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attacb.ent 21(c) 4Ilo]oradO Water Conservation Board Department of Natural Resources 72J State Centennial Buildmg 1313 Shcnl1an 5treet Denvrf. Colorado 80203 Pltooe (303) 8603Ml FAX (303) 860.4474 STATE OF COLORADO o Roy Romer Governor September 30, 1994 James S. Lochhead Executive DireclOr, DNR Daries C. Lile, P.E Director, CWCB Charley A, Calhoun Regional Director U.S. Bureau of Reclamation Upper Colorado Regional Office 125 South State Street, Room 6 I 07 Salt Lake City, Utah 84138-1102 Re: Proposed 1995 Experimental Beaeh/Habitat-Building Flows - Operation of Glen Canyon Dam Dear Mr. Calhoun: e As provided for in your memorandum of September 2, 1994, the Colorado Water Conservation Board and the Colorado Department of Natural Resources submit the following comments on the proposal to release up to 52,000 cfs from Glen Canyon Dam for a week in the spring of 1995, In addition to these comments, Colorado supports and joins in the comments submitted by the Upper Colorado River Commission and the State of Wyoming. , Initially, Colorado notes that the information provided to support the'proposal has been insufficient for meaningful consultation. As a number of parties pointed out during the consultation meeting on September 28,1994, only a preliminary, incomplete study proposal has been provided that does not adequately explain either the investigations to be undertaken during the research flows, or the scientific justification for this release. In particular, there has been inadequate justification for pushing forward such research in 1995, when reservoir levels will be too low to provide the 52,000 cfs previously identified as scientifically desirable, -- especially when later flood releases consistent with the Law of the River could provide the desired flow, e Neither Section 7 Consultation under the Endangered Species Act nor NEPA compliance has been completed. Both will be essential to evaluate the proposal, since comments from scientists during the consultation meeting made it plain that there are substantial amounts of scientific uncertainty about the impacts of the proposed release, particularly with respect to marshes, backwaters, and endangered species. Without an understanding of the relative costs, benefits, and risks to all resources, our ability to eomment is limited, Discussions with representatives of Reclamation during the consultation meeting indicate that a further comment period and a public hearing will be necessary after completion of the Section 7 Consultation and the Environmental Assessment. With that understanding, Colorado submits the following comments,