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STATE Of CALlFOINIA-THE RESOURCES AGENCY Pete Wilson, Governor _.__. _._ _.nn, ._ COLORADO RIVER BOARD OF CALIFORNIA 107 SOUTH BROADWAY, ROOM '103 LOS ANGELES, CALIFORNIA 90012 (213) 62()..4480 @ . t'Nr,p May 1, 1991 tlI~" C'NC~ .. () ~. 199' Colorado River Studies Office - UC 1512 Bureau of Reclamation P.O. Box 11568 Salt Lake City, UT 84147 Comments on Selection of Alternatives for Glen Canyon Dam Environmental ImDact Statement The Bureau of Reclamation conducted extensive public scoping sessions in the spring of 1990 as part of its Glen Canyon Dam Environmental Impact Statement (GCD-EIS) process, has consolidated the information gathered on issues and concerns received during the scoping sessions and has identified a number of alternatives to be considered in the GCD-EIS. A total of ten preliminary alternatives were presented to the public in early April by the Bureau of Reclamation and the agencies cooperating with the Bureau in the preparation of the GCD-EIS. While we understand that it is the intention of the Bureau of Reclamation to be responsive to the many and varied comments received at the scoping sessions, it is our opinion that the ten "preliminary alternatives" presented to the public are not all viable alternatives in the true sense of the NEPA process. Rather, these ten alternatives are an extension of the research effort and should be utilized to further refine the impact analyses on the resources of Glen and Grand Canyons associated with varying operating conditions at the Glen canyon Dam and Power Plant. This phase of the study effort should be characterized as a pre- alternative formulation phase and not the alternatives study phase. The "preliminary alternatives" can be utilized to form the bases upon which the formal alternatives to be documented in the GCD-EIS are developed and subjected to the full economic, environmental, social, etc impacts evaluation and compared to the no-action alternative. Also, the information developed during this phase of the GCD-EIS process will be useful in identifying and analyzing the impacts associated with the alternatives to be fully evaluated in the GCD-EIS. Only reasonable and viable alternatives should be identified and evaluated for the alternatives study phase. On page 15 of the March 1991 (Volume 3) Colorado River Studies Office Newsletter entitled "How to Define Reasonable Alternatives," it is acknowledged that "there is need for continued discussion on whether the alternatives presented are considered to be reasonable