SubjectComment on the Draft EIS For the Lake Powell Pipeline
MessageDear Bureau of Recreation,
I’m writing to voice my opposition against the Draft EIS for the Lake Powell Pipeline project, which contains serious flaws. It completely ignores the importance of water conservation, ignores the impact of climate change on the Colorado River, and was written with a clear leaning toward new water development. As it is now written, the alternatives in this EIS would cause harm to everyone who lives in the Colorado River Basin, and the ecosystem that depends on its flows. One of the main flaws with the EIS is that the purpose and need statement disallows any study of a water conservation alternative. The statement reads that “The purpose of the Proposed Project is to deliver a reliable annual yield of approximately 86,000 acre-feet of water per year from outside the Virgin River Basin into Washington County to meet projected water demands in 2060.” This statement was clearly written with a bias toward the interests who have been pursuing the pipeline and not toward the public interest. A purpose and need statement like this is fatally flawed and prevents the BOR from being able to “rigorously explore and objectively evaluate all reasonable alternatives”, a key provision of NEPA. Since the purpose and need requires a new water source of a very specific amount from outside Washington County, the alternatives of 1) building a pipeline through the northern route, 2) building a pipeline through the southern route, and 3) building no pipeline leave no option to pursue comprehensive water conservation that could allow Washington county to meet future water needs with water efficiency like nearby counties have done. By omitting any thorough evaluation of a water conservation alternative, the EIS is promoting further water waste in Washington County, at great cost to its citizens and in spite of those of us who take steps to reduce our own personal use. The omission of studying water conservation is egregious, given that Washington County currently uses 302 gpcd of water, with the paltry goal of reducing that consumption to 240 gpcd in 25 years. In comparison, Phoenix currently uses 111 gpcd. Some form of a water conservation is clearly a reasonable alternative and deserves to be objectively evaluated. The EIS cites climate change research to project reduced flows from the Virgin River, Washington County’s current water source, but doesn’t acknowledge the same studies’ findings on the impact to the proposed future source, the Colorado River. One study cited in the EIS, by Udall and Overpeck, concludes that the Colorado River will likely see a 30% reduction of flows by 2060, which would jeopardize Utah’s ability to draw water from a new diversion. This EIS does not adequately assess these climate impacts and the subsequent changes in operations at Lakes Powell and Mead, which could prevent the pipeline from drawing any water. Until these serious flaws in the EIS have been addressed, and a conservation alternative is given rigorous exploration and objective evaluation, this EIS fails to uphold the provisions of the NEPA process and protect the interest of the public and the environment. Thank you
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