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<br />e <br /> <br />e <br /> <br />e <br /> <br />, -' <br /> <br /> <br />UPPER COLORADO <br />RIVER COMMISSION <br /> <br />355 South 400 East . Salt Lake City. Utah 84111 . 801-531-1150 · FAX 801-531-9705 <br /> <br />April 19, 1999 <br /> <br />Mr. Robert Johnson, Regional Director <br />Lower Colorado Region <br />U. S. Bureau of Reclamation <br />P. O. Box 61470 <br />Boulder City, Nevada 89006-1470 <br /> <br />Dear Mr. Johnson: <br /> <br />We appreciate the opportunity to provide comments on your draft notice of intent <br />to solicit comments on the development of surplus guidelines for management <br />of the Colorado River. <br /> <br />The surplus (and shortage) guidelines that are the subject of the proposed notice may <br />be helpful in assisting the Secretary of the Interior in making determinations regarding the <br />storage and release of waters from the Colorado River System Reservoirs. These releases <br />are governed by the Colorado River Compact, the Colorado River Basin Project Act, the <br />"Criteria for Coordinated Long-Range Operation of Colorado River Reservoirs" (Operating <br />Criteria) and the decree in Arizona vs California. Operating Criteria presently require a <br />determination by the Secretary after consultation with representatives of the seven Colorado <br />River Basin States and others as the Secretary may deem appropriate. Developing guidelines <br />for the Secretary's use must be done within the context of these authorities. <br /> <br />The draft notice solicits comments for a National Environmental Policy Act <br />(NEPA) process. We believe such a process will overly complicate and delay successful <br />promulgation of the desired guidelines. Incorporating the process into either preparation <br />of the Annual Operation Plan or as development of Secretarial guidelines to be used in <br />the AOP process would more likely keep the issues focused within the context of the <br />law. After such a process has identified appropriate guidelines, the implementation of <br />said guidelines would be subject to any necessary NEP A and ESA review and clearance. <br />