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, . Mr. Robert Johnson June 30, 1999 Page Two so dependent on runoff and much less assured by long-term carryover storage in mainstream reservoirs. Major, diversions in the Upper Basin are generally upstream of major Federal mainstream reservoirs, must depend on site-specific runoff conditions and rely primarily on mainstream reservoirs to store and release water unused in the Upper Basin for delivery downstream to the Lower Basin in accordance with the provisions of the 1922 Colorado River Compact. Those reservoirs are also a source of direct use in the Upper Basin. Thus. long-term storage conditions in these mainstream reservoirs are critical to our ability to ultimately develop and rely on a portion of the 7.5 maf allocated to the Upper Division States. Therefore, the Upper Division States have a real and substar1tial interest in any criteria or guidance used to regulate water through the system. The above concerns. .along with the challenges that sustained high water supply conditions also present, brought the seven Basin States of the Colorado River Basin together with Reclamation to explore operational strategies for long-range planning purposes to balance the risks of floods and shorta'ges. These effortS culminated in a January 1986 report entitled "Colorado River - Alternative Operating Strategies for Distributing Surplus Water and Avoiding Spills." The underlying strategy recommended in that Report has been the basis of long-range planning for the past 13 years. These criteria Mave been reaffirmed by six of the Basin States . (except California) and remain our long-term operation objective. The need for "different" criteria seems to be unique to California and the Metropolitan Water District due to MWD's present water supply demand which exceeds its basic reliable water rights within California's normal allocation of 4.4 maf/year. Unless significantly more liberal criteria are utilized in making "surplus" declarations, the MWD's risk of water supply shortfall could exceed 50% in the near future. Without a California plan to get its demands under a normal year determination within its bIlsic allocation of 4.4 maf, there is no incentive to explore more liberal criteria. This is because all risk of shortages would be placed on the other States~ for the short-term benefit of California. When California successfully develops and begins implementing its 4.4 plan, the Upper Division States as well as Arizona and Nevada have indicated /I willingness to discuss more liberal strategies on a short-term interim basis (10- 15 years). (2) Format for Surplus Discussions. . The Upper Colorado River Commission continues to believe that the appropriate format for these discussions is not a NEPA process or within the two options identified in the public hearings. We recommend that because any criteria ultimately developed must be "interim," expire on their own terms, include storage triggers and be flexible enough to terminate IF sufficient progress is not apparent within California in resolving its internal water supply problem. The Annual Operating Plan process is the most appropriate format to be utilized. With the AOP process the Basin States, water and power users. tribal interests. Reclamation and other interested "publics' can continue to coordinate with each other to find a way to operate the reservoir system. Interim guidance or criteria as proposed by the six States could be another option.