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<br />. .... <br />, <br /> <br />t <br />. <br /> <br />. <br /> <br />'-;"..~ -. r-.:-'."': <br /> <br />,- .-....---. <br />. .,\ ; ~.~.~;" <br /> <br />- <br /> <br />i ~ _ _' . <br /> <br />-- ~. <br /> <br />'- <br /> <br />MINORITY OPINION <br />IIEmRN AREA POWER AllMINISTllATION <br /> <br />IMPLEMENTATION OF INTERIM FLOW RElEASES <br />AT GLEN CANYON DAM AND NEPA C04PLlANCE <br /> <br />Western Area Power Administration (Western) does not concur with the Interior <br />members of the Executive Review Committee on the implementation of interim <br />operat1ons at Glen Canyon Dam. However, Western does support the continued <br />collection of data on the impacts of fluctuating flows during the interim <br />period with existing minimum release rates unchanged. <br /> <br />Western's position is supportable for the following reasons: <br /> <br />1. The illpll!llentat10n of 1nter1. flow requ1re.ents are unsupported by the <br />conclus10ns of the Techn1cal Report. The Technical Report exp11c1t1y <br />acknowledges that the ". . . understanding of the relationships between <br />dam opeTllt10ns and downstream resources is not complete," due to the <br />lim1tations of both the length and uncharacteristic high basin runoff <br />events which occurred dur1ng the stUdy period from 1983 through 1986. <br />Operat10ns during this t1me were clearly atypical. <br /> <br />2. The 111pll!llentat1on of 1nter1. flow requ1re.ents would clearly prejud1ce <br />the collect1on of data on fluctuating flows and "" future NEPA COIIpllance <br />docuIentat1on. By imposing interim flow releases in advance of the <br />definition of current conditions, consideration of a modified baseline <br />condit1on, and alternatives would most definitely be biased. Further, <br />collect10n of data on fluctuating flows and on varying alternative minimum <br />releases could still be accomplished without modification of existing <br />release restrictions. <br /> <br />3. The s1gn1f1cant loss 1n power benef1ts due to a change in .1nimum flow <br />releases has not been adequately addressed 1n the Technical Report or <br />cons1dered by all Execut1ve Review Committee members 1n their dec1s10n- <br />..t1ng process. The annual impacts to power and related power benefits to <br />Western's f1rm power customers due to the implementation of these interim <br />release restrictions for an assumed 2-year stUdy period are estimated to <br />be $9.2 million. However, should these restrictions continue indefin1tely, <br />the est1mated lost power benefits would increase to $21.8 million per year. <br />These lost power benefits represent a significant and widespread economic <br />1.pact to firm power customers throughout Western's seven state market area. <br /> <br />4. Unless ..tually agreed upon between ERC llellber agenc1es and the1r <br />const1tuents, illplementation of an interim release requirement without a <br />full public part1c1pat10n process would very likely be opposed by <br />Western's power contractors. <br /> <br />5. No clear defin1t1on of the pr10rities of aanagement and NEPA compliance <br />requirelents has yet been established. It has been agreed that unt11 <br />add1t10na1 legal review 1s made on these management pr10rit1es by <br />Interior's Reg1ona1 Solicitor and by Western's General Counsel. no <br />tion would be made by the ERC regarding the initiat10n of NEPA. <br /> <br /> <br />5399:03/22/88 <br /> <br />L63 <br />F1n <br />PI<<l : <br />