Comments Submitted to the U.S.B.R in Regards to the Review Of the Long Range Operating Criteria of the Colorado River Reservoirs
Lower Colorado Region
Attention: Jayne Harkins, BCOO-4600
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
It is our understanding that
the Long Range Operating Criteria provide for the coordinated long-range operation of the
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
Comments in Regards to the
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
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
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
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.
past 10 years, the
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.
Friends of Lake Powell strongly endorse the Annual Operating Plan (AOP) process. Furthermore, we believe that operation of the
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
Problems associated with increased salinity discharge due to low
· 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
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.
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.
The Executive Director of the Upper Colorado River Commission