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I I I I I I I I I I I I I I I I I I I OOIJolb Service would be particularly concerned about any action that would reduce the probable long-term frequency of spills from Glen Canyon Dam because this would directly affect the criteria for implementing "management floods" as part of the Glen Canyon Dam Adaptive Management Program. Specific comments follow: p. 2, para. 2: We agree that a programmatic EA is appropriate in this case. p. 4, para. I: Will a state's entitlement increase in "surplus" years if the intended use of surplus water Is to bank it? p. 6, 2nd bullet: It is our understanding that the 100,000 af limit on recovery of storage credits is not part of this rule, but is a practical limitation based upon Arizona's capacity to recover stored water? In other words, this rule poses no limits on the amount of offstream storage or on the amount of stored water that may be used in any year? p. 12, last para.: This analysis is prepared for a normal year. How would a state's entitlement be affected in "surplus" years, and is offstream storage an acceptable use of a surplus entitlement? p. 24, Sec. E: See general comment, above. If this rule enables increased diversions during "surplus" years, there could be long-tern1 cumulative effects on reservoir levels (Mead and Powell), instream flows and the frequency of spills from Glen Canyon Dam. If this is the case, those effects should be discussed in the EA. The National Park Service greatly appreciates the opportunity to review and comment on the proposed rule. J f you have any questions about our comments, please contact me at (970) 225-3503. Sin~~ Iy, ? i F,.? . / /; _ 'Z ,II v~ fI~~b', 7. vz~ William L. Jack on Chief, Water Operations Branch cc: LAME-Superintendent, Burke, Turner GRCA-Superintendent, Haskell, Winfree GLCA-Superintendent, Henderson, Ritenour IMR-Wylie PWR-Kolipinski 2380-Kimball, Walker, Pettee, Smillie