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~~) CC~fJ1r Juc r..lbu. I'rcsic.lcnl c/u td;:lIkura ":',IlCI lJistlicl 1'.0. Bux 260 \,'odde", AZ 85355 602-975-2151 CREDA COLORADO RIVER CNCRGY DISTRIBUTO[~S ,\SSOClk110N RECEIVEP August 23, 1989 AllG2F't;- OQ,ORAOll W~ T~, ct,....l __~'n01" BOAP.O The Honorable Manuel Lujan Secretary of the Interior u. S. Department of the Interior 18th and C Streets, Northwest Washington, DC 20240 Dear Mr. Secretary: On July 27, 1989 representatives of the Colorado River Energy Distributors Association along with representatives of the Colorado River Basin States and the Upper Colorado River Commission met with you to discuss the preparation of an Environmental Impact Statement (EIS) on the operations of Glen Canyon Dam. At that meeting you announced your decision to proceed with the EIS. At that time we and other parties all indicated willingness to support your decision and do all we could to assure a successful completion to the EIS process. We remain fUlly committed to that proposition. However, some special interest groups now propose that the Department establish interim flow criteria for Glen Canyon Dam pending the completion of the EIS. We recognize the need for "test flows" to enable the researchers to gather the data needed for the EIS, and support such test flows so long as they are coordinated in the research effort and the impacts are held to the minimum that will allow valid data to be obtained\ We must, however, Oppose the adoption of interim flow criteria 0 govern operations pending completion of the EIS. Our objection is based on several factors. First, there is insufficient data to support the need for such flows, and even less data to determine what flows would be most beneficial. One of the major reasons for the Glen Canyon Environmental Studies (GCES) and the more recent EIS is to obtain that very data. The GCES did indicate that some of the resources may benefit from an increase in minimum flows, but there was no data to indicate what those flows should be, nor was there data on what the impact of those flows would be on other resources of concern. Indeed there was very little data on the impacts of fluctuating flows. One of the primary reasons your Department decided to continue the GeES was to gather that data. A consideration to change the operating criteria is warranted only after the data is complete, the alternatives fully evaluated, and the EIS process completed. Second, the adoption of interim criteria effectively destroys the Bureau's ability to study the effects of the present operations and thereby negates its ability to include in the EIS a "no change" alternative. This would be a major flaw in the EIS.