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<br />ATTACHMENT AGENDA ITEM 3 <br /> <br />. <br /> <br /> <br />V\7'ESTE:R.N STATES V\7'ATE:R. COUNCn... <br /> <br />Creekview Plaza, SuiteA-2011942 Ea.<t 7145 SouthlMidvole. Utah 1140471(801)561-5300 1 FAX (801) 255-9642 <br />Position No. 204 <br /> <br />April 19, 1995 <br /> <br />The Honorable Daniel P. Beard, Commissioner <br />Bureau of Reclamation <br />Department of the Interior <br />1 &49 C Slreet, N.W., Room 7654 <br />Washington, D.C. 20240 <br /> <br />Dear Commissioner Beard: <br /> <br />In January 1995, the Bureau of Reclamation invited the Western States Water Council ("Council") <br />to assist the Bureau in fostering state involvement in the federal water conservation program under the <br />Reclamation Reform Act of 19&2. The Council has made a good faith attempt to participate with the Bureau <br />in this effort. Our staff has devoted substantial time, as have many of our state representatives. The Council <br />agreed to participate in this effort with the Bureau because we believed it would promote a cooperative and <br />productive relationship with the Bureau, as well as reduce regulatory pressure on water users in our <br />members' respective states. <br /> <br />. <br /> <br />We were astounded when the Bureau published proposed rules on April 3, 1995 (Fed. Reg. Vol. 60 <br />No. 63, p. 16959), in advance of the close of the comment period on the guidelines. This action in effect <br />makes the guidelines mandatory, rather than the flexible mechanism for achieving conservation which was <br />initially represented to be the objective. <br /> <br />Our members, the state agencies charged with water management, planning, and water rights <br />administration, are responsible for working with the local water agencies and water users affected by this <br />federal regulatory action. To the extent that your published regulations now seek to impose federal authority <br />on water management actions covering state-administered water rights, the Council strongly opposes <br />implementation of these regulations. We firmly believe in the u1ility of conservation as a water management <br />tool, and were glad to note that your guidelines as originally released did recognize that conservation is not <br />an end in itself. The Council's intent is to facilitate the efforts of its member states to work cooperatively <br />with local waler users to make the most efficient use of their water resources in an economically feasible <br />manner. <br /> <br />We have grave concerns over the validity of the proposed regulations; the financial burdens they will <br />impose on water users; the regulations' potential effect on state-federal efforts in the area of water <br />conservation: their potential to interpose federal regulation in areas beyond the Bureau's jurisdiction; and <br />other aspects of the regulations and incorporated guidelines. These concerns will be communicated <br />separately by our members. Nevertheless, the Bureau's action jeopardizes the future ability of the Council <br />and its member states to continue working with you on the guidelines. <br /> <br />We would appreciate hearing from you as to whether, in view of the publication of the proposed rule, <br />continuation of our cooperalive effort has any merit at all. <br /> <br />. Sincerely, <br />" <br /> <br />D. Larry Anderson, Chair <br />Western States Water Council <br />