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<br />MAR-17-94 THU 1--08 UP <br />, ~. PER COLORADO RIVER COMM <br /> <br />P.02 <br /> <br />- <br /> <br />The common element that is ~ost troubling is the Beach/Habitat-Building <br />Flow Proposal. Interim flow conditions since Aug~sc of 1991 have demonstrated <br />that significantly reduced river fluctuations are causing beaches to be <br />downwasted to at or near the interim criteria maximum flow elevations and that <br />mainstream backwaters and emergent marsh habitat created during the late 80's <br />ara being lost. The apparent purpose of the proposed beach/habitat-building <br />Plow 1s to mitisate the n.sativ. impacts of the flow recommendations in the <br />prefarred alternative. Such flows might be acceptable provided they were <br />limited to pawerplant capacity. Flows areater than powerplant capacIty are <br />contrary to the law and cannot ba supported by the Upper Division States. <br /> <br />The Secretary of the Interior cannot make releases that would bypass the <br />powerplant unless such releases are required to protect Clen Canyon Dam from <br />unanticipatad flood event inflows. The purpose of such restrictions on <br />raleases is well documented in not only the legislative history of the a~tho- <br />ri&ing lasislation (P.L. 84-485) but is also validated in the Colorado River <br />Baain Project Act (P.L. 90-537), the Criteria for Coordinated Long-Range <br />Operation of Colorado River Reservoirs and the Grand Canyon Protection Act. <br /> <br />We appreciate the opportunity to provide comments at this time and hope <br />they will be useful 1n completinl the GCDErS process. <br />