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<br />0014411 <br /> <br />-8- <br /> <br />" <br /> <br />I.ov.er Basin, - that some of the waters of the Colorado River system are be- <br />ing used "outside" above Lee Ferry. whereas all uses are "inside" below Lee <br />Ferry. Such an implication, which is not in accordence with ft\Cts. end ' <br />which results solely from the distorted boundaries of the adopted "Basin," <br />is unfair .to the States of the Upper Division. Colorado suggests that the <br />Report be revised to show the amounts of water involve" in present and po- <br />tential diversions from the Colorado River system below Lee Ferry for use <br />outside the natural basiil; that suoh quantities be listed individually and <br />be summarized separately from uses within the natural baSin, end be desig- <br />nated "export diversions." the seme as those above Lee Ferry; Imd that the <br />export diversions above and below l;:le Ferry be compared in arrount in the <br />basin-wide summaries whioh Colorado suggests be added to the Report. <br /> <br />18. The Report presents estimates of so~oalled "virgin flows," whioh <br />are not defined. and of so-oalled "depletions," which are inndequately de- <br />fined. and says, at page 61 "The Compaot divided the water on the basis <br />of virgin flows." Colorado suggests that the Report be revised to elimi- <br />nate all oomparisons between so-oalled "virgin flows" and compoct alloca- <br />tions of wate[', and all inferenoes that the two arn directly comparable; <br />and in defining depletions. aooount be taken of chs.nges in stream losses; <br />and further. that the Bureau not assign depletions or savings in stream <br />losses to individual projects. This suggestion does not mean that so- <br />called "virgin flows" should not be evalUated or appear in the Report. <br />for that term, if carefully and fully defined and consistently employed. <br />is useful in analyzing streamflow, water supply. and related data. At <br />the same time the Report should not state or infer that the "virgin flow" <br />quantities are the SaJlle as or are directly oomparable with th:l waters of <br />the Colorado~,Ri'Ver sys't'em that have been and are hereafter to be Ilppor- <br />tioned by the Colorado River Compact. <br /> <br />. <br /> <br />, <br /> <br />19.. While "virgin flows" are not defined in the Report, the quanti- <br />ties therein shown have been calculated as averages for periods of years. <br />commonly for the period 1931-1940 for stream @aging stations above Lee <br />Ferry, and commonly for the period 1897-1943 for stations below Lee Ferry. <br />Bureau of Reclamation representatives say that. in the revised final <br />draft, average values for both periods will appear for stations in both <br />basins. Colorado says that the Report as a whole should be based on long- <br />time averages. The purpose to be served by virgin flow estimates. mani';' <br />festly, is to forecast the average conditions to be anticipated in the <br />future., Hi th respect to nntural phenomena such as precipitation, and <br />the runoff and streamflow resulting therefrom, all planning for the fu- <br />ture is necessarily based on what has ocourred in the past. The best <br />evidence of what to expect in the future must be based on the available' <br />reoords of the past. Since neither the occurrence nor the sequenoe of <br />flood and drouth seasons and cye les of years can be forecast with ac- <br />curacy, Colorado suggests that virgin now quantities appearing in the <br />Report should all be based on the same period of years, in order that <br />comparisons may be made one with another; and that said period of years <br />should be 1897-1943, if that be the longest for wh,;",h streamflow records <br />are available, 0[' can be calculated from related information. That per- <br />iod is of sufficient length to insure that changes in average values, as <br />additional records become available, will p['obably be only of minor <br /> <br />( <br />