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<br />Ms. Jayne Harkins <br />April 16, 1999 <br />Page 2 <br /> <br />Surplus determinations are a part of the ongoing operation of the reservoir system under <br /> <br />e <br /> <br />the existing criteria The surplus determination specified by Article III(3)(b) of the Long Range <br /> <br />Operating Criteria includes specific guidelines: i.e. (I) the requirements of Article III(!) of the <br /> <br />Operating Criteria; (II) requests for water by contract holders and decreed rights; (III) actual and <br /> <br />forecasted storage; and (IV) estimated inflow to Lake Mead. We are not convinced that these <br /> <br />guidelines are in need of review. We believe that additional guidelines could include the method <br /> <br />used to arrive at surplus ( and storage) declarations and be developed as advanced in the letter <br /> <br />from the Six States to the Secretary. Further, that the guidelines be developed in conjunction <br /> <br />with the Annual Operating Plan including appropriate public participation. Once the process has <br /> <br />identified guidelines, implementation of them could be subject to NEP A review and clearance. <br /> <br />The opportunity to submit our comments is much appreciated. <br /> <br />e <br /> <br />~~IY' <br /> <br />Philip . Mutz <br />Upper olorado <br />for New Mexico <br /> <br /> <br />PBM:rav <br /> <br />cc: Upper Colorado River Commission <br /> <br />r\colorado\harkins. <br /> <br />e <br />