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CWCB Supplemental Statement December 19, 1997 Page 3 . We oppose the call for reoperation studies on all federal facilities to find opportunities for environmental restoration and reallocation of water supplies and purposes. Instead such efforts should be targeted at specific critical reaches and regions where there is scientific demonstration that a problem exists and reasonable consensus on the means of solving the problem. We would offer the current endangered species recovery programs and ecosystem protection efforts ongoing in the Colorado and Platte River Basins as positive examples of what can be accomplished through consensus and partnership when problems are properly defined before flexible solutions are developed. Poor Documentation and Factllallrut~curacies: We have serious reservations about the issue specific side reports and river basin reports prepared for the Commission. We do not understand the process used in selecting the authors of these various "expert" reports, and are not aware that any procedure for peer review of their work was followed. We believe the Commission should exercise care in relying on the often conclusory statements presented by these authors, and are concerned that these background reports will soon be cited as authoritative sources in their own right. Some of the background reports are still not available for review (i.e., water quality), nor have we taken the time to provide an extensive review of those that are, but we do urge caution in relying on these reports as the definitive statement on the topics they address unless and until they are subjected to rigorous peer review. We have commented previously on several of the draft basin reports (in . particular the reports on the Rio Grande and the Colorado River) and merely renew our concerns with the individual views expressed by several of the authors. A cursory review of the final basin reports indicates that some of our comments were adequately addressed and many others were not. We are also concerned by factual inaccuracies and weak citations to secondary sources in the descriptive portions of the draft report. Two examples are provided for your consideration: 1. On page 2-5 you state: "Over the long term the [Colorado] river's annual flow is even lower, probably around 13.5 maf." The source you cite for this "fact" is Rodney T. Smith in "Proceedings: The Colorado River Workshop". While Mr. Smith is an acknowledged student of Colorado River matters, he certainly is not an authoritative source for analysis of the long term hydrology of the basin. The seven basin states have seen many estimates and studies of long term hydrology (i.e., extending beyond the . period for which reliable gaging data is available) and have not been convinced that any forecast other than a long term mean annual supply of 15 maf is appropriate for any current planning horizon. The complexity oflong term forecasts is glossed over by your reporting of a specific number as fact, supported only by citation to a weak secondary source. 2. On page 2-25 you state: "Water development for irrigated agriculture is responsible for 87 percent of all wetlands lost between 1950 and 1970 and 54 percent of 3 .