williams Fork System 7 No Federal Action 7 Conservation 7 Ground Water Development Within Municipal Boundaries 7 Nonpotable Reuse 7 Sewage Exchange 11 Purchase, Lease, or Condemnation of of Agricultural Rights 11 Other Water Sources 11 Alternative Scenario Water Sources 11 Other Sources 12 3. Issues and Responses 13 LIST OF FIGURES 1. Two Forks Reservoir 4 2. Upper South Platte Drainage Reservoir Sites 5 3. Chatfield State Recreation Area - Existing Facilities and Water Surface Area 6 4. Williams Fork Collection System 8 5. Williams Fork Collection System and Pumping System 9 6. Gross Reservoir Expansion 10 SECTION 1 INTRODUCTION BACKGROUND The Omaha District, U.S. Army Corps of Engineers (COE) , is rescop- ing the Metropolitan Denver Water Supply Systemwide Environmental Impact Statement (SEIS) to include site-specific evaluation of certain water sources. The need for rescoping became evident in the fall of 1983 when the COE conducted a midterm assessment of the progress of the SEIS. Concerns were raised regarding the conduct and progress of the SEIS by several interest groups in discussions held as part of the midterm assessment. Some of the major concerns were that the quality of the documents and level of analysis were insufficient; that there was not sufficient opportunity for public involvement in the process; that some agencies, groups, and interested parties did not take the SEIS as a serious process, resulting in apathy about involvement; that the SEIS was beginning to take too much time; and that the time and money expended would result in a product of limited utility. The COE discussed these concerns with the Metropolitan Water Roundtable EIS Task Force. It was mutually agreed that an EIS Coordinating Committee consisting of two representatives from each of the principal interest groups (the West Slope, the Environmental Caucus, the Metropolitan Water Providers (Providers), and the Denver Water Department (DWD)) would be formed to work with the COE and its contractor to resolve the concerns. The proposal to proceed with rescoping to include site-specific evaluations in a combined EIS was formalized in the Coordinating Committee in December 1983 and January 1984 after many hours of dis- cussion and deliberation. The actual implementation of the rescoping was initiated with a letter of intent dated 24 February 1984 from the Denver Board of Water Commissioners (DWB) to the COE. The DWB indica- ted its desire to have the SEIS include site-specific analysis of South Platte storage and the Williams Fork system with a focus on Two Forks Dam and Reservoir and extension of the Williams Fork gravity system. The Systemwide/Site-Specific EIS (S/SSEIS) will include the systemwide cumulative impact analysis of water development scenarios and site-specific evaluation of the Two Forks and Williams Fork pro- jects, their alternatives, and the no Federal action alternative. The S/SSEIS will provide sufficient detail on site-specific alternatives to serve as the National Environmental Policy Act (NEPA) document required for all Federal permitting decisions. The S/SSEIS concept was presented to the entire Metropolitan Water Roundtable and has since been endorsed by Colorado Governor Richard Lamm, Denver Mayor Federico Peda, several suburban mayors and city councils, the Environ- mental Caucus, the West Slope representatives, the DWB, and the Pro- viders. The primary change to the systemwide approach that will result with the S/SSEIS will be in Technical Appendix 4 (water sources) and in 1 the EIS. The descriptions of some water sources will be more detailed as a result of the site-specific analyses. The development and evalu- ation of alternative scenarios to satisfy the Denver metropolitan area water demand for the next 50 years will now be reported in Technical Appendix 5 and summarized in the draft S/SSEIS. The draft S/SSEIS will focus on the necessary information for Federal decisions on any identified proposed actions. It is expected that the DWB will submit formal permit applications prior to the distribution of the draft S/SSEIS. PUBLIC PARTICIPATION IN RESCOPING Prior to conducting public meetings on the subject of the rescop- ing of the SEIS, the COE prepared a letter, a fact sheet, and a tech- nical information summary on the rescoping which were sent to the entire SEIS mailing list of approximately 1,700 addresses. These documents were designed to inform the public of the COE's actions and opportunities to participate in those actions. Nine rescoping meetings were held during May 1984 to receive comments on the potential site-specific water sources, to identify alternative water sources and issues, and to discuss the rescoping process. Four meetings were held on the West Slope (21 May, Granby; 22 May, Avon; 23 May, Frisco; and 24 May, Grand Junction) and five were held on the East Slope (29 May, Denver and Broomfield; 30 May, Bailey; and 31 May, Littleton and Fort Lupton). More than 300 people partici- pated in these public meetings. The COE also received a total of 139 letters on rescoping issues. Of these, 30 were from private citizens, 55 were from interested groups, 6 were from Federal agencies, 16 were from State agencies, and 32 were from local governments. 2 SECTION 2 WATER SOURCES AND ALTERNATIVES SITE-SPECIFIC SOURCES The rescoping of the SEIS to include site-specific analysis of selected water sources focused on additional storage in the upper South Platte River basin, completion of the Williams Fork system, and no Federal action. Rescoping presented the projects that had been identi- fied and solicited alternative water sources that should be evaluated in site-specific detail. Site-specific detail will provide sufficient information on each source to allow Federal agencies to make decisions relative to permits and rights-of-way, if an application is filed. Detailed information on costs, yields, operational hydrology, resource impacts, institutional constraints, and mitigation potential will also be developed. SOUTH PLATTE STORAGE Seven water storage projects were identified as candidates for site-specific analysis in the upper South Platte River basin: Two Forks, Estabrook, Ferndale, Highline with Tunnel, New Cheesman with Tunnel, Wildcat, and Chatfield Operational Changes. Two Forks and Chatfield Operational Changes will be evaluated in site-specific detail. It is currently intended that Estabrook, Ferndale, and New Chees- man with Tunnel will be analyzed in site-specific detail. However, as more specific information is developed on costs, yields, and geology, one of these projects may be eliminated from further analysis. Water storage projects which will receive site-specific analysis are illus- trated on Figures 1 through 3. Highline Reservoir with Tunnel and Wildcat Reservoir were elimina- ted as potential near-term projects for the Denver metropolitan water supply and will not be evaluated in site-specific detail. Highline Reservoir with Tunnel does not appear to represent any comparative advantage or disadvantage over New Cheesman and Two Forks to warrant site-specific study at this time. The Highline Reservoir basically will impact the same resources as Two Forks. Storage on the North Fork has a higher yield per unit of storage capacity than storage on the main stem and, for this reason, some groups prefer the development of this water. Storage of North Fork water could be accomplished either with a reservoir on the North Fork or a large reservoir on the main stem with a pipeline or tunnel to the North Fork. Wildcat Reservoir would be a relatively small facility which could only store main stem water. Wildcat will be considered in the systemwide development of alternative scenarios. Such a reservoir could be a future component of a scenario which included a North Fork reservoir. 3 `I"n M LOCATIO MM alp •••• R - I I r- - v . . . • :f .,,, I .- m . r ,, k I NORTH — - - LEGEND o 1/2 1 : 5i TWO FORKS DAM-ELEVATION 8550' - SCALE IN MILES MAXIMUM POOL-ELEVATION 6550 W V1�� CONSTRUCTION AREA N ACCESS ROAD - -I / - ACCESSROADTODAM -- — ALTERNATIVE ACCESS ROAD yyy`�" - -- RELOCATED ROAD /I I - ( +� POTENTIAL SPOIL AREA - M' C CONSTRUCTION ACCESS ' � SRI ) - CC CONSTRUCTION CAMP AREA , q l a� A BORROW AREA f� 1 n 1\ EXIST STRONTIA SPRINGS DAM 1 Z . 