June 15, 1999

Western Association To Enjoy Rivers
P.O. Box 2151
Grand Junction CO 81502


Bureau of Reclamation
2764 Compass Drive, Suite 106
Grand Junction, CO 85106

 Re:  Comments on the Draft EA for Providing Fish Passage at the Price-Stubb  
  Diversion Dam

We believe there is another alternative that provides fish passage at the 
Price-Stubb dam besides removal of the dam or building an out-of-channel fish 
ladder.

The Colorado Riverfront Commission and the Western Association to Enjoy 
Rivers (WATER) Club retained Gary Lacy, a whitewater park engineer, to 
prepare a preliminary design for a boatable in-channel fish ladder that best 
mitigates all of the issues related to the Endangered Fish Recovery Program 
at Price-Stubb.  The proposed concept is to leave the dam in place and build 
a series of five naturally appearing weirs below the dam with pond or eddies 
between them so fish can rest before moving upstream to the next pond.  The 
crest of the dam would be modified slightly to create a more natural 
appearance.  This alternative achieves the following:

1.  There would be no effect on water level above the dam, so there would be 
no effect on the Ute Water intake, the potential for future irrigation 
diversions, landslide stability or river bank stability.

2.  The in-channel fish ladder would be designed for safe down river boating, 
removing a safety hazard and allowing boaters to float from Island Acres 
State Park to Corn Lake and Connected Lakes state parks.

3.  If access to the Colorado Department of Transportation (CDOT) property 
along the west river bank was developed, boaters and spectators could use 
hydraulic features of the in-channel fish ladder for whitewater sporting 
events.  Similar events in Salida and Durango bring in over $80,000 per year 
in tourism dollars.  This site has the potential for an Olympic quality 
whitewater park that could be utilized even at low water in early spring, 
late summer and autumn when other rivers are too low for whitewater sporting 
events.
  
Although this alternative probably costs much more than removal of the dam, 
the Colorado Riverfront Commission has agreed to apply for GO/CO lottery 
funds to pay for the excess costs.  GO/CO has indicated funds spent by the 
Bureau can be used as matching funds, so a major financial commitment by the 
City of Palisade or by Mesa County is not required.

Since neither the original Federal Energy Regulatory Commission (FERC) 
license for hydroelectric power at Price-Stubb nor the proposed amendment to 
the license are economically feasible, a power plant will not be built.   
This issue will disappear when the license expires or sooner if the licensee 
gives up or if FERC voids the license.  It may be possible to use GO/CO funds 
to buy out the licensee and the licensee's property located between the 
railroad and the CDOT land and give the property to the City of Palisade for 
a city park.

This alternative could allow for construction before 2002 and would eliminate 
the possibility that the Bureau might need to build an out-of-channel ladder 
if the license were still valid in 2002.  We urge the Bureau to consider this 
option.  A copy of the preliminary design prepared by Gary Lacy should have 
been provided to the Bureau in April.

Thank you for your attention.



Peter S. Winn
Whitewater Park Committee