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<br />OCT-19-1998 08:48 FROM GLENWOOD BLUEPRINT <br /> <br />TO <br /> <br />13038664474 P.06/12 <br /> <br />OOJ277 <br /> <br />II. Principles <br /> <br />There is no need or justification for the Secretary to modify the existing Operating <br />Criteria to accommodate the California 4.4 Plan. ~ke exi3tiR~ ~ElF&ti~ Cf'i.teria s:aewa sw~ u <br />.d'i'~anlt iR. ts;, ~"CRt the.lf. .d. pt..,., ;" t:l"t t1"l"lrl~,.,.,.....t,=r.l eR Beked~l~. ~Il'f ~'1.19'" -"'pil'::ttTt'\1" "UQe <br />~eeifl iJlll~ "rP'I .r:rit~ Instead of modifying the Operating Criteria, the Secretary should adopt <br />special interim criteria for releases of water from Lake Mead. The six states will prepare a more <br />detailed proposal that describes acceptable interim Lake Mead operating guidelines. The <br />following elements should be addressed in the adoption of the special interim criteria: <br /> <br />1.. No water user, including MWD and SDCW A. can be guaranteed or assured. of a <br />firm supply for any speci fied period. Any assurance or guarantee of supply to MWD and <br />SDCW A will create unreasonable risk to other states. Moreover, the Secretary of the <br />Interior does not have the authority to adopt any criteria that would assure any water user <br />of a full supply. Any interim criteria shall n.ot put unreasonable risk on the other states. <br /> <br />2. The interim criteria will not take effect until fum commitments are in place in <br />California to implement Phase I ofthe 4.4 Plan, including the execution of binding <br />contracts, agreed-on arrangements for transportation, and resolution of the quantification <br />and beneficial use issues. <br /> <br />3. Any interim criteria will be effective only for a specified period ofycarss ~fter <br />whicl,1 the interim criteria will expire on their own terms. The states and Interior will <br />need to discuss the time-frame for the interim criteria suggested in the MWD/SDCW A <br />agreement. After expiration of the interim criteria, the existing Operating Criteria will <br />continue to control operations, unless the Secretary modifies the Operating Criteria <br />pursuant to his authority and under the process set out in the Criteria. <br /> <br />4. Any interim criteria should include triggers that will implement different swplus <br />or shortage deliveries at specified target elevations of storage. Such triggers may.need to <br />include an assessment of the water available to MWD and SDCWA from all sources of <br />supply. The criteria should also include benchmarks, reporting mechanisms, and reviews. <br />by which California will demonstrate measurable and defined progress in meeting the <br />goals of the 4.4 Plan. If sufficient progress is not being made, the interim criteria should <br />automatically and by their own terms terminate or suspend, and operations will revert <br />back to the existing Operating Criteria 18 il.iff~} c.pptiatl. i.e. an A-70 strategy with no <br />look-ahead. V~...- <br /> <br />S. Any interim criteria will not be renewed, except following review. Phase 1 of the <br />Plan does not achieve reduction in use in California to 4.4 maf. Before Phase I is <br />complete and the interim criteria expire, Cali fomia should propose how the next phase <br />will be developed and implemented. Phase II should be developed and implemented by <br />2015. <br /> <br />Page 3 of 4 <br />