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Wednesday, April 25, 2007 Tax Reform, Ethics, Water Shortage   Volume 3 Issue 4  
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Analysis of Utah’s Tax Reform
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Make Your Voice Heard on Water Policy
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Make Your Voice Heard on Water Policy
Comment on the Bureau of Reclamation's Draft Environmental Impact Statement
by Janice Houston, CPPA Senior Policy Analyst

Introduction
At a public meeting held April 5, 2007, staff from the Bureau of Reclamation unveiled a draft Environmental Impact Statement (EIS). This EIS is an attempt to address potential water shortages in the states that rely on the Colorado River for water. With the spring snowmelt and runoff at approximately 50% of average in the Colorado River Basin, it appears the region is headed into its eighth year of drought. Water levels at Lakes Powell and Mead, the main storage reservoirs along the river, are at their lowest levels since they were filling, shortly after construction.
 
This continued drought, along with explosive population growth in most of the Basin states has led the Department of Interior and the Bureau of Reclamation to rethink the current operations at the dams as well as how best to mitigate anticipated water shortages in the future. This article is a summary of the presentation made by Reclamation staff at three public meetings this April. The draft EIS is open for public comment until April 30, 2007. This article will outline the four policy alternatives currently under consideration by the Bureau so that readers and policymakers understand how new operational procedures at these sites may impact water use and policy in the West.
 
Background
When the Colorado River Compact was drawn up in 1922, the science of hydrology was in its infancy. Additionally, the years leading up to 1922 were those of high flow levels on the river. Consequentially, rights to the river’s water were over-allocated. 16.5 million acre feet (maf) were claimed by the seven states that comprise the river Compact (California, Arizona, Nevada, New Mexico, Utah, Colorado and Wyoming) whereas the average amount of water in the river during any given year is roughly 15 maf.
 
This over-allocation, the demands of development and population growth, as well as seven years of severe drought along the river has demanded some type of action to address declining water levels. Under the Colorado River Compact, the Upper Basin states (Colorado, New Mexico, Utah and Wyoming) are required to deliver 7.5 maf of water to the Lower Basin each year, regardless of drought conditions. This requirement has led to the rapid decline of water levels in Lake Powell, which impacts not only recreation on the lake but also hydrologic power generation facilities that depend on the reservoir. Since neither the original Compact nor the operational guidelines written by the Bureau address what would happen in the event the Upper Basin is no longer able to deliver the required 7.5 maf, Department of Interior Secretary Gale Norton gave the task to the Bureau and the Basin states to create a workable solution to the problem. The draft EIS details four possible solutions, each created by parties that have a stake in the outcome of this process. All four alternatives have four key elements. They are:
 
  • Develop a shortage strategy for Lake Mead and the Lower Basin states
  • Coordinate operations of Lakes Powell & Mead
  • Create a mechanism for the storage and delivery of system and non-system water conserved in Lake Mead (This water has to be “wet”—water that physically ends up in Lake Mead, not just water conserved on paper)
  • Modify/extend the existing Interim Surplus Guidelines (ISG)
 
What is interesting about the draft EIS is that no preferred alternative is identified by Bureau of Reclamation staff and will not be identified until after the public comment period is closed. This is the reason it is important for all interested parties to respond to the EIS with their comments and preferred alternative.
 
The four possible solutions are as follows:
  1. Basin States Alternative
  2. Conservation Before Shortage Alternative
  3. Water Supply Alternative
  4. Reservoir Storage Alternative
 
Within the EIS, these four options are compared against a “take no action” scenario and the impacts on hydrology, environment and water storage/delivery are detailed. A key consideration when reviewing this document is that the “take no action” scenario isn’t the same as a “status quo” scenario. The analysis done under the “take no action” scenario includes all proposed development projects each of the Basin states is considering. For example, Utah’s proposed pipeline to St. George from Lake Powell has been factored in as if it were already complete. Bureau of Reclamation staff stated they included all proposed projects so they could simulate the lowest level of flow into Lake Powell. This “worst case” scenario helped them to realistically simulate how large the impacts of each alternative would be on the future river system.
 
