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<br />. <br /> <br />. <br /> <br />Paqe <br /> <br />eomments <br /> <br />1 3rd paragraph 2nd question. The phrase, "..consistent wI eolorado River <br />Storage (eRSP) water delivery requirements.." would seem to require <br />"greatest practicable amount of power and energy. . .". See Section 7 <br />of CRSP Act. <br /> <br />The second question to be answered by the studies is really the focus <br />of the effort. Western believes the first question is based on a <br />faulty premise; i.e., that existing operations can affect conditions <br />created by the same operations. In addition, the first question is <br />redundant; all that is needed is to establish the proper baseline <br />condition, then proceed to answer the second question. The Technical <br />Report seems to require some "impact" to justify'proposing the <br />possibility of altering operations. As noted in the letter, Western <br />believes a better approach would be to identify how much the <br />environmental resources could be improved, what the benefits would be, <br />and through what means such improvements would be accomplished. The <br />effects of implementing any recommended changes have been termed <br />outside the scope of the GeES, so a similar commitment to investigate <br />the effects of any proposed changes would be necessary. <br /> <br />General comment: The environment assessed is site-specific to the <br />river-re1ated environment of the Glen Canyon and Grand eanyon. Though <br />assessment of regional or national environmental impacts is well beyond <br />the scope of this study, to provide a proper perspective it should be <br />stated in the introduction that consideration of mOdifying operations <br />to reduce or eliminate fluctuating flows would have a most definite and <br />adverse impact on the ability to utilize the full Glen eanyon installed <br />capability. Such a change might result in the need by power customers <br />to replace the unavailable capacity with non-hydro (thermal, perhaps) <br />generation. Replacing a renewable resources with a non-renewable <br />alternative would most likely have wide-ranging environmental impacts. <br /> <br />Principal among these impacts might be (1) the impact to air quality. <br />(2) the depletion of the non-renewable fuel (coal, gas, etc.), and (3) <br />the economic impact or the impact to the human environment due to the <br />increased cost of alternative generation, to mention just a few. <br /> <br />5 1st paragraph. 2nd sentence. Statement re: recognition that changes <br />to operations might have negative consequences for other eRSP functions <br />is not consistent wI question No.2 on the 1st page of the Introduction. <br /> <br />The last sentence of the first paragraph indicates that the studies are <br />intended lito enable decision makers to assess the significance of <br />impacts. II Again, Western cannot agree with this approach. The studies <br />should allow the decision makers to determine if the increment of <br />optimization for the recreation and environmental resources is <br />justified in light of the changes that would be required to accomplish <br />the optimization. <br /> <br />2 <br />