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<br /> <br />UPPER COLORADO <br />RIVER COMMISSION <br /> <br />ewes <br />MAY 0 3 1991 <br /> <br />355 South Fourth East Street. Salt Lake City. Utah 84111 . 801-531.1150 . FAX 801-531-9705 <br /> <br />May 1, 1991 <br /> <br />Hr. Roland Robison <br />Regional Director <br />Upper Colorado Region <br />Bureau of Reclamation <br />P. O. Box 11568 <br />Salt Lake City, UT 84148 <br /> <br />Dear Mr. Robison: <br /> <br />The Upper Colorado River Commission, on behalf of the Upper Division <br />States of the Colorado River, appreciated the opportunity to participate in <br />the process of reviewing the preliminary alternatives for consideration in the <br />Glen Canyon Dam Environmental Impact Statement (GCD-EIS), the public meetings <br />of April 1 through April 4, 1991 on this subject, and in providing these <br />comments. <br /> <br />We believe the description of the alternatives selection process in the <br />Colorado River Studies Office March 1991 Newsletter is helpful in identifying <br />both the internal and public process contemplated for completing the EIS. We <br />also believe the range of preliminary alternatives is sufficient to identify, <br />in a broad sense, the range of actions possible and the relative impacts. <br /> <br />We are not concerned at this point about the range of alternatives <br />nearly as much as we are about how t;he process of selection of "reasonable <br />alternatives" will be undertaken. <br /> <br />At tile public meeting in Flagst.aff, ri..rizona, InLerior representati-v-=.5 <br />stated that certain of the proposed alternatives were formulated outside of <br />the "Law of the River." That is, these alternatives would not protect the <br />primary operating mandate of water conservation. This is in spite of previ- <br />ously stated intent in the scoping notice to "develop environmental criteria <br />that will minimize, consistent with law, the impacts of operations of Glen <br />Canyon Dam on the natural resources of the Grand Canyon." This intent was <br />also repeated in the Bureau's "GCD-EIS Background Paper" and "GCD-EIS Develop- <br />ment of Alternatives" documents. Because of these stated intents, upon which <br />the Commission relied, we were disappointed by the Bureau's recognition that <br />four of the ten described alternatives violated the Bureau's own stated <br />guidelines. <br />