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>rr. .U Gab io la, Area >lanager .-\ugust 3, 1982 Page Three 7, Operating Criteria at Glen Canyon Dam The City of Safford is strongly supportive of the continuation of the existing oPerating criteria at Glen Canyon Dam and opposes any manipulation of river flows which would reduce the current generating characteristics of Glen. 8. Contract Term The City of Safford cannot support too strongly its position that a resource of less than 20 years represents a materiaL and significant change: in the embedded cost of CRSP customers, A contract of less than 20 years changes the nature of the resource from a long term resource to a short term re- source and denies many preference customers like Safford which are small entities an adequate and fair opportunity to plan their systems around dependable, resources and the replacement thereof. A 20 year contract with provisions for reconsideration after 10 years based on hydrologic conditions would be fair both to the United States and to the customers. 9. CRSP Capacity Value The City of Safford believes that CRSP capacity should be sold on the basis of 75% exc~edance values with an option to customers for the purchase of additional capacity above adverse river conditions, and/or contingent capacity based at a rate re- flecting the contingency of .that capacity. In the alternative, Western should firm up the contingent capacity for its customers. 10, Federal Project Loads , In the absence of the jdevelopment of federal project loads, the power and energy shoUld be marketed through CRSP customers on a recapturable basis with a provision for five (5) or more years notice. This allows the classification of the marketing of the capacity as a fitm basis without denying federal project use loads the right '~o recapture as required. , 11. CRSP Reserved Cri~eria adequate' criteria The City of Safford reserve criteria and level of 10%. i be~ieves supports that 10% of loads is an the current CRSP reserve 48