555 E. Washington Avenue, Suite 3100, Las Vegas, Nevada 89101-1065 Phone: (702) 486-2670 

Fax: (702) 486-2695 

http://crc.nv.gov 

STATE OF NEVADA 

JOE LOMBARDO, Governor JUSTIN JONES, Commissioner 

PUOY K. PREMSRIRUT, Chairwoman MARILYN KIRKPATRICK, Commissioner 

KARA J. KELLEY, Vice Chairwoman ALLEN J. PULIZ, Commissioner 

ERIC WITKOSKI, Executive Director DAN H. STEWART, Commissioner 

CODY T. WINTERTON, Commissioner 

COLORADO RIVER COMMISSION 

OF NEVADA 

March 25, 2024 

Via e-mail LTEMPSEIS@usbr.gov only 

Bureau of Reclamation 

Attn: LTEMP SEIS Project Manager 

125 South State Street, Suite 800 

Salt Lake City, UT 84138 

Re: Comments on the Draft Supplemental Environmental Impact Statement for the 

December 2016 Record of Decision Entitled Glen Canyon Dam Long-Term 

Experimental and Management Plan 

Dear LTEMP SEIS Project Manager: 

The Colorado River Commission of Nevada (CRCNV) submits the following comments 

regarding the Bureau of Reclamation’s (Reclamation) release of the Draft Supplemental 

Environmental Impact Statement (DSEIS) for the December 2016 Record of Decision 

titled “Glen Canyon Dam Long-Term Experimental and ManagementPlan”(89 Fed. Reg.

9147) (LTEMP) published in the Federal Register on February 9, 2024. 

The CRCNV is required to protect and safeguard the State of Nevada’s allocation of

Colorado River water and power resources granted to it by Congress. CRCNV has a 

significant interest in water matters impacting the Colorado River as well as hydropower 

resources from the Boulder Canyon Project, the Parker-Davis Generation Project, and 

the Salt Lake City Area Integrated Projects. The CRCNV provides hydropowerfrom these 

projects to 23 contractors in southern Nevada including electric utilities, educational 

institutions, Nevada state agencies, and companies that produce goods and services. 

The CRCNV is a member of the Colorado RiverEnergy Distributors Association (CREDA) 

and supports the comments filed by CREDA concerning the DSEIS. The CRCNV is also 

a signatory to the Seven Basin States comment letter on the DSEIS (Seven Basin States 

Letter). The CRCNV offers the following additional comments. 
Colorado River Commission of Nevada March 25, 2024 

Page 2 of 4

Concerns regarding infrastructure integrity of Glen Canyon Dam if any of the 

bypass flow options are implemented. 

During the 38 Sovereigns webinar discussion led by Reclamation on February 28, 2024, 

Reclamation expressed concerns regarding the integrity of the river outlet works at Glen 

Canyon Dam due to potential cavitation and scouring in the river bottom that may occur 

with greater intensity at lower Lake Powell elevations. Reclamation became aware of 

damage following the implementation of High Flow Experiments (HFEs) under LTEMP 

when the river outlet works were used during the experiment. Since then, Reclamation 

has indicated it is continuing to evaluate the extent of these concerns both physically and 

through computer modeling and that, with stakeholder input, will be considering some 

infrastructure modifications that may help mitigate or eliminate these concerns when 

needing to operate the dam at low lake levels. 

The final SEIS must incorporate Reclamation’s ongoinganalysis of flows through the river 

outlet works. It is imperative that the infrastructure be fully operational to manage 

deliveries to the lower basin for extended periods of time under low lake elevations. Any 

of the bypass flow options identified in the DSEIS, let alone existing HFEs under LTEMP 

currently, should not be conducted if protective modifications are not in place, the river 

outlet works are showing signs of ongoing degradation, or if there is otherwise a risk to 

the integrity to the infrastructure. 

The final SEIS should discuss in greater detail the impact of each of the flow 

options on Western Area Power Administration (WAPA) and the hydropower 

community. 

The final SEIS should address the impacts of Reclamation’s proposed actions on the

powerplant equipment at Glen Canyon Dam, the financial impact of the proposed actions 

on the Basin Fund, and the impact of the proposed action on WAPA if it is unable to 

secure replacement power to meet its firm contractual commitments. It should also 

includeimportantofframps that give stakeholders some protection if the proposed actions 

are ineffective, have unintended consequences or become cost prohibitive. 

Thefinal SEIS needs to include offramps for financial protection of the Basin Fund. 

WAPA has long been relied upon to produce hydropower impact analyses in support of 

the Bureau’s proposed actions related to experimental flows. WAPA’s role in this regard

makes sense because WAPA is the entity that markets and transmits hydropower 

resources generated at the dams and actively transacts in the wholesale power markets. 

