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There may be ways to reduce these potential economic impacts. For example, Western may be able to replace the lost 2-plus months of capacity by: (1) exchanging power through intertie arrangements with another producer with a different peak season, (2) purchasing power from another producer, or (3) generating capacity temporarily using a gas turbine. By combining the 2-plus months of capacity provided through these means with the months of unaffected summer capacity, Western could continue to market a 6-month block maintaining 47 MW of firm power. Flexibility of Power Operations Western has suggested that electrical generation impacts could be reduced by allowing some operational flexibility at Flaming Gorge during the period of constrained releases. The effects on firm power could be reduced significantly if releases of up to 4,200 cfs could be permitted for periods of short duration (1-3 hours) to address spinning reserve needs, generate against inadvertent flow (unscheduled energy on a transmission line), reduce emergency transmission line overload on the system, or meet peak demand when demand is especially high. This would allow Western to maintain it's marketable resources and eliminate need for replacement power, valued at $5.8 million annually. If this concept could be implemented, the only remaining impacts to Western, it's customer utilities and consumers would be those arising from rescheduled generation valued as a $298,189 annual economic loss at Flaming Gorge, and offset by a $47,000 annual economic gain at Aspinall over the long term). This would result in an estimated increase in retail rates of less than 0.2 percent. G. OBSERVATIONS AND CONCLUSIONS From the discussion above, several conclusions can be drawn. The Bureau's position is that there is considerable flexibility in operating Flaming Gorge and the Aspinall Units. The controlled releases proposed by the Service are easily within the operating capability of the reservoirs under normal operating conditions. The rescheduling of releases at Flaming Gorge causes a minor adjustment in release schedules, but average annual compact requirements are not altered. This conclusion is born out by a recent Solicitor,s opinion requested by the Bureau (attached). The opinion states "we are of the opinion that the Secretary of Interior may change the operation of the dam, provided there are well supported reasons, such as resource considerations, which require the change." 8