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<br />."" <br />','~ <br /> <br />~ <br /> <br />;i <br /> <br />Water delivery requirements pursuant to interstate compact. <br />and the release and storage of water pursuant to section 602 of <br />the 1968 Act and the Coordinated. Long-Range Operating <br />Criteria, must not be changed or affected in any way by the <br />bill. That is to say. Glen Canyon Dam's monthly and annual <br />reservoir operations for compact purposes must continue to take <br />precedence over power operations (as is provided for by section <br />1 of the Colorado River Storage project Act of 1956 (the 1956 <br />Act) and by section 602(c) of the 1968 Act). and over flood <br />releases (as is provided for by section 602(a)(3) of the 1968 <br />Act) . <br /> <br />", <br /> <br />,.:. <br /> <br />.l <br /> <br />, <br />\_ i <br /> <br />In this regard. section 3 of the bill is confusing in that <br />it seemingly addresses all operations at Glen Canyon Dam. not <br />just powerplant operations. although section 5(b) calls for the <br />implementation of "power operating criteria." It is powerplant <br />operations. not monthly and annual reservoir operations. which <br />are at issue and to which the bill should be limited. <br />Furthermore. even if amended to refer only to the powerplant, <br />section 3 would still leave some ambiguity in that it <br />effectively amends section 7 of the 1956 Act without saying <br />so. <br /> <br />~" <br />~~ ' <br />;).;1 <br />rr <br /> <br />Consequently, we urge that section 3 of the bill be deleted <br />and replaced with language that specifically amends section ~ <br />of the 1956 Act to provide that the hydroelectric powerplant at <br />Glen Canyon Dam shall not be operated in a manner which has <br />significant adverse effects on the natural resources of Glen <br />and Grand Canyons. This would directly address the issue <br />raised by an April 26. 1988. memorandum of the Office of the <br />General Counsel. Department of Energy, which concluded that: <br /> <br />~'; <br /> <br />',; <br />;.. <br /> <br />" <br /> <br />~\, <br /> <br />-', <br /> <br />"I <br /> <br />Section 7 of the [1956] CRSP Act requires <br />that the ... Glen Canyon powerplant. must be <br />operated at ... [its] most productive rate <br />to produce the greatest practicable amount <br />of firm capacity and energy. The only <br />limitations on this requirement are that <br />priority must be given to meeting the <br />allocation of Colorado River waters <br />contained in the compacts and to the <br />delivery of water for irrigation and <br />domestic use. and operations must be <br />consistent with the Boulder Canyon Project <br />Act. the Boulder Canyon project Adjustment <br />Act. ... and the Treaty with the United <br />Mexican States. The operation of the dam <br />and powerplant for other purposes such as <br />recreation and conservation must be <br />consistent with the above prerequisites. <br />... [Memorandum at p. 5]. <br /> <br />With respect to section 5(b). the concluding phrase thereof <br />needs to be reworded to state that "the Secretary shall <br /> <br /> <br />-3- <br />