In the DSEIS, Reclamation has produced its own analysis of hydropower impacts. 

However, the CRCNV is aware that WAPA has produced a competing analysis that is 

significantly more impactful to the hydropower community. The fact that stakeholders 

havetwo sets of competing numbers merely shows that there is a wide rangeof outcomes 

related to the impact of the experiments and, where there is a wide range of unresolved 

outcomes, there is significant financial risk to the Basin Fund. 
Colorado River Commission of Nevada March 25, 2024 

Page 3 of 4

Costs for experimental flows are non-reimbursable costs, meaning that WAPA does not 

include them in power customer rates. The money to pay for experimental flows, which 

in this case is the cost of replacing lost generation, is taken out of the Basin Fund, but 

is not recovered from customers. While the Basin Fund has been used in the past to 

support experiments, those experiments were short-lived and far less costly. In this 

case, the cost of the flow options has the potential to bankrupt the Basin Fund within a 

short period of time, jeopardizing WAPA’s ability to pay for the operation and 

maintenance of the CRSP facilities, support environmental programs such as the 

Upper Colorado River Recovery Implementation Program, support salinity programs, 

and provide irrigation assistance. Before any of the flow options are implemented, 

Reclamation and WAPA must identify a source of funding that is adequate to sustain 

the Basin Fund or include offramps to protect the Basin Fund to avoid its depletion. 

The final SEIS must include offramps if WAPA is unable to secure replacement 

power. 

The CRCNV has commented multiple times that hydropower resources are a critical 

component to operating the power grid, particularly during the hot summer months when 

power is in short supply and the transmission grid is “stressed” by heavy flows. The

hydropower community relies on hydropower resources to serve load. For larger utilities, 

this reliance on hydropower resources and their green attributes, are included in longterm resource plans that are presented to their customers, governing bodies, and, in 

some situations,public utilitycommissions thatreview the reasonableness of those plans. 

Utilities have already had to adjust their resource plans in response to the drought and 

WAPA-199 which relieved WAPA of its obligation to provide a firm amount of power up 

to a contractual amount and forced power customers to accept the risk of replacing that 

supply. Reclamation should have a similar obligation to engage in prudent resource 

planning and, if they intend to remove resources from service, should also be required to 

ensure that an adequate supply of replacement resources is available. 

WAPA has already received early indication from its trading partners that replacement 

power of the amount needed by WAPA to replace lost generation may be unavailable. 

The unavailability of power indicates that there is insufficient generation in the regional 

market to serve demand andsuch a supply anddemand imbalancecould not only disrupt 

market prices but also impact system reliability. The final SEIS must contain offramps 

should WAPA be unable to secure replacement power. 

The final SEIS must include a sufficient plan for implementation. 

Utility planning is complex and requires careful, thoughtful, and frequent communication. 

Detailed implementation and communication plans should also address how frequently 

Reclamation will communicate with WAPA about the likelihood that a trigger will be met 

as well as the quantity of lost generation and the days and hours during which it will be 

lost so that WAPA can replace the power in as prudent a manner as possible. The 

implementation plan should also include sufficient notice to allow WAPA the opportunity 

to analyze the generation pattern and recommend alternative days and hours for the 
Colorado River Commission of Nevada March 25, 2024 

Page 4 of 4

experiment which could aid in minimizing the impact to the Basin Fund. The final SEIS 

should contain timelines for analysis and dialogue that ensure WAPA will have the tools 

it needs to manage the impacts of the experiments in a prudent manner. 

Reservation of Rights 

Failure of the CRCNV to provide specific comments regarding the details of the SEIS 

shall not be construed as an admission with respect to any factual or legal issue or a 

waiver of rights for the purposes of any future legal, administrative, or other proceeding. 

Moreover, the comments herein are specific to this SEIS process and should not be 

interpreted to apply to any other ongoing NEPA processes. Lastly, the CRCNV reserves 

the right to comment further on SEIS documentation as Reclamation proceeds with 

subsequent phases of the SEIS process. 

Conclusion 

The CRCNV appreciates the opportunity to provide comments to the DSEIS to the 2016 

LTEMP ROD. As stated in the 7 Basin States Letter, while the CRCNV is supportive and 

appreciative of Reclamation’s efforts to address the concerns and risks of warm water 

nonnative fish species establishment in Colorado River below Glen Canyon Dam, the 

actions must not be taken at the expense of compromising the integrity of dam 

infrastructure, depleting the Basin Fund for its primary purpose, or putting the electric 

power grid at risk. 

Sincerely, 

Eric Witkoski

Executive Director

Colorado River Commission of Nevada