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<br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br /> <br />UUU4i'H <br /> <br />Nevada Comments on <br />Proposed OlTstream Storage Rule <br />April 3, 1998 <br /> <br />the Consuming State. This is of particular significance with regard to Arizona fifth priority <br />contracts. There is a fine, but real, difference between stating that it "will not be made available" <br />to those contractors and stating that it is outside their entitlements. <br /> <br />ID. Comments on the Environmental Assessment <br /> <br />The EA states in numerous places that more detailed NEP A (and ESA) analysis of specific <br />environmental impacts will be conducted in connection with Reclamation's consideration of <br />specific Interstate Storage Agreements. The Commission and the Authority support <br />Reclamation's conclusion that a more detailed review of such impacts could not reasonably be <br />conducted at this time, as any effects of a specific future transaction to be embodied in an - <br />Interstate Storage Agreement currently are too remote and speculative for meaningful analysis. <br />The nature and extent of any effects necessarily depend upon transaC!ion-specific factors which <br />cannot be ascertained outside the context of an identified proposal. <br /> <br />The Commission and the Authority would note, however, that the specific effects of future <br />Interstate Storage Agreements on Colorado River resources and the environment in general <br />should be expected to be insignificant. The Authority has evaluated long-term Colorado River <br />operations, utilizing Reclamation's computer models, simulating hydrology and incorporating <br />both upper and lower basin state diversion schedules. Results indicate there would be no impact <br />from the expected off stream banking. Diversions for interstate off stream storage would be no <br />greater than diversions expected without such storage (given trends as to the consumptive use of <br />basic and surplus apportionment in the lower division). The only new facilities that might be <br />constructed would be recharge facilities which likewise would be equally expected under the <br />intrastate part of the Arizona Water Banking Authority program. Operationally, the diversion of <br />the released water by the Authority at Lake Mead would result in a decreased diversion for <br />Arizona at Lake Havasu, but would not amount to a net loss in River flows. <br /> <br />We recommend that the EA state the reasons why detailed environmental analysis must <br />await a specific Interstate Storage Agreement being presented for the Secretary's approval. <br /> <br />9 <br /> <br />InlO155.4 <br />