1- — E%1ST. STRONTIA SPRINGS RESERVOIR •I\ .T' '_L_ _ L " ('_ a _ - as, m o B0 . Ce � X m - '' i�- m �' m g �, f - H if' I V A 1 S \. R1 m 'm H I y m r C MI "� Xi o Figure 1 4 } w cc I- W 0 N ~ < a. W Ln p m 0 a m f 0 LWL o J 0 0 F y¢ r x 2 z N _` W~ MEM a W pm N 4 z W N c� Q cc °z Ill a 4 3 ¢ W < 3= O U woMEI N F= N ® W I4N ( (In! No Cl) o cc W W o 2 dcc -46. i_..... e u. 4 E 6 ee Zj 0 7 Wet C "solid C 'a Z a r • F ap 0 R W M. Wm I dR e d� o 0 Ill `�d a O 2 W y C e ��4 m�Qr OP e� e 3 0.0 �� VIM Q — 2 v To o A 'I At‘si I P d Q o CP ~ rt O 0 0 O I; R e a Figure 2 5 CHATFIELD STATE RECREATION AREA EXISTING FACILITIES AND WATER SURFACE AREA River / 1 0,,0 9... 2•Cam'-. 4 8 8 J ( �' rf . `�� N N I 11 r •\ 30 12 13 • 26 . 28 // \\ ✓I 14I . " \ \ i ` � 1 \. 22 `. � 23 / .\ 29 `\ \ • \ x . 15 \ ` �^ i � .\16 .. 1 Y^'', 17 8 20 `.. \ 1 • \ �F r 19 • iC. .� \ i e i i Cif / l . LEGEND / 1 l //�i. SURFACE WATER I/ �p % % Cy ----•-• CHATFIELD STATE PARK BOUNDARY ® 1.Cottonwood Grove ►icnic Ares r 2.Stevens' Grove Picnic Area 17.Fox Run Plonk Area ,./ 1 ( 31 I ti V / 3. Owl Olen Picnic Ares16.Kingfisher Perking Area i it7f 4. Hatchery 10.Platte River Bridge L .g 8. Chatfield Overlook 20.Platte River Poking Ares 6. North Boat Ramp 21.Heronry Overlook 44 'C 1\ 7. Massey Draw Parking Area 22. Perk Office J1, ` 6. Corps Office 23.Model Airplane Field 4. ®/y0 ' 0. Visitor Center 24. Campy Area f /' 10. Deer Creek Inlet 26. Lakeview Perking J ti NORTH 11. Deer Creek Picnic Area 26. Riverside Picnic Ares 12. Swimbeech 27.Marine J1 13. Overflow/Baboon Launch 26. Plum Creek Picnic Area ' 0 1/2 1 14. Jamison Picnic Ares 29. Plum Creek Nelura Ares I H II I l MILES IS. Catfish Flats Picnic Area 30. Spring Gulch SCALE 16. Horse Corral/Livery 91.Dog Training Ares FIGURE 3 6 WILLIAMS FORK SYSTEM Three water sources were identified as candidates for site-specif- ic analysis under this category: Williams Fork Gravity, Williams Fork Pumping, and Gross Reservoir Enlargement. All three will be evaluated in site-specific detail and are illustrated on Figures 4 through 6. NO FEDERAL ACTION Five water sources were identified as potentially being used if Federal agencies were to deny applications for an upper South Platte River storage facility and for completion of the Williams Fork system. These water sources include: Conservation; Ground Water Development Within Municipal Boundaries; Nonpotable Reuse; Sewage Exchange; and Purchase, Lease, or Condemnation of Agricultural Rights. The analysis of these water sources will not be limited to the no Federal action alternative. These water sources, in various combinations, will be available for use in Technical Appendix 5 (alternative scenarios) for satisfying the near-term water demands. Conservation. Conservation is represented by five possible actions: metering of unmetered homes in the city and county of Denver, retrofitting homes which do not have water--conserving fixtures (toilets and low-flow shower heads), restrictions on the area of new lawns and/or the use of low-water requirement vegetation in new landscaping, implementing a leak detection program, and modification of price. One or more of these actions will also be part of the alternative scenarios developed as part of the systemwide analysis. The conservation analy- sis for the no Federal action alternative will be of sufficient detail that costs, yields, and impacts can be compared with the other site- specific alternatives. However, conservation has the potential for being implemented to different degrees with associated degrees of im- pacts to the individual water suppliers. The detail of information and analysis will be less than for the South Platte storage and Williams Fork water sources. Ground Water Development Within Municipal Boundaries. This water source has been expanded from Ground Water Under Municipally-owned Land to include Ground Water Development Within Municipal Boundaries. It is possible that, under no Federal action, municipalities would actively pursue the development of nontributary ground water under their boun- daries and not be constrained to land they own. The analysis will consider the volume of water available and the cost to develop the ground water. The analysis will not include design of well fields within individual municipal boundaries, but will utilize conceptual plans to develop costs. A major satellite well field that would provide water to the entire metropolitan area is included in the systemwide analysis. The satellite well field is considered a water source that would be devel- oped some time in the future. As such, it is available for inclusion in alternative scenarios. Nonpotable Reuse. Nonpotable reuse focuses on the possible use of treated wastewater in lieu of treated potable water for the irrigation of public lands and as a possible alternative to industrial raw or 7 NW, 2 w ,,s i0 £ tu M o. • i Y f • y¢ D ua uu G w; LLy Q a. at a `Ill a 3W wz w c g •-~ J W c� U 40 ,, —D - 3 o O "<�• � _ • Li CC = ii ; a _ W �� • / \•••.` ii la .1e • ) � /( h _ I,' ti 4.41 '3 : i , ' _ < , a n, I .� 1 4\ y y i u y �, //`` -A : d �L�'� "�� .lE I _ :- , � F i , Oil ` ,may_. S ♦• l yi a O < , J < R V ¢ < z o I . ; Ig o a ¢ o o - n W o o 5 v a LLW z o '" o o ` _ 3 ¢ o < o W EF, W I p V O O W W 2P, O O a O i u ' O i < Wm < z 3 x ¢ u 0 0 a 3 a J w , i1 ; 0 > ® IIi4I30 Figure 4 8 U)f l la v , z W W ° N CC " CC W O 0 wF o } Y F . u w � LLyy a >` °o . I 20 W .o o. 3> N 2 LL ~ o N. 0 a.IlJ 4:4 I- Ewa W < o o °za O U CC : aW z a Z • .3 2 I Y 0. J w 1' i 1 9 1 .1 ifr Q• N ti• . �. I x f 6 It ® 9� 1_ 1 _ I 0 00 O ° ✓ a pS o 2 Z • 0 <▪ a a a 0 2 Z = p is' o LT, Q o v: W u O 3 -I w i ¢ a ilI ! Figure 5 9 C 6 a s - CC o® - s i = m a z o O . 2 O e w J ; • W Z W ' ? • . e a. a. �wU m > e j W= en o. w e w i 3 I-,f, a 0 0 c E o < u Y 5ii, H X 43 ! cc . 11 I I O. d I LL a wl . .: _ owru � �� r X /Y.a��V� ff 'o' N 1 i`� I � ._ _ 9 r• ':-I' G A ti) z 1 {� JI P P. e ` Y�i.r e f W • ' 4 i t 0 •x off 17 �f // i i{i✓- 4 f. st.,..,,,?:". ry i A nJ Nfe m e r 3<. Od • e,,• r' )1 ` e , ai . / l Yr 4,. L P \F Figur• 8 I0 potable process water uses. Conceptual plans, cost estimates, and availability of water for potable reuse will be described. Impacts will be based on the conceptual plans. It is not expected that site- specific designs will be developed to conduct this analysis. Sewage Exchange. Sewage Exchange involves exchanging the DWD's treated wastewater for raw water upstream from Denver's intakes. Only transmountain diverted water can be exchanged because Colorado water law prevents exchange or reuse of in-basin flows. This analysis will focus on the details of the hydrologic accounting methods of the DWD and the effects of increased diversions at the Denver intake on the South Platte River downstream. No separate onstream storage project to optimize this water source will be considered because it would likely require a Federal permitting action and because the maximum yield potential may be achievable without storage. Purchase, Lease, or Condemnation of Agricultural Rights. In the event that no structural water sources were permitted, municipalities and other water providers might pursue the purchase, lease, and/or condemnation of agricultural rights. The analysis of this source will be focused on the senior agricultural water right holders in the South Platte River basin and headwater areas of the Colorado River basin. The analysis will consider water potentially available and the socio- economic and agricultural productivity effects of developing this water source. OTHER WATER SOURCES Several water sources that were candidates for site-specific analysis will not be studied in site-specific detail. Many of these are being evaluated as part of the systemwide alternative scenarios component of the EIS. Those water sources that are not used in alter- native scenarios will not receive further analysis. ALTERNATIVE SCENARIO WATER SOURCES These are water sources which, in addition to South Platte storage and Williams Fork alternatives, would be expected to be used in the development of alternative scenarios in the systemwide analysis. The water sources described under no Federal action are included in this category as well as: East Gore, Eagle-Piney/Eagle-Colorado, Straight Creek, Joint Use of Existing Systems, Ground Water, Potable Reuse, Bear Creek Operational Changes, Green Mountain Exchange, and Joint Use Reservoir. Information regarding the costs and yields of these water sources and their