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<br />if~ <br /> <br />""~' <br />.;"~ <br />:,f..c:' <br /> <br />about one in 20 years. This change in annual reservoir <br />operations at Glen Canyon Dam has been accommodated within the <br />context of the existing Coordinated. Long-Range Operating <br />Criteria. The States' Representatives and the Commission do <br />not believe that any further changes are necessary. <br /> <br />Position on H.R. 4498 <br /> <br />The States' Representatives and the Commission continue to <br />believe. as stated at the April 26 hearings on H.R. 4498. that <br />this bill is not needed in light of the steps which Secretary <br />Lujan has now announced he will take. However. should a bill <br />move forward. it must address the fOllowing concerns: <br /> <br />1. The bill's amendments to sections 1 and 3 of the <br />Colorado River Storage Project Act of 1956 (the 1956 Act) are <br />unacceptable. Amending section 7 of the 1956 Act to provide <br />that the hydroelectric power plant at Glen Canyon Dam shall not <br />be operated in a manner which has significant adverse effects <br />on the ecological and recreational resources of Glen and Grand <br />Canyons would be acceptable. <br /> <br />2. Water delivery requirements. section 602 of the 1968 <br />Act. and the Coordinated. Long-Range Operating Criteria must <br />not be changed or affected in any way by the bill. <br />Furthermore. Glen Canyon Dam's monthly and annual reservoir <br />operations must continue to take precedence over power <br />operations. as is now provided for by section 1 of the 1956 Act <br />and by section 602(c) of the 1968 Act. In these regards. there <br />are a number of ambiguities in the bill which need to be <br />clarified. especially as to what is meant by "emergency interim <br />o.perating criteria" in section 3 and by "new long-term <br />operating criteria" in section 4(b). In general. these <br />ambiguities can be resolved by providing for the promulgation <br />of new "power operating criteria" for Glen Canyon Dam. which <br />new criteria would be separate and distinct from the existing <br />Coordinated. Long-Range Operating Criteria. <br /> <br />3. The issue of flood releases has already been addressed <br />by the changes in reservoir operations which were implemented <br />in 1986-87. Therefore. references to flood releases in the <br />bill should be deleted. <br /> <br />4. Interim power operating criteria would interfere with <br />the test flow program which is being conducted for the Glen <br />Canyon Dam ErS. Indeed. the test flow program itself <br />constitutes interim operations. Therefore. interim power <br />operating criteria should not be implemented until the <br />completion of the test flow program. <br /> <br />5. The costs of the Glen Canyon Dam EIS. the Glen Canyon <br />Environmental Studies. and the purchase of power necessitated <br />by the test flow program should be funded from appropriations <br />for. and be treated as non-reimbursable mitigation costs under. <br />section 8 of the 1956 Act. <br /> <br />Amendments to H.R. 4498 <br /> <br />Amendatory language which would accomplish items numbered 1 <br />through 4 above is attached. <br /> <br />-2- <br />