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River operation studies, both prepared by the Bureau of Reclama- <br /> tion (BR) . In the interim the staff has analyzed these reports <br /> and recommends approval of the draft letter of comments attached <br /> to Mr. McDonald ' s, March 14, 1984, memo to the Board members. <br /> These comments follow: (Appendix F attached) <br /> 1) Operations to date have been consistent with the seven <br /> state agreement. We agree with operations through <br /> spring 1984 provided they are justified by the <br /> forecasts. <br /> 2) Operations are apparently designed to achieve 7. 5 maf of <br /> available space on January 1, 1985, under the existing <br /> plan. Most of the available space occurs in Upper Basin <br /> reservoirs . This does not comply with 602(a) Storage <br /> Requirement and goes beyond what the basin states agreed <br /> to. <br /> 3) The operational studies requested have not been provided <br /> by the BR. The studies are required in the next several <br /> weeks in order to be useful. Operations after July 1, <br /> 1984, are what we really object to. Arizona, California <br /> and New Mexico have expressed the same concerns. <br /> 4) The essential part of the state position is that we will <br /> not agree to any available space target in excess of <br /> • 5. 35 maf absent a showing of either unique conditions or <br /> concrete proof that the 1982 Hoover Flood Control <br /> Regulations are invalid. Excess flood control space can <br /> only be reasonably justified through Spring 1984 at <br /> present. <br /> 5) The study plan presented on February 3 , 1984, has been <br /> initiated and is in progress without having received any <br /> state input into the plan. <br /> Mr. Felix Sparks, Colorado ' s representative on the Upper <br /> Colorado River Commission, was then asked to comment and explain <br /> further the position of the other basin states on this issue. He <br /> stated that the UCRC and its staff has thoroughly reviewed this <br /> matter and they concurred in Colorado ' s position and statement. <br /> He explained that the exceptional circumstances (Record flows in <br /> 1983, a high runoff potential in 1984 and damaged spillways <br /> throughout the system) have shown that operations to date and <br /> through the spring of 1984 are prudent and reasonable. It is <br /> operations in 1985 and beyond that are totally unjustified and to <br /> which we object. The Central Arizona Project, Dolores Project <br /> and Dallas Creek Project will come on line in the next 2 to <br /> 3 years, which will increase demands by over 1 .0 maf and place <br /> them at their highest level ever. Thus, these studies and <br /> operations should be looking at maximizing storage, which is <br /> • inadequate even when totally utilized, to allow the Upper Basin <br /> to develop its 7.5 maf apportionment. <br /> -9- <br />