linkages in scenarios will be of sufficient detail so that scenario costs, operational effects, and cumulative impacts to key resources can be defined. Key resources are generally related to fish and wildlife, socioeconomic parameters, streamflows, and water quality. Project costs will be based on sufficient information to determine cost-effectiveness of alternative scenarios. Costs will include capital, operation/maintenance, and general mitigation. Ji OTHER SOURCES There are some water Sources that are not expected to be utilized in the development of alternative scenarios for the 5O-year planning period. Some represent water sources that could be developed over the very long term. Some are inappropriate to study further because there is no interest in sponsoring them. Many are conceptual in nature. These water sources include: Watershed Vegetation Management, Weather Modification, Importation, Lower South Platte Reservoir Pumpback, Fremont Fort Reservoir, and Wolcott Dam and Tunnel. The latter three, which have not received previous analysis, will be analyzed in recon- naissance detail to determine their suitability in the formulation of alternative scenarios. The first three have already been preliminarily evaluated in Technical Appendix 4 (water sources) and, thus far, have not been selected by any interests formulating alternative scenarios. 12 SECTION 3 ISSUES AND RESPONSES The COE received comments from the public, government agencies, and special interest groups at the public meetings held on the East and West Slopes during May 1984 and through letters received through 22 June 1984. These comments have been compiled and summarized into the following list of issues and concerns. A full set of comments can be reviewed at the COE Omaha office (U.S. Post Office and Court House, 215 N. 17th Street, Room 7015, Omaha, Nebraska 68102), at the Entercom office (425 S. Cherry Street, Suite 200, Denver, Colorado 80222), or at the Denver Water Department (1600 West 12th Avenue, Denver, Colorado 80254). The list of issues represents a consolidation of the issues raised during rescoping. This summary is intended to present the issues and concerns that the public, interest groups, and governmental agencies believe should be addressed in the S/SSEIS. In the process of consoli dating the comments, the potential exists that some issues or concerns may have been misinterpreted. If this has occurred, bring it to the attention of the COE by writing to the above addresses. 1. Issue - No permitting should be conducted prior to completion of the EIS. Response - No construction permits can be issued until after the final EIS has been prepared. 2. Issue - The Foothills agreement required a completed systemwide analysis of the planned DWD water supply. How can any site-specific analysis proceed? Response - The Foothills agreement committed only the involved Federal agencies "to conduct an analysis of any projects currently under construction and/or any future water development projects within the Denver water system which impact Federal resources, to determine the site-specific and cumulative effects of those projects. This will include an evaluation regarding their potential linkage to subsequent projects, consistent with the CEQ regulations (40 CFR 1500)." There is no requirement that one precede the other. Because of the change in schedule, which became necessary during the COE's midterm evaluation, an agreement was reached with the interested parties whereby some site-specific evaluations would be conducted now in exchange for added time to complete systemwide studies. The original systemwide aspect of the EIS, including scenario formation and evaluation, will be main- tained. The systemwide analysis and scenarios will remain a primary focus of the S/SSEIS process. The addition of site-specific work will enhance the systemwide analysis. 3. Issue - Institutional issues should be considered in the analysis of all water sources. 13 Response - The institutional issues will be identified and described for all water sources in the S/SSEIS. 4. Issue - The S/SSEIS should include evaluations of currently unused South Platte River basin water rights (mostly agricultural) owned by the DWD. Response - The DWD's current water rights and their yields have already been evaluated and presented in draft Technical Appendix 3 (existing water yields). A fact sheet summarizing the results of this evaluation is available by request. 5. Issue - The water source categories listed in the rescoping documents should be rethought. The West Slope diversion linkages to storage projects must be included. Response - The project categories are in response to the requested action by the DWB. Water source linkages are being evaluated as part of the alternative scenarios in the systemwide portion of the S/SSEIS. In addition, reservoir sizing studies will be conducted in the site- specific analyses to determine whether any of the DWD' s proposed reservoir sizes are dependent on future West Slope diversion projects. 6. Issue - The overappropriation of Colorado River water has resulted in a situation where any diversions will affect all downstream users and will reduce western Colorado's ability to meet Colorado River compact calls. Further diversions also could not be made up by Green Mountain Reservoir. The effects of these situations must be analyzed. Response - Colorado's obligation under the Colorado River and Upper Colorado River compacts is administered by the State Engineer's office. It would be inappropriate for the COE to make any such determinations. The compact documents specify that the State Engineer is the sole agency to administer the compacts in Colorado. The State Engineer will be requested to comment on the effects any water source or alternative would have on the ability of Colorado to meet its compact obligations. 7. Issue - The COE should not evaluate questions concerning the impacts of transmountain diversions on the administration of the Colo- rado River compacts within Colorado. Response - See response to Issue 6. 8. Issue - The possible impacts of alternative water sources and scenarios on the West Slope as a result of the administration of the Colorado River compacts should be addressed in the S/SSEIS for both site-specific projects and the cumulative systemwide analysis. Response - To the extent that data are available or reasonable assump- tions can be made and in consultation with the State Engineer, the issue of the impacts of future water sources development on the admin- istration of compact calls will be described and evaluated. 14 9. Issue - A statewide water management program should develop from the results of the EIS. The current population of the State combined with the anticipated growth will no longer make it possible for each provider to supply its own demand independently of other providers. The entire State will lose by poor and piecemeal planning. The State's water resources should be developed for the benefit of all of Colorado, including both the East and West Slopes. Response - The purpose of the S/SSEIS is to identify and evaluate alternatives which will satisfy the water demands of the Denver metro- politan area for the next 50 years. As such, the S/SSEIS will evaluate the benefits gained by operating the independent sources in a system— wide manner. It is not intended, however, to develop a statewide water management program. Such a program would be the responsibility of the State of Colorado, not the Federal Government. 10. Issue - All water sources should receive site-specific analysis. Response - NEPA requires that site-specific analysis be done on reason- able alternatives to proposed actions. In this instance, reasonable alternatives have been defined to include South Platte storage and the Williams Fork system. Some sources which would not be developed for 30 years or more would require another site-specific analysis prior to their development. To include them in the current site-specific analyses would not be an efficient use of the available resources. All potential water sources will be evaluated in systemwide detail. 11. Issue - The purchase of existing agricultural and industrial water rights should be studied in site-specific detail. Response - To the extent that such an analysis can be conducted, the purchase, exchange, lease, and/or condemnation of agricultural and industrial water rights are being evaluated in site-specific detail under the no Federal action alternative (see Section 2, Water Sources and Alternatives). 