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<br />usbr/wapa <br /> <br />VII. Issues to be Addressed <br /> <br />Choice of Measuring Device for Compliance with the ROD <br /> <br />As described above, different measuring devices exist to measure the actual water releases from <br />Glen Canyon Dam. They all measure with a lesser or greater degree of error. Under the <br />USBR/W AP A MOU, the official record of compliance is the SCADA. This could be changed by <br />joint agreement of the two agencies. <br /> <br />Once a measuring device is established, a "tolerance level" should also be established due to the <br />inability of the operators of the dam to precisely control flows (this is an issue regardless of the <br />conclusion regarding "regulation", explained below). <br /> <br />Interpretation of the ROD as Regards Western's Operation of a Load Control Area <br /> <br />Because of changing conditions such as generator unit efficiency, generator loading and <br />transmission system fluctuations, it is difficult to accurately control releases from Glen Canyon <br />Dam. It is not as simple as just turning off a switch and no flow occurs. If the river limits are to <br />be considered hard limits, Glen Canyon will not be able to participate in electrical system <br />regulation as fully as if the limits were "target" constraints. In order for Glen Canyon to deliver <br />scheduled generation and to fully participate in power system regulation with Western, the down <br />ramp limit of 1,500 cfs and the upramp limit of 4,000 cfs must be hourly averages to achieve, not <br />hard inviolable limits. <br /> <br />An alternative is to limit the upramp to 3,000 cfs and the downramp to 500 cfs. This change <br />would allow for 1,000 cfs of operational flexibility. This flexibility would be used for <br />transmission system regulation. lbis would be the only way to more fully ensure that the ROD- <br />specified flows are not exceeded while allowing Glen Canyon Dam to participate in transmission <br />system regulation. However, this alternative would severely limit the capability of Glen Canyon <br />Dam to follow electrical demand on an hourly basis. <br /> <br />Iframp limitations, as specified by the ROD, are hard constraints, either Glen Canyon Dam does <br />not participate with Western in regulating a load control area to the extent it has been,.QI ramping <br />, to follow hourly load is much more severely limited than that described in the ROD. Is it <br />reasonable to interpret the ROD as requiring this choice? <br /> <br />Regulation and its Impact on the Ecology ofthe Grand Canyon <br /> <br />The impact of regulation, as differentiated from the impact of the "preferred alternative", should <br />be analyzed and/or monitored. This may involve simply paying greater attention to the flows at <br />the Lee Ferry gage and a broad dissemination of these data. On the other hand, it may require an <br /> <br />8 <br />