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-4- <br />Coordinated Operations of Lakes Powell and Mead. Several of the proposed alternatives <br />in the DEIS, including the Basin States Alternative, call for a more coordinated operation of <br />Lakes Powell and Mead in hopes of more efficiently managing the Colorado River System <br />during the interim period. Under this coordinated operation, releases from Lake Powell may <br />vary based upon levels in both Lake Powell and Lake Mead, in the interest of limiting <br />shortages in the Lower Division, as well as reducing the risks of Upper Division curtailment. <br />Colorado has agreed to this approach toward reservoir management during the interim period <br />as described in the Basin States' Alternative and implemented through the Basin States' <br />Proposed Guidelines. <br />However, in adopting a preferred altemative for managing Lower Basin shortages as a result <br />of this or any future process, the Department of Interior and Bureau of Reclamation must not <br />lose sight of the primary purpose for which Lake Powell was originally constructed: "to <br />initiate the comprehensive development of the water resources of the Upper Colorado River <br />Basin ...making it possible for the States of the Upper Basin to utilize, consistently with <br />provisions of the Colorado River Compact, the apportionment made to and among them in <br />the Colorado River Compact and the Upper Colorado River Compact, respectively...." <br />Colorado River Storage Project Act of 1956 (43 U.S.C. § 620}. Accordingly, pursuant to the <br />Colorado River Storage Project Act, any system for coordinated operations of Lakes Mead <br />and Powell must not subordinate the need for Upper Basin storage to the interest of limiting <br />Lower Division shortages. <br />The Basin States Alternative maintains consistency with the Colorado River Storage Project <br />Act by imposing a minimum 602(a) storage level in Lake Powell of 14.85 million acre-feet, <br />which amount is then adjusted upwards annually. Colorado would strongly object to any <br />proposed alternative that does not similarly protect Upper Basin storage. Specifically, <br />Colorado would strongly object to any action, such as the proposed "Water Supply <br />Alternative," which violates the statutorily mandated requirement that sufficient storage be <br />maintained in Lakc Powell to protect future Upper Division development, or that otherwise <br />ignores, alters or amends the current mechanisms used to determine sufficient storage in <br />Lake Powell. <br />Mexican Treaty Shortage Issues. Colorado agrees with the other Basin States that the issue <br />of how and under what circumstances the United States will reduce the water allotted to <br />Mexico under Article l 0(a) of the Mexican Water Treaty of 1944 must be addressed in order <br />for the Bureau to develop a comprehensive program for administering the Colorado River <br />System and managing the Colorado River System reservoirs. Colorado believes that the <br />United States should reduce the quantity of water allotted to Mexico in any year the <br />Secretary reduces the water available for consumptive use pursuant to Art. II(B)(3) of the <br />Consolidated Decree. <br />However, Article III(B)(3) reductions are not the exclusive circumstances determining <br />whether the United States should reduce the amount of water allotted to Mexico under the <br />1944 Treaty. Other conditions may also arise that are reflective of extraordinary drought in <br />the Colorado River System under Article 10 of the Treaty. Resolution of the timing and <br />extent of reductions in the water allotted to Mexico has the potential to affect interests in both <br />the Upper and Lower Colorado River Basin. <br />Flood Protection • Water Project Planning and Finance • Stream and Lake Protection <br />Water Supply Protection • Conservation Planning <br />