12. Issue - Ground Water Development Within Municipal Boundaries should be included in the site-specific analysis as part of the no Federal action alternative. Response - The Ground Water Under Municipally-owned Land evaluations will be expanded to include development of Ground Water Within Municipal Boundaries as part of the no Federal action alterna- tive (see Section 2, Water Sources and Alternatives). 13. Issue - The Joint Use of Existing Systems should be studied in site-specific detail. Response - The Joint Use of Existing Systems is part of the S/SSEIS analysis, but it is not part of the no Federal action alternative or other site-specific studies because, under water-short conditions, suppliers with surplus water or storage capacity would be unlikely to share on any long-term basis. 15 14. Issue - Watershed Vegetation Management and Weather Modification should be studied in site-specific detail, especially the effects they would have on wildlife and cost of insurance in the affected areas. Response - Neither of these water sources is contemplated to receive site-specific analysis (see Section 2, Water Sources and Alternatives). They are not viable alternatives to South Platte storage or Williams Fork and do not qualify as requiring no Federal action. 15. Issue - Potable reuse should be evaluated as a water source which could add to the yield of the Denver metropolitan area by the year 2000. Response - A potable reuse pilot plant will begin operation in 1984. No reuse water will be available for potable use until a minimum of 7 years of health and safety testing has been conducted. As a result, the time when such a source would be available is assumed to be beyond the year 2000. 16. Issue - The water sources included in the Environmental Caucus scenario should receive site-specific analysis. Response - Water sources receiving site-specific analysis are iden- tified in Section 2, Water Sources and Alternatives. The water sources which are part of the draft Environmental Caucus scenario will be evaluated in the appropriate detail relative to the site-specific water sources of others and near-term (to the year 2010) water demands. The draft Environmental Caucus scenario is currently being refined and additional water sources will be evaluated appropriately. 17. Issue - The Eagle-Piney/Eagle-Colorado and East Gore projects should undergo site-specific analysis, including their necessity as sources for Two Forks Reservoir. The effects of the projects on Eagles Nest Wilderness and ground water must be evaluated. Response - These projects will be evaluated as part of the alternative scenarios. It is not anticipated that these projects will be evaluated in site-specific detail but that costs and hydrology will be considered in a more detailed manner in order to determine their relationship to Two Forks. 18. Issue - Homestake II should be included in the site-specific analyses. Response - Homestake II is the subject of a separate EIS and permitting process. There is no need to duplicate that process. Homestake II is part of the S/SSEIS in that the yields of this project to Aurora are identified in the draft Technical Appendix 3 (existing yields) , it is identified as a potential project of others that could serve as an additional water supply source , and it will be included in the cumula- tive impacts analysis if permits are granted for it. 16 19. Issue — The S/SSEIS process must fully explore the possibility of the Windy Gap project providing at least short-term supplies to commu- nities in the northern Denver metropolitan area. Response - The current scope of work for the SEIS is considering the Windy Gap project, as well as other non-DWD projects, as potential water sources. These water sources are included in Section 2 under Joint Use of Existing Systems and Projects of Others. The results of these analyses will be presented in Technical Appendix 4 (water sources) . 20. Issue - The Williams Fork Pumping project should be studied in site-specific detail as well as the Williams Fork Gravity system. Response - Both the gravity and pumping projects are considered as alternatives for completion of the Williams Fork system and will receive site-specific analysis. 21. Issue - The enlargement of Gross Reservoir should be included as part of the site-specific analysis. Response - Gross Reservoir will receive site-specific analysis in the S/SSEIS as an alternative to the Williams Fork system. 22. Issue - The Straight Creek project should be included as part of the site-specific analysis. Response - Currently, Straight Creek will not receive complete site- specific analysis, but costs and hydrology will be considered in greater detail as part of the systemwide analysis. Straight Creek does not fit the definitions applied to the projects selected as alterna- tives to the requested projects (South Platte storage and completion of the Williams Fork system) and the DWB did not request a site—specific analysis. 23. Issue - The alternatives for the South Platte storage and Williams Fork projects should be able to meet the functions of the preferred projects. Response - While function is an important part of selecting alterna- tives, the identification of alternatives has not been constrained by the necessity to satisfy 100 percent of the function. 24. Issue - All viable alternatives must be analyzed at a comparable level of detail so that they are ready for permitting at the end of the EIS process. Response - All water sources cannot be developed in the same time frame as South Platte storage and Williams Fork. Thus, all water sources evaluated cannot be developed to permit detail. All reasonable alter- natives will be analyzed at a comparable level of detail. 17 25. Issue - Conservation should be looked at in site-specific detail, including metering, water restrictions, water-conserving devices, and landscape regulation. Response - Conservation will be evaluated to the highest practical degree. It is anticipated that conservation will approach site- specific detail for the Denver metropolitan area, but, by its nature, it is not possible to conduct a site-specific analysis in the sense of other projects. Sufficient information for comparative purposes will be provided on various conservation measures as available. 26. Issue - The Green Mountain Exchange should be studied in site- specific detail. Response - The Green Mountain Exchange will be analyzed at a higher level of detail than other far-term water sources. Certain aspects will be studied in more detail in order to determine the linkage to South Platte storage projects. A separate detailed study has been initiated by the Colorado Water Resources and Power Development Authority. The COE is coordinating its review of the Green Mountain Exchange with that agency. Information developed by the study, includ- ing detailed engineering studies, will be incorporated into the EIS if it is available prior to completion of the EIS process. 27. Issue - The Green Mountain Exchange should not be studied in site- specific detail because the issues facing it are too complex to solve quickly. Response - The Green Mountain Exchange will not be studied in site- specific detail because it is not an alternative to South Platte storage and because the time frame for development and implementation makes this water source a long-term option. 28. Issue - The Joint Use Reservoir should be part of the site- specific analysis. Response - The Joint Use Reservoir will be analyzed at a higher level of detail than other far-term projects. This level of detail will approach that of the site-specific analyses for costs and project hydrology. A separate detailed study has been initiated by the Colo- rado Water Resources and Power Development Authority. The COE is coordinating its review of the Joint Use Reservoir with that agency. Information developed by the study, including detailed engineering studies, will be incorporated into the EIS as it is available prior to completion of the EIS process. 