Comments Submitted to the U.S.B.R in Regards to the Review Of the Long Range Operating Criteria of the Colorado River Reservoirs


Friends of Lake Powell
P.O. Box 7007
Page, Arizona 86040

928 645-0229

December 6, 2004

Regional Director
Lower Colorado Region
U.S. Bureau of Reclamation
Attention: Jayne Harkins, BCOO-4600 
P.O. Box 61470
Boulder City, NV 89006-1470


Dear Ms. Harkins,

The Friends of Lake Powell appreciate the opportunity to provide comments on the 6th review of the Long Range Operating Criteria for the Colorado River reservoirs.

It is our understanding that the Long Range Operating Criteria provide for the coordinated long-range operation of the Colorado River reservoirs for the purposes of complying with the provisions of the Colorado River Compact, the Upper Colorado River Basin Compact, and the Mexican Water Treaty.

Additionally, we understand that a major objective of the 1922 compact is to provide for the equitable division and apportionment of the use of the waters of the Colorado River system.

Comments in Regards to the Long Range Operating Criteria

1.       It is critical for the Long Range Operating Criteria for reservoir operations to uphold the intent of the 1922 Compact.  The criteria should be flexible and responsive to variations in hydrologic conditions, and should not jeopardize the interests of the Upper Basin.

2.       The 1922 Compact anticipating drought conditions specified a 10-year, objective-based, water delivery schedule.  We note that the existing Long Range Operating Criteria dictate a minimal annual release of 8.23 million acre-ft from the Upper Basin, which is counter to the flexibility implied in the 1922 Compact.

3.       We are concerned that the Long Range Operating Criteria contain a requirement to equalize Lake Mead with Lake Powell during times of Upper Basin water surplus but that there are no provisions to equalize the level of Lake Powell with Lake Mead during times of Upper Basin drought as long as the Upper Basin is conditionally satisfying its 10-year water delivery obligations.

4.       Presently, there exists a large imbalance between the water volumes in Lake Mead and Lake Powell (14.3 maf to 8.8 maf), which have jeopardized the interests of the Upper Basin and put at risk the future generation of hydroelectric power at Glen Canyon Dam.

5.       Over the past 10 years, the Upper Basin has delivered more than 100 million acre-feet of water to the Lower Basin, which now in combination with drought conditions has prejudiced the interests of the Upper Basin.

6.       As such, the existing Long Range Operating Criteria need clarification that the minimal objective release of 8.23 million acre-feet stated in Long Range Operating Criteria is an ‘operating target’ which is subject to revision in the Annual Operating Plan (AOP) process.

7.       The Friends of Lake Powell strongly endorse the Annual Operating Plan (AOP) process.  Furthermore, we believe that operation of the Colorado River reservoirs can be optimized with each Basin sharing more equitably in the burden of drought.  This would be best be accomplished by maintaining, as equally as practicable, the active water stored in Lake Powell and Lake Mead (for so long as Upper Basin 10-year water delivery obligations are satisfied).

We note that the existing Long Range Operating Criteria have prejudiced the position of the Upper Basin and put the generation of hydroelectric power from Glen Canyon Dam in jeopardy.  The low level of Lake Powell affects many stakeholders and this includes impacts to:

  CRSP power customers, who include over 200 different customers and power marketing entities

  The City of Page drinking water supply

  The Navajo Generating Station cooling water supply

  Infrastructure at the Glen Canyon National Recreational Area

  Lake Powell recreational interests, and

  Upstream consumptive uses hastened by a potential ‘call of the river’


In addition to these stakeholder interests, there are further potential negative impacts associated with a drop in Lake Powell below the minimal power pool elevation:

·           The CRSP Basin Fund would become insolvent by 2007

·           Environmental Projects – 756 NEPA and ESA decisions could be reopened

·           Problems associated with increased salinity discharge due to low reservoir levels

·           Compromises to the electrical grid system including ‘black start’ capability, restricted power imports due to inadequate voltage support, the need to replace regulated power and spinning reserve and the termination of the Salt River Project transmission exchange agreement

In summary, the ongoing drought has put stress on the Colorado River water system.  It is our expectation that future “Annual Operating Plans” will contain more flexible water delivery provisions that will not only meet the general guidance of the “Long Range Operating Criteria” but allow a flexible response to changing hydrologic conditions that do not unfairly prejudice the position of the Upper Basin. 

 Using the AOP process, we believe that the U.S.B.R. can equitably manage the Colorado River to share water surpluses and the burdens of drought between the two basins while simultaneously honoring the delivery intent of the 1922 Compact. 

 Thank you for the opportunity to comment on these important matters.

Signed ,

The Friends of Lake Powell


Comments from the Upper Colorado River Commission


December 6, 2004

Regional Director Lower Colorado Region U.S. Bureau of Reclamation Attention: Jayne Harkins, BCOO-4600 P.O. Box 61470 Boulder City, NV 89006-1470

Dear Ms. Harkins:

On behalf of the Upper Colorado River Commission, we wish to respond to the Federal Register Notice for public comment on the review of the existing Coordinated Long Range Operating Criteria, (LROC), for Colorado River Reservoirs.

We do not object to the changes proposed in the federal register. However, we also wish to make the following additional comments regarding the content of the existing LROC.

The Commission does not endorse the assumption and objective in the LROC of a minimum release of water from Lake Powell of 8.23 million acre-feet every year. To date, no lower basin use and supply data have been presented to show that this release volume is required in accordance with the Compact. If such a number is used in the LROC, it must be understood that this is a planning objective which may be modified in the Annual Operating Plan to reflect current conditions and in accordance with Compact requirements.

We remain concerned about the drought and depletion of storage at Lake Powell. It is imperative that the LROC be interpreted to have sufficient flexibility to allow for modifications in the AOP as needed to reflect critical conditions and compact requirements. The Commission supports review of the LROC in accordance with the process and schedule in the Colorado River Basin Project Act of 1968. Decisions regarding the timing for the next review should be left open, as it may be necessary to begin the next review prior to the time suggested at the public hearing.

Thank you for the opportunity to comment.

Signed,

The Executive Director of the Upper Colorado River Commission

 

Friend of Lake Powell