WSP06185

• File Number: 8220.101.09B
• Description: Glen Canyon Dam/Lake Powell
• State: AZ
• Basin: Colorado Mainstem
• Date: 1/1/1994
• Title: Comments re: Operation of Glen Canyon Dam Draft Environmental Impact Statement
• Water Supply Pro - Doc Type: EIS

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in a manner fulIy consistent with and subiect to the Colorado River Compact,
the Upper Colorado River Basin Compact, the Water Treaty of 1944 with
Mexico, the decree of the Supreme Court in Arizona v. California, and the
provisions of the Colorado River Storage Project Act of 1956 and the
Colorado River Basin Project Act of 1968 that govern alIocation.
a'pprQpriation. developmenL and el\Portation of the waters of the Colorado
River Basin. !i 18020>). (emphasis added) -

Section 1806 of the Act further provides that nothing in the Act affects in any way "the
allocations of water secured to the Colorado Basin States by any compact, law, or decree."
This reiterates the point that the Act was not intended to disturb the Law of the River. The
Senate report "emphasizes the importance of this fundamental principle, which applies to
and is meant to control the interpretation and application of every provision of the title:
S. Rep. No. 267, 102d Cong., 2d Sess. 138-39 (1992). Thus, the Grand Canyon Protection
Act must be implemented consistent with CRSP and CRBP A All of these provisions of the
Law of the River must not be impaired by the Final EIS.

Ada.vtive Management. Colorado rccogTIi7es that the Colorado River ecosystem
downstream of Glen Canyon Dam is extremely complicated and many uncertainties exist
regarding the impacts of water releases from Glen Canyon Dam. We therefore support the
concept of Adaptive Management and the establishment of an Adaptive Management Work
Group (AMWG) which includes not only EIS cooperative agencies but representatives of
the Basin States and other interests. The AMWG must consider all scientific, economic,
and Law of the River issues in its evaluations and recommendations for operational changes
and must be willing to adopt less restrictive as well as. more restrictive measures and
operating criteria.

It will be critical for proposed members of the AMWG to participate during the
development of the adaptive management process, scheduled to occur between the draft and
final EIS. Without such participation, the adaptive management process wilI not achieve
its intended purpose.

Flood FrCQ)lenc;y Reduction Measures. The DEIS recommends reduction of the frequency
of unscheduled flood flows greater than 45,000 cfs to no more than 1 year in 100 years as
a long term average. This objective would require the reservation of additional storage
space in Lake Powell for flood control purposes. However, any reservation of flood control
storage space would impair the ability of the Upper Basin to store sufficient water to meet
its delivery requirements to the Lower Basin at Lee Ferry during droughts. Such storage
is protected under H02(a) of CRBPA, and will become increasingly crucial in the future,
as the Upper Basin States increase their compact apportioned use. The Grand Canyon
Protection Act enforces the law that storage in Lake PowelI not be impaired by reason of
any change in operations at Glen Canyon Dam.

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