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<br />OCT-19-1998 08:51 FROM GLENWOOD BLUEPRINT <br />000282 <br /> <br />TO <br /> <br />13038664474 P.10/12 <br /> <br />II. Princjo~~ <br /> <br />~ There is no need or justification for the Secretary to modify the existing Operating <br />Criteria to a~mmodate the California 4.4 Plan. The existing Operating Criteria should serve as <br />a default in the event the 4.4 Plan is not implemented on schedule, and upon expiration of the <br />special interim criteria. Instead ofmodif}ing the Operating Criteriat the Secretary shoul~ adopt <br />special interim criteria for releases of water from Lake Mead."lhtr six states will oreoare a more <br />petailef;l orooosal that describes accentab'e interim ~~ad Qoeratimz EUidelines. The <br />following elements should be addressed in the adoption of the special interim criteria: <br /> <br />a ,1. . No water user, including MWD and SDCW At can be guaranteed' or assured of a <br />firm supply for any specified period. Any assurance or guarantee of supply to MWD and <br />SDCW A will create unreasonable ris~ to other states. Moreover, the Secretary of the <br />Interior does not have the authority to adopt any criteria that would assure any w~ter user <br />of a full supply. Any interim criteria shall not put unreasonable risk on the other states. <br /> <br />b ~. The interim criteria will not take effect until firm commitments are in place in <br />California to implement Phase I of the 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 />e~. Any interim criteria will be effective only for a specified period of years, after <br />which 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 />d ~. Any interim criteria should include triggers that will implement different surplus <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 SDCW A 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 0'WIl terms temrlnate or suspend, and operations will revert <br />back to the existing Operating Criteria as currently applied, i.e. an A-70 strategy with no <br />look-ahead. <br /> <br />e i. Any interim criteria will not be renewed, except following review. Phase.I of the <br />Plan does not achieve reduction in use in California to 4.4 maf. Before Phase I is e-ver <br />comoJete and the interim criteria expire, California should propose how the next phase <br />will be developed and implemented. Phase II should begin imp1cmcmation before,; Of <br />immediettlYtipa1'i t:ft~ eamplet1al'l afPb.asc 1. :N~' imerim criteria, Of a roocwal efthe <br /> <br />Page 3 of 4 <br />