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      From: Kristen Anderson <kleighanderson@gmail.com> 
      To: <snakevalley@utah.gov> 
      Date: Tuesday - September 29, 2009 8:20 PM 
      Subject: Undue haste 




      I understand and appreciate that the State of Nevada has rights to the 
      Snake
      Valley aquifer as well as the State of Utah, and that it is important to
      maintain good relationships with neighboring states and cooperate to solve
      disputes. However, neither state benefits from tapping an aquifer if there
      is not enough information to estimate the Available Groundwater Supply as 
      is
      specifically mentioned in section 2.4 of the proposed deal, especially 
with
      considerations such as seasonal variation and drought to be factored in.

      Furthermore, Section 2.8 recognizes that drawdown of the aquifer would
      "necessarily" have an impact on the hydrological systems of rivers and
      lakes. It may also potentially affect groundwater wells, such as those 
used
      in the region for agriculture.

      Agreeing to perform studies during operation, as opposed to identifying
      areas of concern and potential impact prior to budgeting and construction
      has a high potential for risk.

      No method for enforcing compliance to allocated and unallocated water use 
      is
      included in this plan, the same cautions being taken for reserved
      groundwater in Section 5.3 ought to be taken for allocated and unallocated
      water. There is no apparent reason other than the desire for 
implementation
      that the same caution should not be extended to allocated and unallocated
      water prior to construction and budgeting.

      Hydrologic Monitoring and Management Plans suggested in Section 5.2 have 
no
      oversight mentioned in regards to representatives of the other state.
      Re-consultation and withdrawal reduction in Section 5.4 may have negative
      effects on users in both states who rely on the already established
      withdrawals.

      The interstate panel in section 6.5 should be co-administered by both the
      Nevada State Engineer and the Utah State Engineer in order to adequately
      meet the claims of citizens of both states.

      In conclusion, this deal needs to consider the impact of withdrawal to 
      areas
      of concern and determine Available Groundwater Supply for allocated and
      unallocated groundwater before implementation. Also, citizens of both 
      states
      would be better served if representatives of both states are involved in 
      the
      drafting of Hydrologic Monitoring and Management Plans that withdraw large
      quantities of water, and also if representatives of both states administer
      interstate panels for adverse impact claims.