29. Issue - The possible effects of the Green Mountain Exchange on Eagles Nest Wilderness should be evaluated. Response - All impacts of water sources will be identified and evalua- ted. The Green Mountain Exchange would not encroach on the wilderness. However, it could be used as a substitute for East Gore and Eagle-Piney in one or more scenarios, which would eliminate wilderness impacts of these two water sources. 18 30. Issue - Three sources are not environmentally acceptable: Impor- tation, Watershed Vegetation Management, and Weather Modification. Response - See Section 2, Water Sources and Alternatives. 31. Issue - A lower South Platte Reservoir Pumpback, a Wolcott Dam and Tunnel, and a Fremont Fort Reservoir should be analyzed as potential water sources. Response - These sources will be evaluated as possible additions to alternative scenarios. The level of detail in the analysis will be dependent on whether they are selected as water sources used in alter- native scenarios. 32. Issue - The condemnation of agricultural water rights is not legal and should not be emphasized. Response - Municipalities do have the right to condemn agricultural water rights. This method will be evaluated as a potential means for acquiring water rights. The impacts, including social and economic, will be evaluated. 33. Issue - The size of Two Forks Reservoir should be considered carefully. It should be large enough to meet the needs of the Denver metropolitan area but small enough that it would not encourage unlim- ited transmountain diversions. The sources required to fill it should also be evaluated in depth. If the Eagle-Piney/Eagle-Colorado and East Gore systems would be necessary, they should be studied in site- specific detail. The effects of the denial of the water rights for those projects must be evaluated. Response - The evaluation of alternative scenarios will include de- tailed information on the scenario hydrology. Two Forks Reservoir is estimated to yield approximately 98,000 acre-feet with 1.1 million acre-feet of storage capacity. This yield does not include future projects. The actual optimum storage capacity for the project, includ- ing linkages with other water sources, will receive considerable analysis in the S/SSEIS. 34. Issue - The costs for Two Forks must include the costs for the next added projects. Response - The costs for Two Forks alone will be developed in the site- specific analysis as will the costs of all South Platte storage alter- natives. Costs and effects will be developed for all components of the alternative scenarios. 35. Issue — Analyses for Two Forks should include wet versus dry years and a historical use perspective as if the reservoir had been developed over a period of record. 19 Response - The analysis of Two Forks and all water sources will include wet, average, and dry year conditions. A historical use period of 28 years is the basis for development of the safe yield and is explained in the draft Technical Appendix 3 (existing yields). 36. Issue - Two Forks Reservoir would be located in one of the most heavily used recreation areas of the State, which is close to both Denver and Colorado Springs. The impacts on that recreation must be evaluated, including the possible complete loss of recreation, impacts to rock climbing, fishing in a stretch of gold medal stream, and enjoyment of the riverine system. The differences between recreation in a free-flowing river system and that associated with a reservoir must be acknowledged and evaluated. The analysis of the replacement of recreation should consider recreation policies (especially those of the U.S. Forest Service (USFS)) and a reservoir recreation pool. Response - Recreational amenities of the South Platte River in the vicinity of the Two Forks project are recognized as significant re- sources. The site-specific study will provide a detailed analysis that will include existing recreational resources, resources lost, resources created, and identification of mitigation measures and costs to the extent mitigation is possible. The analysis will include the economic value of existing and future recreation opportunities. 37. Issue - Two Forks water quality should be modeled because it has a long detention time. Response - Two Forks water quality will be modeled after operational characteristics have been defined. 38. Issue - The possible failure of at least one dam in a series of dams on the South Platte River should be analyzed. If Two Forks is constructed, seven in-line dams would be located on the river. Response - Dam safety is a component of any dam analysis and will be included for all dams evaluated. 39. Issue - Two Forks should be considered as a transmountain diver- sion water source. Response - Two Forks would be a water storage facility that would store transmountain as well as in-basin water. 40. Issue - If only "reasonable and feasible" alternatives to Two Forks (which provide the same function as Two Forks) are evaluated, the S/SSEIS process will lose its creativity. Response - While function may be an important part of the review, identification of alternatives has not been constrained by the ability to fully meet each function. Two Forks has several purposes and functions, which could be met in a variety of ways by other water sources. 20 41 . Issue - The scenarios have to be established before alternatives to Two Forks can be developed because no single project can serve the functions of Two Forks. Response - See previous comments regarding scenarios and site-specific analyses in Section 2, Water Sources and Alternatives. 42. Issue - The effects of the Williams Fork projects on recreation must be evaluated and information should be included on the relocation and replacement of facilities. Response - All affected resources will he evaluated. 43. Issue - The DWD does not have a USFS right-of-way for the Williams Fork gravity system. This issue must be addressed in the EIS. Response - The Federal actions required for a project will be discussed under institutional issues. 44. Issue - If one of the Williams Fork projects is constructed , Williams Fork Reservoir water will not be available to compensate for the water diverted. Response - The S/SSEIS will look at the effects of the Williams Fork projects on Williams Fork Reservoir. 45. Issue - Importation should include the importation of water from the Columbia River system. The analysis should also include informa- tion that Federal agencies are assembling on the effects of that sort of project on the Ogallala Aquifer. Response - The study of importation of water from the Columbia River basin is prohibited by congressional act. Because Denver is in the Missouri River basin, no such prohibition applies to the study of importation from it as a source. Information generated as a part of the High Plains Ogallala Aquifer Study will be considered. 46. Issue - Ground water should he studied as an emergency water source, not a long-term continuous source. Response - Ground water will be evaluated under three conditions: 1) as a permanent water supply source under the no Federal action alter- native; 2) as a near-term potential source in lieu of allocating additional water taps for suburban growth; and 3) as a major water supply source for the Denver metropolitan area that would potentially be developed toward the end of the planning period (2035) . Both long-term and emergency management will be evaluated. 47. Issue -. The individual water sources should not be over- constrained. Trade-offs should be reviewed for all of the scenarios that are developed. Response - The major purpose of the scenario analysis is to evaluate the trade-offs of the scenarios. ' I 48. Issue - Wolford Mountain Reservoir should be built before Denver takes one more drop of water. Response - Comment has been noted. 49. Issue - If Una Reservoir is built as a joint use facility, its use should be restricted to agriculture and municipalities. Oil shale developers should pay for their own facilities. Response - Specific West Slope uses of a Joint Use Reservoir will not be evaluated, only identified. 50. Issue — A lot of money has been invested in the EIS in order to get a product by March 1986. Site-specific work should not be done on infeasible projects nor should the process be sidetracked by non- related issues at the cost of several months delay in the schedule. Response - NEPA requires only the analysis of reasonable alternatives and consideration of related issues. 