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<br />\ <br /> <br />. <br /> <br />. <br /> <br />could be included in the rate base to only those in service by the end of the <br />5-year cost eval uat i on peri od. Certai n investment costs of authoriz ed future <br />storage project and participating project features which have historically <br />been included in the rate base would be excluded, which would result in a <br />lower rate increase than is now being proposed. <br /> <br />This argument, however, is without merit as DOE Order R.A. 6120.2 by its <br />terms makes exceptions for both statutory requi rements and for i nterpretati ons <br />by the Secretary. Both P.L. 84-485 and the interpretation of the Secretary <br />of the Interior made contemporaneously with enactment of the statute support <br />the conclusions that the sections of DOE Order R.A. 6120.2 relating to cost <br />evaluation periods do not apply to the CRSP. The purpose of DOE Order R.A. <br />6120.2 is to establish financial reporting policies, procedures, and method- <br />ology for all Department of Energy (DOE) Power Marketing Administrations <br />(PMA's) except where deviations therefrom are specifically approved by the <br />Secretary, authorized by statute, or identified and explained in a transmittal <br />memorandum, or in the footnotes to reports. The proposed rate is clearly <br />within the DOE Order R.A. 6120.2 exceptions. Special legislation by the <br />Congress may be required in order to implement this alternative. <br /> <br />IV. Participating Projects Associated with CRSP <br /> <br />A portion of the proposed Colorado River Storage Project (CRSP) rate adjust- <br />ment anticipates the repayment of authorized participating projects (Glen <br />Canyon, Flaming Gorge, Curecanti unit-Blue Mesa, Curecanti Unit-Morrow <br />Point, Curecanti Unit-Crystal Point, Seedskadee Project, Fontenelle Powerplant. <br />In Western's repayment study, credits to the Upper Colorado River Basin Fund <br />are apportioned among the states in accordance with the directives of Congress. <br />Observance of the allocation percentiles within P.L. 84-485 results in credits <br />to some states in excess of amounts required for authorized participating <br />projects. <br /> <br />Application of the legal principles embodied within P.L. 84-485 results in <br />authorized participating projects in Colorado controlling the level of <br />required revenue in the repayment study. In apportioning sufficient revenues <br />to the State of Colorado to accomplish repayment of these projects within the <br />required time period, revenues must also be apportioned to other states. <br />Credits resulting from this apportionment currently exceed the requirements <br />for repayment of authoriz ed parti ci pati ng projects. <br /> <br />These credits cannot be used to construct or replace the participating <br />projects. Although the money may eventually be used for the repayment of the <br />construction costs of authorized projects within the Upper Colorado River <br />Basin, construction itself requires congressional appropriation and NEPA <br />documentation. The existence of these credits has no environmental signifi- <br />cance, and the impact of the projects they would repay will be adequately <br />addressed when the Congress moves to fund the projects. <br /> <br />V. Environmental Consequences <br /> <br />In considering the environmental impacts of the proposed rate adjustment, <br />Western has analyzed the effects of the proposal and the alternatives on the <br />physical environment, the natural environment and the social and economic <br />environment. The latter category has been considered in terms of the five <br />criteria mentioned in the introduction to this environmental assessment. <br /> <br />4 <br />