Laserfiche WebLink
<br />I .. <br />I <br /> <br />I <br />I <br />I <br />I <br />I <br />t <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br /> <br />0003~6 <br /> <br />Programmatic Environmental Assessment <br /> <br />Page 3 <br /> <br />water transfer (and presumably the transfer of large sums of money). But Reclamation claims to <br />be sufficiently uncertain of the future to not analyze this likely scenario. This EA should be <br />reworked to include CRSS analysis of flows in the river. Major impacts include changed flows in <br />the lower river and to Mexico. In a region that receives almost no water, changes of a few tens of. <br />thousand acre-feet annually make a large difference to the environment. <br /> <br />Specific Comments <br /> <br />1. One of the aspeCts of the rule relevant to NEPA analysis is "[w]hen a Consuming State entity <br />wants to recover all or part of its storage credits from the Storing State entity, the Colorado River <br />water delivered in satisfaction of storage credits will be accounted for as consumptiVe use of <br />unused apportionmmt allocated in that same year to the Consuming State,...'" This appears to <br />say that the Consuming State can retrieve its stored water, but only when it is not using its <br />apportionment. This means that Nevada can only retrieve water when it has unused <br />apportionment. What would be the advantage to a consuming state if this is a correct reading? If <br />our reading is incorrect, you should clarifY the language. <br /> <br />2. In the discussion of the Arizona Water Banking Authority, the EA states that ''provisions <br />preclude it from entering into agreements with entities in California and Nevada for storage of <br />water on their behaIfuntil the Secretary adopts a rule in support of the interstate COlllJlonent of <br />the Arizona program...". What is the authority for water that Nevada has currently stored in <br />Arizona? <br /> <br />3. "Interstate recovery of storage credits in Arizona for California and Nevada will not be <br />allowed in a shortage year.,,5 This provision allows Nevada growth to far exceed its firm yield <br />from the river. Presumably any other source that Nevada develops in the future would also be in <br />shortage; its capacity for withdrawal from its intrastate recharge facilities do not approach <br />1 ~O,OOO afly, as is the limit that Nevada would be allowed to recover in a normal year". <br />Reclamation should only allow Nevada to enter into a storage agreement if it has reserves <br />for drought years. Otherwise this rule will facilitate Las Vegas' growth beyond even what it <br />massive plumbing system can provide and there would literally be emergency situations in the city. <br /> <br />'DEA at 8, emphasis added. <br />5DEA at 6. <br /> <br />6Jd. <br /> <br />Waler Resources Research and Consulting <br />