51. Issue - The costs incurred by delaying the EIS should be borne by the agencies or groups that are responsible for the delay. Response - Comment has been noted. 52. Issue - The public should be involved throughout the EIS process. Public meetings should be held during the EIS preparation period and summary documents of each technical document should be produced and sent to the mailing list. Response - The public participation process of the S/SSEIS provides for public input following the completion of all draft documents. Public comments may be made in either public meetings or by written submit- tals. In addition, the preparation of the S/SSEIS has been integrated with the Metropolitan Water Roundtable, which provides a forum for the major water interest groups to participate in the process. Summary documents will be prepared and circulated to the public. 53. Issue - The S/SSEIS should look into alternative project financing methods, including 1) rate payers paying and 2) the builders/buyers paying. Response - Alternative methods of project cost repayment will be pre- sented and will include an identification of the effects the alterna- tives will have on the impact group. 54. Issue - The S/SSEIS must evaluate the impacts of projects on fisheries and wildlife and develop mitigation plans for those impacts. These include losses or changes in habitat, impacts to threatened and endangered species, the displacement of species, and the possible replacement of old species by new species. 22 Response - These resources and concerns will be evaluated in the S/SSEIS to determine the site-specific effects of selected projects as well as cumulative effects. Possible mitigation plans will be devel- oped as necessary. Beneficial effects will also be identified and discussed as they are applicable. 55. Issue - The S/SSEIS should evaluate the effects of projects on plant ecology (including threatened and endangered species) , changes in species composition, and wetlands. The S/SSEIS should also develop mitigation plans. Response — These resources and concerns will be evaluated in the S/SSEIS to determine the site—specific effects of selected projects as well as cumulative effects. Possible mitigation plans will be devel- oped as necessary. The analysis will also seek to identify beneficial effects to plant ecology. 56. Issue — The S/SSEIS must consider the hydrology of the project area and the hydrologic effects of projects. Response - The S/SSEIS will study these issues both from a site- specific and cumulative perspective. 57. Issue - The seismicity and geologic stability of project areas must be evaluated. Response - Geologic evaluations, including seismicity, will be included in all project analyses. 58. Issue — The S/SSEIS should evaluate the effects of projects on recreation and the water requirements of recreation and should develop mitigation plans. These evaluations should include both the loss and creation of recreation amenities, such as trails, fishing areas, access to areas, and campgrounds, among others. Response — These resources will be evaluated in the S/SSEIS as part of the site-specific analyses and to define cumulative effects. Possible mitigation plans will be developed as necessary. Beneficial effects to recreation will also be identified and discussed. 59. Issue - The effects of projects on cultural resources, including both historical and archaeological resources, must be evaluated. Response - These resources are being evaluated in the S/SSEIS to define cumulative environmental effects. Site-specific evaluations will also be conducted for selected projects. 60. Issue - The socioeconomic effects of projects must be determined. These evaluations must include the effects of projects on agriculture; the possible changes in lifestyles that could result from either the implementation or nondevelopment of a project; the effects on local housing, employment, and infrastructure; the effects on local busi- nesses and industries; the disruptions, usage changes , and costs 23 involved in route relocations of transportation corridors; the dis- placement of families and businesses; and the changes in tax revenues. Response - The socioeconomic effects of projects to both the East Slope and West Slope will be identified and evaluated. 61. Issue - The downstream ditch impacts in the South Platte River basin should be studied on all alternatives using the year 1950 to the present as the period of record for comparison. These impacts should include the economic and sociological issues of flows and return flows. Response - South Platte River basin hydrology will be evaluated from the standpoint of preproject conditions (which consider the maximum development of existing water rights) versus postproject hydrology for a dry year and an average year, as defined in the draft Technical Appendix 3 (existing yields). The analyses will consider economic and sociological impacts. 62. Issue - The lack of taps and the high price for those that are available are a concern. In Denver, the water tap is approaching 10 percent of the average cost of a new house. Response - It is assumed that these charges are for new homes outside of the city and county of Denver and that both water and sewer taps are included. The effects of these costs will be evaluated as part of the economic analysis under with and without project conditions. The analysis will also include the effects and impacts of paying for future projects with increases in water rates. 63. Issue — If development stops, existing populations will be re- quired to pay off past bonds. Response - Cessation of development of major new water sources and the effects on population growth and existing residents will be evaluated in the no Federal action alternative. 64. Issue - The no Federal action alternative should look at other sources of water taps, if the DWD has none, and the economic dislo- cation which would result. Response - The no Federal action alternative assumes that no Federal permit would be issued for either a storage or diversion project. The analysis, therefore, must consider alternative water sources and the reliability of those sources to support future development. Because a water source translates into water taps and new water taps represent future development, this issue will be addressed. The impacts of possible water shortfalls will be evaluated. 65. Issue - The conservation of agricultural water should be analyzed. Response - The conservation of agricultural water is not a subject of this analysis because it is not a water source available to the Denver Water Board or the Providers. 24 66. Issue - The water need for snowmaking in West Slope ski regions should be analyzed. Response - The socioeconomic effects of water competition will be anaylzed where appropriate. This will include existing uses. 67. Issue - The analysis of the projects must include bath direct and indirect costs and financing components. Costs should include previous expenditures, capital for construction and relocations, operation and maintenance, and mitigation. Indirect costs should include the eco- nomic effects of lost tax revenue of land versus the increased benefit to local economy due to new financial opportunity. There should also be consideration of no major water project development on metropolitan developers who have already made investments that could potentially not be recovered versus the costs to the rate payer for financing of major projects. Financial components should include alternative methods of financing as well as the consideration of some municipalities' need to repay current indebtedness. Response - Project costs for site-specific projects will include sev- eral elements. These elements will include capital costs which are made up of structural facilities, such as land, pipe, concrete, roads, facility relocations, and other appurtenances necessary to build the project. Other costs include operation and maintenance components, such as power, cleaning, repair, and mitigation. The cost categories will vary, depending on the project. The adverse impact that a project would have on the economy of an area is not a project cost unless it is mitigated. The impact will be identified and will become part of the trade-off analysis. The ability of Denver to pay to finance capital projects and float bonds are issues Denver and other water providers must address prior to proceeding with any project and are not appro- priate for evaluating as a part of the EIS process. This EIS will, however, consider alternative methods for repayment of the project costs and the effects those alternatives would have on the affected groups. To the extent that they can be quantified, the effects of projects on land use and land values will be evaluated for both "with project" and "without project" (no Federal action) conditions. All projects receiving site-specific analysis will be evaluated in terms of their economic benefits and problems for both the "with project" and "without project" conditions. 