WSP04127

• File Number: 8220.101.09A
• Description: Glen Canyon Dam/Lake Powell
• State: AZ
• Basin: Colorado Mainstem
• Date: 2/1/1989
• Author: BOR
• Title: GCES Phase II and III Plan for Implementation and Addendum
• Water Supply Pro - Doc Type: EIS

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~. At the Economic Study Team Meeting in Phoenix on January 11
among your opening remarks you,stated: "Dr. Marchant asked me to
say that "The Bureau of Reclamation has not decided to change
anything [regarding operations of Glen Canyon Dam]." David
Marcus then asked, "Does this also mean that the Bureau of
Reclamation has not decided !l2! to change anything?" Dave ducked
the question with the respom', "You should talk with your
representative on the ExecuL Je Review Committee about that,"

I question the relevance of such politically rhetorical questions
from both sides, but since you dignified the power interest's
question of bias toward a predetermined course of action with a
public response, the environmental interest in the converse
question deserves a more adequate response than what you gave
Dave Marcus. For clarity and directness I'll cut out the double
negatives of Mr. Marcus' question and reask it here: "Has the
Bureau of Reclamation decided to change nothinq?"

4, Was the omission of any direct reference to "environmental
impact" or "impact on downtream resources" intentional..,
perhaps to offset any implication that this process was akin to
an environmental impact statement? The "effects" of operations
was referenced twice (pages 2 and 3) and the "impacts" of
operations was referenced twice (page 3), but left open as to
reference of impacts on the environment, power production, or
both. Curiously, "impact" was used in direct reference to
"Impact on the power user," (page 4) and reference made to
"impacted agencies," (page 6), But "environmental impact" was
used only once and only then as the subject of possible NEPA
process (page 7), "Impact" is a stronger word than "effect" and
it is used in reference to impacts on the power user and
agencies, and curiously omitted in reference to the environment.
This seems to indicate a bias toward greater concern over
"impacts" on power users and the agencies than "effects" on tne
environment! (Yes, you do have to dot every "i" and cross every
"t"; that's what this process is for,)

5, Let's turn to page seven; that's were I have the greatest
concern and it means harping back or. my longstanding position
that NEPA should be invoked now and not later, My underlying
criticism of Phase II and Phase III is that it is "power driven,"
not environmentally driven (for that matter, not even balanced,
all pretext aside.) By failing to invoke NEPA now complete
administrative discretion is left with the Bureau of Reclamation.
The opening paragraph to page sever. as much as says, "The
Department of Interior mayor may not implement any of the
recommendations of the ERC" and suggests no criteria for how it
will make that decision.

Reference is made to initiating the NEPA process onlv in the
event the basin states don't like the results! The only way the
basin states are going to like the results is if there is little