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<br />I <br />I <br />I <br />I <br /> <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br /> <br />000645 <br /> <br />Programmatic Environmental Assessment <br /> <br />Page 2 <br /> <br />operations model, Rosekrans' found that lower basin yield only decreased by 1 % while excess <br />flows to Mexico occurred in 35% of all years (compared with 22% under current operations). <br />Even if Mexico diverts some of this extra flow, increased water is a benefit to the environment of <br />the delta. However, there is increased uncertainty in the Lower Basin during drought years. <br />Water banking of SUIplus water could allow for continued use, and even some growth in <br />consumptive use, with a restored Glen Canyon. For these reasons, the Sierra Club does not want <br />to oppose this ruleIJ13king. <br /> <br />Even without the restoration of Glen Canyon, reoperation of the river may be desirable to <br />provide water for environmental uses while meeting future demands in the basin. Offstream water <br />banking (both for intra- and interstate consumers), interstate water marketing between both <br />Lower Basin states and between basins, water wheeling, complete removal of subsidies and water <br />conselVation in irtigation districts should be considered tools to meet needs for the future. <br />Therefore, we oppose the issuance of this rule at this time, find the Environmental Assessment to <br />not go far enough (more explanation below), and join with Defenders of Wildlife and the <br />Southwest Center for Biological Diversity in requesting a full EIS for its entire operation of the <br />Lower Colorado River. The full EIS should include a range of alternatives, including this rule. It <br />should also include mitigation water for environmental uses, including the delta region in Mexico. <br /> <br />Comments on the Draft Environmental Assessment <br /> <br />TIris DEA considers a rule that will allow states to store water offstream in other states. <br />Presumably, any state can be a "consuming state" or a "storing state". However, Reclamation <br />uses this uncertainty to rely on a programmatic environmental assessment. Impacts of specific <br />storage and redemption plans will be considered when proposed. For example, an EA, <br />presumably a FONS!, will be issued annually for the storage of50,000 af of water in ~na. It <br />may be that impacts of an annual storage are slight, but cumulatively they represent a substantial <br />decrease of water in the river. Also, when another state redeems that water, say Nevada, it will in <br />effect transfer water usage upstream (however, see the comment below). There will be less water <br />in the river between Lake Mead and Lake Havasu. Admittedly, this river reach is primarily <br />reseIVoir, but fluctuation of these reseIVoirs are limited due to endangered species. Loss of this <br />water could impact the operations of these reseIVoirs, especially during a sustained drought. But <br />this EA does not assess these changed flows. <br /> <br />Reclamation admits that the most likely scenario is as descnoed above; Nevada stores <br />water in Arizona for future use3. Arizona has j'lven passed legislation to facilitate this storage and <br /> <br />'Rosekrans, S., 1997. The effect of draining Lake Powell on water supply and electricity <br />production. Environmental Defense Fund, September 17, 1997. <br /> <br />3DEA at 2. And Section D, DEA at 4, is an entire example based on this scenario. <br /> <br />Water Resources Research and Consulting <br />