Within a flurry of political, governmental and organizational activity regarding the Gooseberry-Narrows project, two letters highlighting public well being exchanged hands last week.
One letter was from the United States Army Corps of Engineers to the U.S. Bureau of Reclamation. The second correspondence was from a Carbon commissioner to the federal agency.
The proposed project's draft environmental impact statement is due to be released the middle of November. Activity by all parties has been increasing prior to the DEIS' release.
A nearly 100-year-old idea jumping on the scene numerous times since the early 1940s, the project involves damming upper Gooseberry Creek and creating a nearly 17,000 acre foot reservoir. The water would be diverted to the western side of the mountains to provide water for Sanpete County.
Opposition to Gooseberry-Narrows has come from numerous sources, including the Utah Rivers Council, Utah Power & Light and entities in Carbon County, where the water is used for agricultural, industrial and municipal purposes.
The first letter to BOR was from Brooks Carter, chief of the intermountain regulatory section of the U.S. Army Corps. Copies were distributed to public agencies and interested parties, including the engineers for the project, the Sanpete Water Conservancy District, U.S. Environmental Protection Agency, Utah Division of Water Quality, U.S. Fish and Wildlife Services, state wildlife resources and U.S. Forest Service.
Copies for Carbon County concerns apparently emerged as spin-offs from the original correspondence.
The U.S. Army Corps of Engineers was set up during the earliest stage of the development of the U.S. to help resolve problems on public works projects. The organization is primarily comprised of civilian engineers and science specialists who advise and assist agencies planning projects.
".. part of our responsibility is to coordinate with the appropriate agencies to ensure that the completed NEPA document satisfies the needs of the respective agencies," stated Carter's letter to BOR.
In order for the engineer corps to accept the National Environmental Protection Act document that is presently being revised, Carter indicated that "there are several areas that need to be further addressed or disclosed."
One objective of a NEPA document is to disclose how impacts will affect the entire area encompassed by a proposed project.
At the end of the letter to BOR, Carter identified 21 areas the corps feels need "additional consideration."
Carter's list included conservation, economics, aesthetics, general environmental concerns, wetlands, fish and wildlife values, flood hazards, flood plain values, land use, navigation, shoreline erosion and accretion/growth), recreation, water supply and conservation, water quality, energy needs, safety, food and fiber production, mineral needs, property ownership, public welfare and environmental justice.
Many of the listed items are similar to the concerns Carbon County organizations and residents have voiced regarding the construction of the dam.
Overall, the corps of engineers has two main concerns, namely "economics and environmental" issues, pointed out Carter.
"A thorough analysis of the overall economic gains and losses for each county affected should be presented," indicated Carter. "This analysis should not only address recreation, but should also consider items like energy needs and production, mineral needs and the overall needs and welfare of affected people."
The DEIS prepared on the Gooseberry project focuses on the benefits that Sanpete will derive from the completion of the project, but barely mentions the negative impacts on Carbon County residents, noted Carter.
Addressing environmental issues, Carter's letter referred to an evaluation of the Wild and Scenic Rivers Act by the U.S. Forest Service.
"The USFS study clearly identifies both Fish Creek and Gooseberry Creek as regionally unique important resources," states Carter's letter. "Because of this, we feel that it is important to emphasize that any proposed mitigation measures should replace these potentially impaired or lost functions and values on a 1:1 ratio as required by our policy."
The letter to BOR emphasized that all of the concerns should be addressed before the DEIS or final environmental impact statement is issued on the proposed Gooseberry project.
"This will finally force those in favor of the project to address the economic problems this could cause for Carbon County," pointed out Commissioner Mike Milovich on Monday .
The letter from the U.S. Army Corps of Engineers was the first correspondence BOR received last week from parties concerned about the dam.
Carbon Commissioner Bill Krompel also addressed the issues with the federal agencies not only in a telephone conversation, but in a letter that voices concerns regarding the actual costs of constructing the dam.
In the early 1940s, a tripartite agreement specified that Sanpete County entities would for part of a refurbished Scofield Dam in exchange for the right to build a water storage structure on Gooseberry Creek.
"In 1942, Sanpete Water Users Association agreed to $116,000 as their share of Scofield dam estimated costs," stated Krompel in the letter.
"However, when the Scofield Dam was finally built in 1946, the actual costs were $900,000. If we take one-half of the actual costs on Scofield Dam, $450,000, and inflate it to 2002 dollars, Sanpete Water Users would own $4,320,000 without any accrued interest," pointed out Krompel.
The actual cost of constructing the Gooseberry dam has become a major issue. Estimates have continually risen and questions whether the Sanpete group has secured the private property needed for the reservoir have surfaced. And apparently, the matter of earthquake mitigation has not been considered for the project, another costly feature of building any structure.
The issues and the concerns raised in Krompel's correspondence could add millions of dollars to a project that is pushing the $30 million mark.
Even though Sanpete has had the right to 5,400 acre feet of water since an agreement was signed in the mid-1980s, the county has not publicly acknowledged the use of any of rights, noted Krompel's letter.
In Utah, water ownership determinations are frequently based on "beneficial use" or whether entities are utilizing official rights for good purposes.
Krompel's letter maintained that Sanpete has not satisfied the beneficial use criteria in connection to water rights from the drainage system.
A significant part of Krompel's letter was based on a conversation the commissioner had with Kerry Schwartz from the reclamation bureau earlier in the week.
According to Krompel, Schwartz indicated that the timing for using the water was wrong for Sanpete. The farmers did not need the additional water until later in the growing season. But then, the water was not available.
The reason cited by Schwartz has been one of the explanations that Sanpete gives for building the Gooseberry dam - to keep water stored in reservoir for use later in irrigation cycles.
How the two letters may affect the federal agency's decisions regarding the release of the draft environmental impact statement or construction of the proposed Gooseberry dam remain to be seen.
But local government and water conservancy district officials continue to focus on stopping the dam's construction or make the Gooseberry project financially sound for Carbon County.
"The way I see it, the cost of this dam could be approaching $40 million with all that has come up," pointed out Milovich. "We will just have to see where it goes from here."