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Bureau of ReclamationAttn: LTEMP SEIS Project Manager

125 South State Street, Suite 800

Salt Lake City, UT 84138

LTEMPSEIS@usbr.govRE: GLEN CANYON DAM LONG-TERM EXPERIMENTAL AND MANAGEMENT

PLAN (“LTEMP”) DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT

STATEMENT (“DSEIS”) —89 FR 9147, February 9,2024The Navajo Tribal Utility Authority (“NTUA”) appreciates the opportunity to provide

comments on the U.S. Bureau ofReclamation’s (“Reclamation”) LTEMP DSEIS, issued Februaiy9, 2024, and noticed at 89 Fed. Reg. 9147-9148.

NTUA is a wholly owned enterprise of the Navajo Nation, a federally recognized Native

American Tribe. NTUA is organized under the laws of the Navajo Nation and was established

on January 22, 1959, to address the absence of utilities on the Navajo Nation, and NTUA hasgrown into the largest tribally owned and operated multi-service utility provider delivering a

portfolio of services. NTUA provides for the operation, maintenance, and expansion of electric,

communications, natural gas, water, wastewater, and generation services for the Navajo peopleat a low and reasonable cost. NTUA strives to serve a population of approximately 165,000

spread across the Navajo Nation, an area of about 27,000 square miles that encompasses a large

part of the state of Arizona and portions of Utah and New Mexico. Within the Navajo Nation,

35% live below the poverty line, compared to 12.6% for the United States. NTUA’s service

territory is remote, and NTUA serves 43,000 electric customers from its own transmission and

distribution systems.

NTUA’s headquarters are located in Fort Defiance, Arizona. Because of the vast size of

NTUA’s service territory, NTUA also maintains district offices throughout the Navajo

Reservation, including (in Arizona) at Kayenta, Tuba City, Chinle, Red Mesa, and Dilkon, and

(in New Mexico) at Shiprock and Crownpoint. To meet the energy needs of its customers, NTUA

relies on both its own generation resources and transmission service from various

Hce’,e Office: KAYENTA TUBA CITY SHIPROCK CHINLE FORT DEFIANCE DILCON CROWNP0INT

P.O. BOX 170 P0. BOX 37 P0. BOX 398 P.O. BOX 1749 P0. BOX 549 P0. BOX 587 HC 63 BOX D P0. BOX 1825

FT DEFIANCE, AZ 86504 KAYENTA, AZ 86033 TUBA CITY, AZ 86046 SHIPROCK, NM 87420 CHINLE, AZ 86503 FT DEFIANCE, AZ 86504 WINSLOW, AZ 86047 CROWNPOINT, NM 87

CALL 800-528-5011 OR 928-729-5721 FOR ALL OFFICES.

*This institution is an equal opportunity provider and employer.
Reduced and/or bypassed generation at Glen Canyon Dam (“GCD”)/CRSP, as discussed

in the DSEIS, has implications and potential impacts to NTUA, including the affordable deliveryof electricity to the Navajo people and to counterparties. From a tribal perspective, hydropoweris necessary for our Navajo people to be able to pay their electric bills. Basic necessities such as

electricity, water, internet are still not adequately met on the Navajo Nation, which isunacceptable. With the risk of interruption or congestion affecting hydropower resources, suchimpacts will exacerbate an already serious problem.

NTUA is concerned with specific transmission congestion impacts that are appearing in

the models. Data generated by the National Renewable Energy Laboratory (“NREL”) found

congestion effects due to reduced GCD generation, including potential congestion impacts that

may affect NTUA. For example, the NREL data found congestion impacts from Kayenta to

Longhouse as an effect of reduced GCD generation. Analysis by Argonne National Laboratory

(“Argonne”) found that the reduction in generation at GCD significantly affects the transmittal ofenergy to Four Corners and Northern loads.

Moreover, the models relied upon in the DSEIS do not include WAPA’s work and should

include WAPA’s analysis. WAPA’s work includes the March 11, 2024 WAPA Desert Southwest

Region, “Impact of Reduced Glen Canyon Generation on Transmission Reliability 2024.”

(“WAPA Report”). The WAPA Report would help in understanding the broader picture as to

transmission reliability and ability to weather impacts of reduced GCD output. Section 3.3 of the

DSEIS should be revised to include analysis undertaken by WAPA, as well as the informationfrom NREL and Argonne noted above.

NTUA receives an allocation of Colorado River Storage Project (“CRSP”) hydropower,

which is a cheaper source of power than alternatives. NTUA has partnered with 12 tribes who

are entitled to an allocation ofCRSP hydropower. As discussed further below, NTUA has entered

into benefit arrangements whereby NTUA receives the other tribes’ allocation of hydropowerand, in return, NTUA sends the tribes a payment. These payments go into tribal funds and help

support programs for the community.

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affordable for its Navajo customers, who cannot afford more expensive electric bills. If

hydropower is not available for NTUA’s use, NTUA must purchase replacement power, whichmay be from natural gas powerplants and more expensive. At peak hours, replacement power istwo-to-four times more expensive than hydropower.
reimbursable costs drawn from the Basin Fund and returned to the Treasury.” While

acknowledging impacts if the Basin Fund balance falls below $70 million, the DSEIS does notanalyze in Section 3.3 the likelihood and degree of a shortfall under the $70 million level (andlikelihood of triggering a cost-recovery charge, as noted in DSEIS at 3-27), or other quantitativeanalysis of the impacts to the Basin Fund. The DSEIS should reflect such analysis.

Lastly, the DSEIS at 3-220 acknowledges that some tribes “operate their own electric

utilities and receive power directly from WAPA. Power received directly from WAPA tends to be

lower cost than other resources. A reduction in WAPA power allocation, therefore, translates into

higher costs for Tribal utilities.” The DSEIS continues by discussing benefit crediting

arrangements and their importance to tribes. However, the DSEIS does not analyze whetherreductions in GCD output will adversely impact these benefit crediting arrangements nor attempt

to quantify any such impact. The DSEIS should undertake this analysis.

NTUA appreciates Reclamation’s consideration ofthese comments and urges Reclamation

to update and reissue a public draft SEIS as recommended herein.

Sincerely,

NAVAJO TRIBAL UTILITY AUTHORITY

Walter W. Haase, P.E.General Manager