Topic 1: BOR introduced an arbitrary new “requirement” that Washington County needs a “second source” of water and then made this a critical purpose and need for the LPP, thus rejecting water conservation alternatives.
What the Draft EIS says or doesn’t say:
- BOR arbitrarily asserts that a “second source” of water, beyond an entire Virgin River watershed, is necessary for water security, and thus, conservation alternatives are rejected out of hand.
- BOR justifies the need for a second source based on forecasts of reduced flows in the Virgin River, ignoring similar reductions to the Colorado River. Indeed, Colorado River water users already face shortages.
- BOR analyzes impacts of LPP on Lake Powell, but never analyzes the reverse, whether Lake Powell can reliably provide water for the LPP. In many years the project will almost certainly be limited to low or no yield at all.
Why this is a problem:
- BOR provides no explanation or justification for how large a watershed should be to qualify as “reliable,” or when a community needs a “second source”; in fact, we’d still have just a “single source” of water—the Colorado River watershed.
- The “second source” of water for the LPP is the already over-allocated Colorado River, where flows are declining and expected to further decline due to climate change.
- The cost for a “second source” seems an unreasonable burden to place on the county—and our state—and not necessary if we would just lower our demand and use local supplies.
- BOR believes Washington County’s water supplies are not secure, even though we have dozens of wells, surface diversions, water retailers, and surface and underground reservoirs within the 2,800 square miles of the Virgin River watershed.
- The LPP will not meet the stated purpose and need, and the reliability is not addressed. The water supply analysis overestimates the reliability of the project being able to provide water for the pipeline.
- Colorado River flows are declining, so the cost of seeking a second source in Lake Powell—$1.8-2.0 billion—seems an unreasonable burden for such an unreliable source.
- The BOR must show that a “second source” of water is reliable; that water will be available in Lake Powell and that the LPP can be a permanent water supply.
- The BOR’s analysis of the security of the water supply for the LPP does not demonstrate that Lake Powell will be a reliable “second source”; it doesn’t meet the test for scientific integrity and accuracy of information required by NEPA.
- The BOR must provide examples of other communities with reasonable GPCD demand and which have similarly large watersheds and that have a “second source” of water before asserting that Washington County must have such a second source.
- Are you troubled because the BOR blindly accepted the assertion that “Washington County needs a second source of water”? Explain in your personal comment how you feel about this decision.
- Have you lived in another city/region where they did not have a second source of water and they managed to grow and thrive? Write comments about that experience.