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<br />.002866 <br /> <br />. <br /> <br />. <br /> <br />f) Fulfillment of this item is open for debate given the <br />results presented in the attached table. <br /> <br />In conclusion, the criteria used in CRSS/CRSM appear to be <br />in accord with the "law of the river" to my understanding with <br />the ~ollowing two exceptions. First, I cannot find any reference <br />permitting allowable shortages or there charge against the Upper <br />Basin other than through the Secretary of Interior's <br />discretionary power. Thus, reducing allowable depletions by <br />6.l2~ may not be appropriate. The apparent justification <br />provided for this relates to river calls, water availability and <br />use conditions; but substantiation beyond that presently supplied <br />is needed in my opinion. <br /> <br />Secondly, the assumption is made that the upper basin <br />depl~tions are limited to 5.8 maf based on results of several <br />water availability studies. While this may be reasonable at <br />present it is certainly subject to change with the hydrologic <br />conditions. The 602 (a) storage requirements would be <br />significantly larger if a 7.5 maf maximum depletion level were <br />used, and it would be in the best interests of the upper basin to <br />at least evaluate this situation further. <br /> <br />l~e other issues to watch are the standing 8.23 maf versus <br />7.5 maf objective minimum delivery, the sediment accumulation <br />computation and the lower basins desire to have probability <br />levels included in the computation as opposed to or in addition <br />to the critical period of record. <br /> <br />Recorrunendations <br /> <br />The method of computing 602 (a) storage in CRSM appears to <br />provide the UIJper Basin with very Ii t tIe protection beyond <br />minimum power pools until depletions in excess of 5 million acre <br />feet occur. Implementing the following recorrunendations would <br />help improve protection to upper basin reservoirs under 602 (a) <br />and result in storage levels more in tune with the intent of this <br />subs~ction. <br /> <br />A. Clarify for the record that the 5.179 maf referred to <br />in step 4 represents live storage. <br /> <br />B. Request model studies be provided that show tile <br />difference in 602 (a) storage requirements using 7.5 <br />maf in place of 5.8 maf when determining the critical <br />record period and corresponding results. It would also <br />seem appropriate to have a water availability study <br />process which would update the hydrology data base <br />every five years and make new water availability <br />projections. <br /> <br />-4- <br />