WSP06879

• File Number: 8200.400
• Description: Colorado River Basin Briefing Documents-History-Correspondence
• State: CO
• Basin: Colorado Mainstem
• Water Division: 5
• Date: 10/1/1999
• Author: DOI-BOR
• Title: Programmatic Environmental Assessment-Rulemaking-Offstream Storage Colorado River Water - Development-Release Intentionally Created Unused Apportionment-Lower Division States - Appendix H-Section III
• Water Supply Pro - Doc Type: Report/Study

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From:
To:
Date:
Subject:

Steve Glazer <[e-mail]>
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4/3/983:12pm
Comments/43 CFR Part 414 and DEA

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Please accept these comments in this form for the purpose comment due ate.
A hard copy is being sent by mail, postmarked today.

Bureau of Reclamation
4/3/98
Administrative Record
Lower Colorado Regional Office
P.O. Box 61470
Boulder City, NV 89006-1470

Classification
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Attn: AC1006-AA40

Re: Comments on Proposed Rule and Draft Environmental Assessment:
Offstream Storage of Colorado River Water and Interstate Redemption of
Storage Credits, Lower Division States

On behalf of the Sierra Club, its Colorado River Task Force,
CalifornialNevada and Southwest Regional Conservation Committees, we thank
you for this opportunity to comment on the above mentioned rule and DEA. We
also wish to express our appreciation for holding informational hearings on
2/23 and 3/27 which one of our representatives was able to attend. Most
helpful, was the question and answer format used in the 3/27 meeting.

We have reviewed the Proposed Rule and DEA and numerous concerns have surfaced.
A. Comments on the Proposed Rule:
The Rule, although generic, was developed with the objective of
facilitating Nevada's storage of water in Arizona. It does not take into
account some of the specific needs of California, nor does it provide
adequately for possible storage needs of Indian tribes. The Proposed Rule
should either be revised to adequately cover such transfers, or should be
explicitly stated to apply only to Nevada-Ariz~ma transfers.

In the rule definitions, Sec. 414.2, a definition of surplus is omitted. It
is our opinion that proposing this rule is premature because criteria for
surplus, normal, and shortage water conditions are not yet defined. Since
surpluses have already been declared without first having defined the
criteria for such a declaration, further delays in developing criteria will
only lead to difficult situations in the future when normal or shortage
conditions exist. Adding new rules, in the mean time, will only add more