CSU’s comments on Cove Reservoir Dec 31, 2020. Read Here.
Conclusions of our comments:
It is noteworthy that farmers along the East Fork are receiving less water in the summer, a pattern happening to agricultural producers across the West. Temperatures are rising, increasing evaporation and premature snowmelt and reducing summertime water supplies. The solution to build a dam will not likely provide extra water for the 100-yr life of the project. The East Fork, like most rivers in Utah, is already over-allocated. NRCS must determine, as best they can, how climate change will alter physical water available in these watersheds for the projected 100-year life of the project and who has the priority to use it before they approve such a large storage project. Water rights for Zion National Park, the Wild and Scenic River designation, and downstream senior water users need to be considered. Most importantly, NRCS must address the change of flow patterns in the summer within the famous narrow slot canyons of the Bureau of Land Management’s Parunuweap Canyon Wilderness Study Area (WSA) of 30,800 acres. This WSA boundary is fairly close to the project area along the East Fork and downstream of the burrow pits.
KCWCD claims they have already spent $2 million building the project piecemeal. The property for the reservoir was purchased, a pipeline was built double its original size from the proposed reservoir to the Orderville diversion, and they participated in the Orderville diversion. They left these vital components out of the environmental review of the Plan-EA. They applied for the NRCS grant in 2017 and three years later, in 2020, the project completes a watershed plan and an environment assessment omitting key information.
A major problem with the project is that it diverts water from the East Fork in two ways; building a dam to contain runoff from 4.7 square miles in eleven subbasins that would normally flow to the East Fork plus the diversion of mainstem East Fork flows into the reservoir. Both of these withdrawals from the East Fork watershed disrupt the natural flow of the river and neither are adequately analyzed in the Plan-EA.
KCWCD is claiming a benefit of the project, without evidence, of extra production of alfalfa for farmers on their existing fields and leaving a very small amount of water for the endangered fishes. It is unconscionable to invest $20 million of public funds to water yet more alfalfa that will further degrade natural systems.
As we outlined in these comments, the current Plan-EA is missing crucial information and many questions are unanswered. Therefore, the conclusion in the Plan-EA that there is no significant impact of the project on environment has no merit. There is inadequate analysis of impacts to Wild and Scenic River values downstream of the project. There is inadequate analysis of effects on imperiled species by reductions in flows in the East Fork Virgin River caused by diversions into the proposed reservoir. There isn’t any assurance offered that Zion National Park, or the Wild and Scenic values of the East Fork, or the Bureau of Land Management’s Parunuweap Canyon Wilderness Study Area (WSA) of 30,800 acres will be protected. These are National Conservation Lands set aside for future generations as pristine wild lands. NRCS and CSU have a responsibility to preserve these lands. Consequently, this project demands a full Environmental Impact Statement.
See links to the Plan-EA and more information Here: CSU’s Action alert to write letters
Proposed Cove Reservoir project to be delayed for preparation of an Environmental Impact Statement, Spectrum, January 22, 2021