July 27, 2009
Ms. Rena Brand
U.S. Army Corps of Engineers
Denver Regulatory Office
9307 S. Wadsworth Blvd.
Littleton, CO 80128-6901
Dear Ms. Brand:
Thank you for this opportunity to provide scoping comments to the Army Corps of Engineers (Corps) for developing an Environmental Impact Statement (EIS) for the effects of the proposed Regional Watershed Supply Project (RWSP) sponsored by the Million Conservation Resource Group. Living Rivers is a non-profit organization based in Moab, Utah and dedicated to restoring the Colorado River ecosystem.
The Big Picture
For the past few years Colorado River water users have come to the realization that current consumption levels may not be sustainable. Colorado River flows over the past decade have been about 25% below normal, forcing the establishment of the first “Shortage Criteria” for the operations of Lake Powell and Lake Mead reservoirs. This new environment of scarcity was predicted as far back as the debates surrounding the authorization of the Colorado River Storage Project Act, and arguments presented in Arizona v. California.
Moreover, scientists continue to stress that drying reservoirs are likely to be a persistent problem in the coming decades due to climate change. Proposed depletions, such as the RSWP, will surely aggravate this condition. The EIS team should consult with the National Oceanic and Atmospheric Administration, Colorado University at Boulder, in developing an up-to-date analysis of the Upper Basin’s ability to utilize the proposed project under a full range of climate change scenarios.
At present, it is reasonable to assume that a 10% reduction in the Colorado River’s annual streamflow has already occurred, and that forecasting should be based on a mean annual flow of 13.5 maf. It’s quite possible that runoff could fall to 12.0 maf or less by mid-century. Such a reduction would certainly complicate deliveries for holders of new water rights in the Upper Basin.
Such hydrologic modeling should then be applied to complete a programmatic, basin-wide EIS to establish water budget for the Colorado River, perfect the water rights of federal reserve lands, and to develop and initiate programs to improve the ecological health of the Colorado River system as a whole. Neither the RSWP nor any other water supply project should be examined until some of the larger issues affecting the management of the Colorado River system have been resolved first.
Water Quality and Quantity
One of the provisions in the Colorado Compact of 1922 is that the water delivered to the lower basin not be impaired, which indicates that the commissioners considered water quality is just as important as water quantity. Development of water diversions in the upper basin is partly why Congress authorized the Salinity Control Act of 1974. Other authorizations by Congress of concern include the Clean Water Act of 1972 and the Endangered Species Act of 1973.
Extracting these flows from the basin will increase salinity for the lower basin, and deplete instream flows for the Green River above Lake Powell, and the delta ecosystem in Mexico. The Corps must determine how this depletion will affect critical habitat of endangered species, and assess the potential for salinity damage to downstream agriculture and urban water infrastructure.
Such an analysis must include increases in heavy metals, industrial toxins and waste from agricultural fields, oil and gas drilling, and mining (with particular emphasis in the renewed uranium mining in the upper basin). The Corps should therefore consult with the US Fish and Wildlife Service, the Salinity Control Forum, the Bureau of Land Management, and the Environmental Protection Agency.
Water quality impacts to Lakes Powell and Mead will also likely result. The dramatic remobilization of stored sediment in these reservoirs has already been observed in the present decade. These perched sediment deposits include toxins, heavy metals, salt, hydrogen sulfide and create a situation of lower dissolved oxygen in the water column. It would be appropriate to investigate these impacts and consult with the US Geological Survey and with the Technical Service Center of the Bureau of Reclamation at Denver.
Contributions to Global Warming
The gas-fired electric generating stations proposed for this project to pump water over the continental divide, and other divides of high elevation, will further aggravate the problems of a warming atmosphere on the water supplies of the globe. This cumulative impact must also be analyzed in this EIS for its contribution to diminishing water supplies over time.
It is our hope The Corps will use this opportunity to initiate a programmatic basin-wide EIS and not perform yet another piece-meal EIS that adds another layer of vulnerability to an already over-stretched water delivery system. The Colorado River system, as guided by the Colorado River Compact, is on the brink of collapse, as are the growing number of river reaches now designated as critical habitat. It’s time that the federal government exert the leadership necessary to assure the sustainable management of the Colorado River in the 21st century by developing a basin-wide strategy that puts conservation first and resists all efforts to extract more water from this over-taxed river system.
PO Box 466
Moab, UT 84532