68. Issue - Considerations of the economic costs , benefits , and burdens of a proposal are largely policy matters for the consideration of the project proponent and, as long as they do not grossly distort the environmental effects of a project, are not a matter of concern in the environmental impact analysis and decision making. Response - NEPA states that "NEPA procedures must insure that environ- mental information is available to public officials and citizens before decisions are made and before actions are taken." It is, therefore, appropriate that disclosure of economic costs, benefits, and burdens to the project proponents' constituents be discussed in the S/SSEIS. The determination of whether these factors distort the environmental effects of a project cannot be made without those disclosures. The 25 ability of Denver or other providers to pay for projects is a policy matter but the consequences of those decisions on the public need to be identified. This S/SSEIS will, to the extent possible, consider alternative methods of financing and their effects on the affected groups. 69. Issue — The value of wilderness to the economy of the West Slope should be evaluated. Response - The economic value of wilderness will be considered as part of the recreational and socioeconomic analyses. 70. Issue - Helicopter access to wilderness areas should be evaluated. Response - No projects in wilderness areas are currently being proposed for site-specific analysis. Therefore, detailed analyses of the impacts of helicopters used in wilderness areas will not be necessary. 71. Issue - Wilderness areas should be studied on foot, not flown over or given some other superficial examination. Response - It is currently expected that only a limited amount of field work in wilderness areas will be conducted because East Gore and Eagle/Piney will not receive site-specific analysis. 72. Issue - Wilderness areas should not be established only to be destroyed by some form of development. Once they are destroyed, they are gone forever. Response - The systemwide analysis will evaluate the effects of pro- jects which would have an impact on wilderness areas. 73. Issue - County permitting requirements must be included in the institutional evaluations for each project. Response - All applicable Federal, State, and local regulations and permits will be identified and described. 74. Issue - When the DWD buys land for a project, it takes that property off of the local tax rolls but may continue to benefit from local services (fire and police protection). The project effects should be evaluated and mitigation plans developed. Response - The change in tax revenues as well as other socioeconomic concerns of projects will be identified and described as a socioeco- nomic impact to the affected communities and/or counties. Socio- economic benefits of the project to local entities will also be identi- fied. Mitigation of socioeconomic effects is a local concern. The COE has no authority to require social or economic mitigation. 75. Issue - The water supply systems to be evaluated in the S/SSEIS are to meet the demand for water by new Denver residents, who will use 26 the West Slope for recreation. The economic analysis should consider the environmental effects in relation to increased recreation use of the area. Response - Future increase in recreation demands resulting from in- creased population and leisure time will be considered in the evalu- ation of recreation and tourism impacts of water sources development. 76. Issue - If all of the available water on the West Slope is diver- ted to the East Slope, it will be extremely difficult for the West Slope to support its own growth. This should be evaluated. Response - Water requirements for West Slope communities and other future development represent a key element in the evaluation of water sources of the S/SSEIS. The need for future water supplies is based on existing supplies, forecasted demands, and current water resource development planning of the West Slope communities. The effects of transmountain diversions on future water requirements is being con- sidered. This analysis will not be related to specific uses, however, because there is no State water plan on which to evaluate the effects of diversions. 77. Issue - Compensatory storage should be included in all trans- mountain diversion projects on a one-to-one basis. The exportation of water from the Colorado River basin cannot cost the original basin. Western counties, especially headwater areas, have suffered great losses by transmountain diversions. Not all diverters have been required to build compensatory storage and, as a result, a lot of water has been lost. Both past and future storage is owed to the West Slope by the DWD. Response - As stated in the response to Issue 74, mitigation of socio- economic impacts is a local concern. The impacts will be disclosed, but the COE has no authority to require mitigation of them. 78. Issue - The proposed compensatory storage is completely inade- quate. Response - See response to Issue 77. 79. Issue - Thirty years ago, the DWD agreed to reserve 300,000 acre- feet of water for energy development in western Colorado. This agree- ment should be included in the S/SSEIS evaluations. Response - The accuracy of this statement will be determined. If correct, this issue will be evaluated as part of the institutional issues analysis. 80. Issue - The impacts of the Denver metropolitan area's integrated water system on the Nation's possible requirements for energy, in the form of coal and oil shale, by the years 2010 through 2035 must be evaluated. 27 Response - The S/SSEIS will present a description of the cumulative effects the implementation of alternative water development scenarios will have on both the East and West Slopes. To the extent that data are available or assumptions can be made, the cumulative analysis will identify the effects the scenarios would have on competing water re- source development interests. However, the S/SSEIS will not evaluate the Nation's possible requirements for energy or the ability of indus- try to obtain water to satisfy that demand. 81. Issue - Some areas, such as Denver, do not have adequate resources to support growth. The West Slope should not be destroyed in order for Denver to grow. Response - The economic, social, and environmental effects of potential new diversions on the West Slope will be evaluated. 82. Issue - A lot of money has been spent on the S/SSEIS to get a product by March 1986 when the DWD will be out of surplus water. The tap allocation program will be ending (December 1986). It is urgent that the site—specific studies go forward and not get sidetracked by other issues. The EIS is 80 percent funded by people outside of Denver and, in order to retire $34 million in bonds, these providers have to be able to collect tap fees. Response - The COE's goal is to produce the final S/SSEIS by March 1986. However, the primary objective is to produce a complete and defendable EIS for Federal agencies to use in their decision processes. 83. Issue - Water quality is affected by reduced water volume and the concentration of pollutants resulting from the removal of dilution water by diversion. Salt and other pollutants entering the river are concentrated as water volume is reduced. Several organizations are currently involved in the removal of salt from Colorado River water in order to meet the salinity requirements of interstate agreements. If diversions by the East Slope are going to further concentrate pollu- tants in the river, the East Slope should help to pay for the removal of those pollutants. This issue should be addressed in detail and coordinated with current Bureau of Reclamation (BuRec) studies. Response - This issue will be addressed at both the site-specific and scenario levels. The analysis will utilize BuRec studies and its formula for calculating salinity. 