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<br />MAYNES,BRAOFORO&SHPS <br /> <br />10:303-247-8827 <br /> <br />APR 07'94 <br /> <br />14:35 No.016 P.21 <br />-.... ,"., ... <br /> <br />4 <br /> <br />b.llev. it would be prudent to determ1ne the1r r.spons. before making <br />~ajor changes to present flow condit10ns. <br /> <br />. Th. assu'Ptlon that flows .1mtck1ng pre-dam flows would be beneffctal <br />to endangered f1sh 1s not presently sctent1ffcally supported. This <br />assumption fafls to recogntze permanent post-da. condtt10ns related <br />to the presence of the dam, prlmartly clear, coldwat.r rel.ases and <br />greatly reduced sedt..nt loads. Flows that were favorable under pr.- <br />da. condlttons are not necessarily des1rable now. Research should be <br />undertak.n to vertfy or dtsprove this assumptton be for. It 1s used to <br />Justffy operational changes. <br /> <br />6. The adapttve management process ts an excellent resource management tool In <br />concept. Western Is committed to this process, and strongly supports <br />Reclamation In making adaptive management the heart of the alternattves. <br />We have to be concerned that the r.cent ftrst test of the prlnctple, based <br />on sc1ence and wtth the unantmous support of the cooperating agencies. did <br />not result fn ;~lementatlon of the proposed operational changes. <br /> <br />. In the first test of the adaptive management process, Reclamatton <br />dented the proposal, sayfng that ft was too near the end of the HEPA <br />process to make a change. However, major operatfonal changes were <br />..de fro. normal operatfons to tntertm flows, at a ttme when llttl. <br />scfentfftc knowledge was avatlabl., and Impacts unknown. Vestern <br />strongly belteves that sctence must be us.d to determtne operational <br />parameters, both now and for the long ten.. <br /> <br />. Adaptive management ts the core of all but on. of the alternat1ves. <br />the foundation upon wh1ch they are butlt. If adapttve management <br />prov.s to be ineff.cttve tn practtce. then the alternatives 1n the <br />draft EIS cannot be vtable, and the alternat1ve I~act assess..nts <br />are tncorrect. Adaptive management Is the linChpin of thts EIS; tf <br />tt is not viable, then none of the alternatives wtll work. <br /> <br />7. The primary iMPacts to power generation have been addressed 1n the draft <br />EIS. The indlr.ct effects have not been adequat.ly d1scussed, or factored <br />into the impact analysfs as unavofdable tmpacts of the alternattyes. <br /> <br />. Chang.s to operattons of Glen Canyon Dam and Powerplant would result <br />In long-term effects on power production. For all but the Maxlmu. <br />Powerplant Capacity Alternative, these would Include lower amounts of <br />marketable capacity, lower amounts of on-peak energy, and greater <br />amounts of off-peak energy. Power customers will be requIred to <br />replace this hydropower resource w1th more expensive thermal <br />generation. <br /> <br />. Greater reliance on fosstl fuels will cause Increased environmental <br />Impacts due to increased eMiss10ns and air pollution, the effects of <br />mining, and the .ffects of transporting fuels over long distances. <br />Th. continued financial vitality of the Basin Fund and its ability to <br />...t r.payment obltgations as the value of the Colorado River Storage <br />Proj.ct hydropowlr is chang.d May be s.rlously Impacted. <br /> <br />. The us. of Ixlsttng surpluses to replace lost Glen Canyon hydro <br />resourc.s cannot b. consid.red to b. without implct. The true impact <br />