BOARD01293

• Board Meeting Date: 5/24/1999
• Description: WSP Section - Colorado River Basin Issues - Upper Colorado River Commissioner's Report
• Board Meetings - Doc Type: Memo

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Mr. Robert Johnson
April 19, 1999
Page 2

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The Upper Division States as well as Arizona and Nevada have proposed to the
Secretary "interim" guidelines for consideration as California implements a process to live
within its basic apportionment in "normal" determination years. Such interim guidelines are
by their own definition temporary. These interim guidelines would be incorporated into the
AOP process to assist California in meeting its urban water supply needs while adjusting its
in-State demands over time. Using the five-year review of the Operating Criteria as a forum
is inappropriate because the development of interim guideiines for the purpose of carrying
out the mandates ofIII(3) of the Operating Criteria will not modify the Operating Criteria.

The Commission believes that these interim guidelines should only be developed
within the AOP process perhaps through the technical work group. The AOP technical
work group can facilitate discussion and implementation of interim guidelines concurrently
with the ongoing process of developing the 2000 and succeeding years AOP's. The AOP
process already provides the opportunity for public participation as required by the Secretary.
We recommend that the draft Federal Register notice be redirected to advise the public of e
the intent to begin this process of developing secretarial interim guidelines through the AOP
process and invite the public to participate.

Very truly yours,

~~WtL- g

Wa E. Cook
E e tive Director

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WEC:pj

cc: Charles Calhoun, Regional Director
Upper Colorado Region, U. S. Bureau of Reclamation
Jane Harkins, Water Operations
Lower Colorado Region, U. S. Bureau of Reclamation
Upper Colorado River Commissioners
Lower Colorado River Basin Representatives

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