Basin States' Comments on Draft Environmental Impact Statement, CO River Interim guidelines for Lower Basin Shrotages and Coordinated Operations for Lake Powell and Lake Mead

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-3- the interim period. Beginning in 2026, the potential risk of Upper Division curtailment will increase substantially due to increased development in the Upper Basin. Accordingly, Colorado believes the description in the DEIS of the geographic region affected by the Action will be invalid by the expiration of the interim period, and that it will be necessary at that time to reexamine management of Lakes Powell and Lakes Mead. Expiration of Guidelines. Expiration of the Guidelines in 2025 is critical toward Colorado's support of any preferred alternative. Continued operation of Lake Powell in a manner consistent with the proposed Action after 2025 may prove highly disadvantageous to Colorado. Moreover, as noted above, the assumptions upon which any proposed Action is chosen will no longer be valid after 2025. The DEIS correctly recognizes that the Guidelines implementing the Action will be interim in nature, and will remain in effect for determinations to be made through 2025 regarding water supply and reservoir operating decisions through 2026. However, the DEIS does not clearly state what default operating criteria will be relied upon after that date.3 As stated in the Basin States' Comments, the DEIS should explain that at the conclusion of the effective period of the Guidelines, the modeled operating criteria arc assumed to revert to the operating criteria used to model baseline conditions in the final EIS for the Interim Surplus Guidelines dated December 15, 2000 (i.e., modeling assumptions are based upon a 70R strategy f'or the period commencing January 1, 2026 (for preparation of the 2027 AOP)). These operating criteria would utilize the present 602(a) algorithm for calculating 602(a) storage requirements for releases from Lake Powell. As is more fully explained below, it is extremely important to Colorado that the Bureau continue to operate Lake Powell in a manner that serves the interests of the Upper Division States, and that sufficient storage be maintained in Lake Powell to protect Colorado's and the other Upper Division States' current and projected future uses. Accordingly, Colorado would object to any operating criteria that would alter any of the assumptions in the present 602(a) algorithm, and specifically objects to the proposed review of the 602(a) algorithm proposed in Arizona's DEIS comments and scoping comments. Consultation with Basin States in 2020. As mentioned above, Colorado believes it important that the DEIS identify default criteria for operating Lakes Mead and Powell after 2025. However, because of the importance of the management of Lakes Mead and Powell to the overall operation of the Colorado River System, Colorado believes it preferable for the Bureau to identify and develop new Guidelines for the management of Lakes Mead and Powell and the administration of the Colorado River System before the interim Guidelines developed through this process have expired. To ensure such action is taken, Colorado recommends that the Final Environmental Impact Statement and Record of Decision require the Bureau to initiate future consultation with the Basin States and other interested parties no later than 2020 to identify and implement appropriate management mechanisms for the Colorado River System following expiration of the proposed Action and implementing Guidelines. The Basin States Proposed Guidelines includes language that would require the Bureau to initiate such consultation. ' For example, the DEIS omits identification of what will happen after expiration of the proposed interim action in 2025 at pages, including but necessarily not limited to pp. ES-2, lines 6-13 and 1-1, lines 21-26. Flood Protection • Water Project Planning and Finance • Stream and Lake Protection Water Supply Protection • Conservation Planning