84. Issue — Salinity is not a problem in the Upper Colorado River Basin. The salinity issue should be evaluated from the basinwide approach rather than from the point of effects of individual projects in the headwater areas. The relationship between increased depletions from transmountain diversions and salinity control projects is not relevant to the S/SSEIS. Response - This issue will be addressed at both the site-specific and scenario levels. 28 85. Issue - Water quality in Dillon Reservoir and Summit County in general should be studied. Response - A detailed study of selected tributaries of the Blue River between and including Green Mountain and Dillon Reservoirs is currently being conducted. These data will be incorporated in the S/SSEIS. 86. Issue - The no Federal action alternative could result in increased concentrations of sewage effluent going down the South Platte River to Adams and other downstream counties, thus affecting reser- voirs, ditches, and wildlife areas. These effects must be evaluated. Response - These effects will be evaluated. The quality of effluent discharged into the South Platte River and the water quality that must be maintained in the river are regulated by the Colorado Water Quality Control Commission and are based on protecting the uses of the river. 87. Issue - The effects of projects on the National Pollutant Dis- charge Elimination System (NPDES) permits downstream from projects should be evaluated. Response - The hydrologic analyses and water quality analyses will include the minimum flow requirements for point source discharges and whether water quality degradation would be expected. Domestic waste- water treatment plants will be the center of this analysis which will focus on the Blue, Eagle, and main stem Colorado Rivers on the West Slope (to approximately the Utah border) and the North Fork and main stem South Platte Rivers (to downstream from Denver) on the East Slope. 88. Issue - The Providers have a need and a desire for a South Platte River basin storage facility to come online which will utilize their existing water rights. Response - Technical Appendix 2 (water demand) and Technical Appendix 3 (existing yields) will be used to determine timing of the Denver metropolitan area's need for water. The ability to utilize all rights will be evaluated. An objective of the S/SSEIS is to provide informa- tion which will contribute to sound water utility planning decisions. 89. Issue - Consolidated Ditches does not want to be left out of discussions of the reuse of water. The water going downstream, includ- ing its quality, is a concern. Response - As with other interests, downstream interests will have an opportunity to review and comment on the effects of development of the various water sources. 90. Issue - The population projections by the Denver Regional Council of Governments (DRCOG) have been found to include several inconsisten- cies regarding assumptions used in their development, which should be considered in the analysis. Response - All forecasts and the underlying assumptions associated with them have been reviewed. It is intended that the DRCOG policy 29 projections to the year 2000 will be used for developing water demand. For the years 2000 to 2035, modifications in the DRCOG assumptions will be made as directed by the COE. 91. Issue - The DRCOG population projections must be used because, historically, DRCOG projections have been low. Any Federal agency should use local government numbers for population projections. Response - See response to Issue 90. 92. Issue - The demographic and water use projections should account for the effects of the full costs of water supply scenarios on in- migration and future water use factors. Demographic projections should also account for other inhibitory effects on growth in the region (such as regional transportation problems, air quality trends, quality of life concerns, and Denver's relative competitive position compared with other areas) and should be explainable, consistent, and defensible. Response - The water demand model will be rerun after the full costs of projects are known in order to determine what reductions in water use will result from increases in water rates to pay for those future projects. The population projections used in the SEIS have been reduced to reflect a reduction in Denver's competitive advantage rela- tive to the rest of the Nation after the year 2000. This reduction in population growth reflects the expected declining quality of life as Denver becomes larger and more congested. 93. Issue - Is it possible that adding the population increase rates for all Sun Belt cities would result in a total population greater than the number of available migrants? Response - The development of a population balance for the Sun Belt region of the United States is not within the scope of this EIS. However, Denver's projected share of the total available migrant pool will be evaluated for reasonableness. 94. Issue - How will cumulative impacts be determined? Response - Cumulative impacts will be determined based on the informa- tion developed in Technical Appendix 4 (water sources) which presents specific impacts of individual water sources and by utilizing the sequence and timing of water source projects assembled in Technical Appendix 5 (alternative scenarios). 95. Issue - The effects of proposed West Slope reservoirs (for exam- ple, the Getty-Chevron-Cities Service reservoir on Roan Creek) should be included in the discussion of cumulative impacts. Response - Existing and other water resource development projects, which are determined to be reasonable and likely to occur, will be included in the cumulative impacts analysis as part of Technical Appendix 5 (alternative scenarios). Cumulative effects for major areas of concern (such as salinity, streamflow, threatened and endangered species, etc.) will be identified. 30 96. Issue — The COE should be aware of a planned transbasin diversion in northeast Colorado from the South Platte River to offset pumping that has taken place in the Ogallala Aquifer (in the upper Republican River watershed in northeast Colorado and southwest Nebraska). This project (Transcounty Water, Inc.) should be included in environmental evaluations of cumulative impacts and effects on threatened and endan- gered species. The project would use 200,000 acre-feet of South Platte River water. Response - All projects reasonably likely to occur which would affect both East and West Slope streams in the study area will be evaluated as appropriate in the cumulative impact assessment. 97. Issue - The EIS would seem to be biased automatically toward Two Forks and the Williams Fork gravity system. Response - The COE will not allow biases to be introduced into the process. 98. Issue - How will non-DWD sponsored projects have sufficient data to study in site-specific detail? Response - All projects which are to be studied in site-specific detail will have sufficient information developed to allow a comparative analysis. The DWD and the Providers are responsible for making such data available. This information will be collected or developed during the next year and will be available prior to preparation of the draft EIS. 99. Issue - Because the DWD and other metropolitan Providers are paying for the EIS, will the COE and its contractors be biased in their evaluations? Response - No. The DWD and the Providers are only paying for the systemwide analysis and for the data gathering for the site-specific water sources. The COE is using its own funds for administration and for preparation of the draft and final EISs. 100. Issue - Data should be acquired from sources in addition to the DWD. Response - Data from all available sources will be utilized. The DWD and the Providers , under third party contracting procedures, are responsible for providing all of the information necessary for the COE to prepare a final EIS. In addition, the COE and its contractors will determine the adequacy of all data for use in the preparation of the EIS. The COE and its consultants are also contacting other Federal and State agencies to determine what potential data requirements they will have. This information will be incorporated in the S/SSEIS. 31 Hello