Wyoming Rural Electric

Association 

Nebraska Rural Electric

Association 

Utah Rural Electric

Cooperative Association

Colorado Rural Electric

Cooperative Association

2312 Carey Avenue 

Cheyenne, WY 82001

P.O. Box #82048 

Lincoln, NE 68501

10714 South Jordan Gateway

Suite 300

South Jordan, UT 84095

5400 Washington Street

Denver, CO 80216 

Grand Canyon State Electric

Cooperative Association

New Mexico Rural Electric

Cooperative Association 

2210 S. Priest Drive 

Tempe, AZ 85282

614 Don Gaspar Avenue 

Santa Fe, NM 87505

March 25, 2024

U.S. Bureau of Reclamation

Attn: LTEMP SEIS Project Manager

125 South State Street, Suite 800

Salt Lake City, UT 84138

Via Email only – LTEMPSEIS@usbr.gov 

RE: Draft Supplemental Environmental Impact Statement (DSEIS) for Glen Canyon Dam Long-Term

Experimental and Management Plan (LTEMP) (89 Fed. Reg. 9,148 (February 9, 2024)) (EIS No.

20240024) 

Statewide associations of electric cooperatives from the states of Wyoming, Nebraska, Utah,

Colorado, Arizona, and New Mexico appreciate the opportunity to provide comments on the DSEIS

which was issued on February 9, 2024. 

60 Years of Power Generation

 

This year marks the 60th anniversary of power generation at the Glen Canyon Dam (GCD).1

Both the vision and sacriÐices made by previous and current generations make it possible to now

provide over Ðive million retail customers from across seven western states2 with access to

affordable, reliable, and clean power. Large parts of the Colorado River Storage Project (CRSP)

customer area include rural, remote, and even underserved or disadvantaged communities. 

GCD is a clear example of human ingenuity and adaptability. It harnesses a natural energy

source and converts it into an always available power resource which is vital for the health, safety,

and welfare of all CRSP retail customers. Any proposed experimental actions resulting in reduced

power generation at GCD must scrutinize the probability of any perceived desirable results from

those experimental actions by weighing the full impacts on the human environment. The longevity

of GCD and its hydropower operations must always be a priority. The solvency of CRSP depends

upon GCD hydropower operations. Most importantly, lives in the West depend on GCD to keep the

lights on for generations to come.

1 https://www.usbr.gov/newsroom/news-release/4747 2 Power Generated at GCD is provided primarily to seven states which are part of the Colorado River Storage Project

(CRSP) customer area. However, GCD is part of the Western Power Grid and may provide power to the Western Area

Power Administration’s (WAPA) 15-state region as was done in in 2000, 2001, 2020, and 2022 when emergency power

was provided to California. 
March 25, 2024

Page 2 of 3

DSEIS Proposed Action

The Bureau of Reclamation (Reclamation) has concluded that the potential threat which

smallmouth bass pose on threatened and endangered species below GCD is an unacceptable risk

which necessitates immediate actions to prevent smallmouth bass from becoming established

downstream from GCD. The DSEIS contemplates six alternatives to address the smallmouth bass

risk. Four of the six proposals include changes in operations at GCD regarding Ðlow option

alternatives aimed at reducing the river temperature below 15.5 degrees Celsius. This would

theoretically disrupt smallmouth bass spawning. 

SpeciÐically, the Ðlow option alternatives contemplate bypassing water through the river

outlets and reducing releases through the penstocks which is where power generation occurs. Thus,

each bypass Ðlow option would reduce power generation at GCD. The DSEIS attempts to address the

economic impacts to hydropower if Ðlow options are implemented. However, this analysis fails to

provide accurate and complete economic impacts caused by the power generation reductions. 

Such gross inadequacies prevent a decision maker and the public from being able to make a

fully informed decision regarding the proposed actions. Reclamation should work closely with

WAPA to amend the energy and power section (Section 3.3) of the DSEIS, so that complete and

accurate information can be weighed prior to issuing a Ðinal SEIS. 

Impacts to Hydropower and CRSP

The National Environmental Policy Act (NEPA) requires federal agencies to take a hard look

when preparing environmental impact statements. This “hard look” standard means federal

agencies must thoroughly assess the cumulative effects of their proposed actions on the human

environment.3 This also includes consideration of economic factors.4 Then the information must be

disclosed to the public before making decisions. 

The methodology implemented in the DSEIS misapplies the use of averages by including

when experimental Ðlow options would not be triggered. This Ðlawed methodology drastically

minimizes the actual impacts which the experimental Ðlow options would have on hydropower. 

Moreover, the DSEIS should include a complete analysis of the proposed actions’ impact on

hydropower and CRSP. This would include, at a minimum, consideration of components included in

the LTEMP FEIS in 2016. Such components included impacts to the Basin Fund and CRSP

operations, changes to marketable capacity, availability of replacement power, effects on regional

energy prices, effects on WAPA wholesale prices, and effects on retail rates for the millions of CRSP

retail customers. 

Reclamation must work with WAPA to ensure that all foreseeable impacts on hydropower

are included within any Ðinal SEIS. This will allow for decision makers to weigh complete and

accurate information. It will also allow for full consideration of the impacts on CRSP and the

millions of CRSP retail customers who will bear the costs associated with the proposed actions

within the DSEIS. 

3 C.F.R. § 651.16 (2024). 4 C.F.R. § 1502.16 (2024).
March 25, 2024

Page 3 of 3

We appreciate the opportunity to provide comments on this critical issue on behalf of the

electric cooperative member-owners who are also CRSP retail customers.

Respectfully,

Shawn Taylor Rick Nelson 

Executive Director General Manager 

Wyoming Rural Electric Association Nebraska Rural Electric Association 

Nathaniel Johnson Kent Singer 

Executive Director Executive Director 

Utah Rural Electric Cooperative Association Colorado Rural Electric Association 

Dave Lock Charise Swanson

Chief Executive Officer Chief Executive Officer 

Grand Canyon State Electric Cooperative

Association

New Mexico Rural Electric Cooperative 

Association