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<br />. <br /> <br />. <br /> <br />Mr. Rick Gold <br />May 3, 1990 <br />Page two <br /> <br />In contrast, monthly and annual release schedules are <br />distinct from power operations and are governed primarily by <br />interstate compact requirements and the Colorado River Basin <br />Project Act of 1968. Should the EIS examine any aspect of <br />annual reservoir operations, then water conservation storage in <br />Lake Powell must be held inviolate. <br /> <br />With respect to the analysis of alternatives, current power <br />operations (i.e.. existing minimum and maximum flows and <br />existing ramp rates) and other human activities which are <br />presently affecting the natural environment of Glen and Grand <br />Canyons should logically be defined as the "no action" <br />alternative. We believe it imperative that a full range of <br />both structural and non-structural alternatives to the "no <br />action" alternative then be examined. subject to the condition <br />that all alternatives must be in compliance with interstate <br />compact requirements and the Colorado River Basin Project Act <br />of 1968. <br /> <br />The non-structural alternatives examined should include not <br />only changes in within-the-month fluctuations in power <br />operations, but also changes in the current institutional and <br />management arrangements for other human activities that may be <br />adversely affecting the downstream environmental and ecological <br />resources of Glen and Grand Canyons (e.g., regulations <br />concerning the trout fishery; permitting practices for <br />recreational boating and for camping on beaches; dispersion of <br />'rafters in the Grand Canyon; vegetation management on beaches; <br />etc.). A full range of structural measures should be <br />examined. This includes a reregulation structure below Glen <br />Canyon Darn, which structure has the potential to minimize <br />impacts on environmental and recreational resources without <br />sacrificing the economics of power generation and repayment <br />revenues to the federal treasury. <br /> <br />As we believe is required by NEPA, evaluation of the "no <br />action," structural, and non-structural alternatives must <br />consider economic and social, as well as environmental. <br />impacts. In view of the multiple benefits which Glen Canyon <br />Dam provides to diverse beneficiaries, the EIS must, therefore, <br />analyze tradeoffs between the various alternatives and weigh <br />and compare their benefits and costs. Since the Secretary's <br />ultimate decisions will be dependent upon an understanding of <br />these tradeoffs. this is a critical aspect of the EIS. <br /> <br />In Closing. we would like to comment on two items <br />concerning the overall scope of the EIS. First, some have <br />suggested that the EIS should examine all aspects of the <br />operation of the Colorado River Storage Project, not just <br />operations at Glen Canyon Dam. The States' Representatives and <br />