Alternatives
The Basin States Alternative was drawn up by the official representatives from each of the states party to the Colorado River Compact. The purpose of this alternative is to minimize water shortages to the Lower Basin states of Arizona, California and Nevada while allowing the Upper Basin to continue to develop their Colorado River water. Any water that ends up in Lake Mead through conservation measures (intentionally created surplus or ICS) is returned to the government entity responsible for conservation. For example, Nevada is proposing a series of dams along the river. If Nevada is willing to pay for those dams, the water it conserves with them would be an ICS that Nevada could draw on in the future. The size of the intentionally created surplus would be 2.1 maf.
 
The Conservation Before Shortage Alternative was developed by a consortium of environmental groups. The goal of this consortium was to minimize shortages to the Lower Basin through voluntary conservation measures. Voluntary conservation would be strongly encouraged through the mechanism of compensation paid by the federal government to any governmental or non-governmental group that could prove they put ICS water into Lake Mead. The proposed size of the ICS would be double that of the Basin States’ proposal—4.2 maf. Also, the elevation of Lake Mead would absolutely be preserved at 1,000 ft., thus requiring Lake Powell to send down water (regardless of its own elevation) even if drought conditions worsen. This is in contrast with the Basin States Alternative which would have the elevations of Lakes Powell and Mead fluctuate as needed during times of drought.
 
The Water Supply Alternative was developed by Bureau of Reclamation staff after consultation with interested parties. The goal is to maximize water deliveries at the expense of retaining water in the reservoirs. This alternative is the closest to the idea of allowing the Colorado River to flow freely down its course. This alternative is also the “lowest impact” of the four—meaning that a shortage plan is only implemented when the Upper Basin cannot deliver the expected 7.5 maf. This contrasts to the above two alternatives which each create an operational plan for the lakes in periods of high and average flow as well as during times of drought. In contrast to the other three alternatives, this proposal does not create a mechanism by which surplus water can be stored. Again, the purpose of this plan is to mimic as closely as possible the natural flow of the Colorado River and water storage is not something the river would do on its own.
 
The Reservoir Storage Alternative was developed by the National Park Service and the Western Area Power Administration (WAPA). Its purpose is to maximize water storage at the expense of water deliveries to the Lower Basin. It is the opposite of the alternative above and is meant to ensure that recreation and power generation interests at Lake Powell and Lake Mead have adequate water. Water releases from Lake Powell would be determined by the elevations of both lakes, thus ensuring that hydropower facilities have enough water to operate. This alternative also creates a mechanism for ICS—limiting the storage capacity to 3.1 maf.
 
Each of these alternatives tries to mitigate potential water shortages that might cripple the region while promoting an agenda of conservation and cooperation. The approach and goals of each alternative are different and must be considered carefully before making any decisions. To further examine the alternatives you can access the draft EIS at the following URL or visit the Bureau of Reclamation’s Upper Colorado Regional Office to view a hard copy of the draft. The URL is http://www.usbr.gov/lc/region/programs/strategies.html and the address of the regional office is 125 S. State St. Rm. 7220, SLC UT. The deadline for comments is April 30, 2007.
 
Next Steps
The Bureau of Reclamation will take all comments into consideration when developing its preferred alternatives, which in all likelihood will be some hybrid of the four proposals discussed here. Sometime before the end of June 2007, the Bureau will identify and publish that alternative. In September, the final EIS will be published and a 30 day comment period will commence at the date of publication. By December 2007, the Bureau will publish its “record of decision” and the new plan for managing the Colorado River will go into effect.
 

Conclusion
Although Utah is an Upper Basin state, there is much contained in this EIS that will impact water policy in Utah. First, changes in the water depth at Lake Powell will certainly impact recreational opportunities. Additionally, while the pipeline to St. George was factored into the proposal, any future development of Colorado River water by the state will have to contend with the new operating procedures. Also, if Utah is willing to invest the resources, the conservation portion of these proposals may work in the state’s favor. It would be a way to bank surplus water for use in times of need. Additionally, it may be a way for St. George to inexpensively build their water supply. Finally, it may be the impetus the state needs to expand its current water banking capacity and allow non-governmental entities the opportunity to participate in conservation and water development. Bottom line, though, is that policymakers and citizens of the state have a once in a lifetime opportunity to speak out about the Colorado River’s future. To comment on the draft EIS—please email your thoughts to strategies@lc.usbr.gov.
 

 

[PRINTER FRIENDLY VERSION]

LETTERS
Conservation Before Shortage , Stacey Hamburg
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Published by Center for Public Policy & Administration
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