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. U~ A0-.~- i; Sho'''''''''' of Governor Mike Sullivan re: ~ /If/;':' ~- Glen Canyon Dam Dnft Environmental Impact Statement fr ~ March 21, 1994.. Page 3 / (fLV Nowhere in the dEIS is any basis or ~tionale given for not identifying one of the two methods of red~cing flood flow frequency as the preferred method. The State of wyoming believes that there is no option; that Reclamation must select raising of the spillway gates as the means to reduce the flood flow frequencies, rather than reserving more space in the reservoir (and thus impacting the States' apportionments and storage). As drafted in the dEIS, is the public to assume that either option is equally acceptable to the Bureau of Reclamation? - We would point out that on page 42 of the summary dEIS, Reclamation has written that: tIll the height of the spillway gates is raised to reduce flood frequency, the Upper Basin yield determination would be unchanged" (emphasis supplied). It should not be necessary to call to the attention of Reclamation that section 1806 of the GCPA specifies that law is DQt intended to affect in any way the allocations of water secured to the Colorado River States by any compact, law or decree. It is obvious that the sentence cited above discussing the Upper Basin yield clearly implicates Basin states' allocations. Reclamation must recognize and abide by the GCPA's provisions, including that law's relationship with the existing Law of the River. As aptly pointed out by the Upper Colorado River Commission, the inclusion of measures to reduce flood frequencies downstream of Glen Canyon Dam is of the greatest concern if such measures would further restrict the filling of Lake Powell. wyoming believes that the only appropriate and legal way that the Bureau of Reclamation can accomplish the desired flood frequency reduction to help the protection of the environment of the Grand Canyon is to raise the height of the spillway gates. Beach/Habitat Buildina Flows It would appear that the apparent purpose of the proposed beach/habitat-building flow is to mitigate the negative effects of the present interim flows and those that are recommended in the preferred alternative. The inclusion of this common element in each of the restricted fluctuating and steady flow alternatives is most troubling because, as the dEIS admits, on page 37: "Scheduled flows exceeding powerplant capacity (33,200 cfs) may require legislation to implement." This language correctly identifies the existing constraint in the Law of the River that the Secretary of the Interior cannot make releases that would bypass the Glen Canyon Powerplant unless those releases must be made to avoid unanticipated powerplant bypasses (flood flows). This release restriction is well documented in the provisions and the legislative history of the Colorado River Storage Project Act, the Colorado River Basin Project Act, the criteria for the Coordinated Long-Range Operation of Colorado River Reservoirs, and in the GCPA. II j i .' ;1 ...... ,- '< ,/?/ ~ ~ : }'J< 1/, :~ cP " .- \.1 .;:~ ,..,". -f 1,.- t::O' ;"f. ',.-;,>" C-~r f~j .r ,"...,: ii~~ t-;'-'~. '""'J ..,', .,