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, UUUOlll I I I United States Department of the Interior NATIONAL PARK SERVICE W;aler Resources Division 120 I Oak Ridge Drive. Suite 250 Fan Collins. Color4ldo 80525-5596 .., k~/.t' - ." .f IN REPLY REFER TO. I I I I I I March 17, 1998 .-.~'~f\ i ~/-'J.S- -_.../ . , .'.' ,/,/ \-)+-_ l!l2tiDLt71- '-(tieD _ L54(2380) Colorado River AOP (;L-" f--'-'>:L- ;....Jlju.-.!-- . , '-/'. Mr. Dale Ensminger Boulder Canyon Operations Office Bureau of Reclamation P.O. Box 61470 Boulder City, Nevada 89006-\470 .,.... ','. Dear Mr. Ensminger, I I I I The National Park Service (NPS) has reviewed the December, 1997, Draft Programmatic Assessment for Proposed Rule Making for Offstream Storage of Colorado River Water and Interstate Redemption of Storage Credits in the Lower Division States. This rule makes it possible for interstate use of Colorado River water stored offstream in a Lower Basin state. It is our understanding, for example,_ that presently the Arizona Water Banking Authority which was established to store Colorado River water offstream in Arizona, is precluded from the interstate sale and transfer of that water until the Secretary adopts a rule (such as the proposed rule) in support of the interstate component of the Arizona program. The purpose of the proposed rule is to increase the efficiency and flexibility of the management of Colorado River water supplies in the Lower Division states. I I The NPS supports the purpose and need for the proposed rule. Our initial assessment is that the proposed rule will not affect river or reservoir resources under the management jurisdiction of the NPS in "nonnal" or "shortage" years. We have some question as [0 how this rule might work during "surplus" years. Specifically, it is not clear to us if a state's apportionment of Colorado River water in surplus years could be greater than it's "normal" year apportionment if the only application of surplus deliveries would be to dedicate them to offstream storage. For example, could Nevada seek surplus water in a "surplus" year for the sole purpose of increasing its offstream storage credits in Arizona, cven ifthere is not a beneficial consumptive use for surplus water in Nevada? In this case might this rule result in increases in water diversions in the Lower Basin in "surplus" years over what would othelWise have occurred? Any rule which increases the amount of surplus diversions during "surplus" years could have long-term cumulative affects on reservoir levels (Mead and Powell), instream flows and the frequency of spills from Glen Canyon Dam. While these long-tem1 cumulative effects (if possible) may be modest, they should be acknowledged and evaluated in the Programmatic EA. The National Park I I I I