NEPHI CITY 

Phone: 435-623-0822 

21 East 100 North Nephi, UT 84648 Fax: 435-623-5443 

January 29, 2024 

U.S. Bureau of Reclamation 

Attention: LTEMP SEIS Project Manager 

125 South State Street, Suite 800 

Salt Lake City, UT 84138 

Subject: GLEN CANYON DAM LONG-TERM EXPERIMENTAL AND MANAGEMENT 

PLAN (LTEMP) DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT 

STATEMENT (DSEIS) - 89 FR 28, February 9, 2024 

On behalf of the Nephi City we appreciate the opportunity to provide comments on the DSEIS, 

issued February 9, 2024. In addition to our comments, we support and agree with the comments 

presented by Utah Municipal Power Agency (UMP A). Our City is one of the six member utilities 

of UMPA. We also agree with the comments and concerns submitted by the Colorado River 

Energy Distributors Association (CREDA). 

Nephi City operates a not-for-profit municipal electric utility serving over 2,800 residential and 

commercial customers. We aim at providing reliable, affordable, and sustainable electtical service 

to our citizens. Our electric utility is a critical driver in promoting the economic welfare of the 

community. 

By contract with Western Area Power Administration (W AP A), we receive over 20% ofour power 

resources from these federal facilities. Any cost increases or power reductions have a significant 

impact on our cmmnunity. This clean and renewable hydroelectric energy suppotis our effotis to 

meet our carbon-free and renewable goals in the community. Over the past years, we have been 

impacted by drought conditions in the upper Colorado basin leading to lower energy production 

and higher costs. 

The DSEIS acknowledges that power generated through Glen Canyon Dam would need to be 

replaced and lays that responsibility onto W AP A for solutions. However, it does not address and 

considers the scarcity in energy generation faced by utilities. We express serious concerns 

regarding the draft SEIS's failure to sufficiently analyze the impact that the flow options will have 

on hydropower production and the 1isk that reduced hydropower production may have on the 

ability for utilities to provide power to the Utah region during the smmner. Currently the energy 

market is being strained and a further reduction of hydroelect1ic generation will add to constraint 

energy market with scarcity and higher prices. The DSEIS fails to refl ect impacts in our market 

area and only examines the Palo Verde trading hub. 

We acknowledge the importance of protected species and recognizes the risks associated with 

smallmouth bass (SMB) proliferation in the river reaches below Lees Ferry. Many years of good 

science and multi-millions of dollars have been invested in protecting endangered fish species and 

improving the habitant ofthe river. Although Reclamation has well intention in drafting the SEIS, 

it has been rushed and lacks a thorough and comprehensive examination ofother alternatives other 
than use of the bypass tubes. Maintaining a higher elevation in Lake Powell should have been 

examined. 

We recognize the challenge for Reclamation in balancing the priorities and complex issues related 

to operating the dam. We do support these efforts to address the interests of protecting the 

hydropower resource in balance with other social, cultural, tribal, and environmental purposes. We 

strongly urge further studies to avoid reduction of hydropower generation and the impact to 

reliability and affordability in the region. In summary, we urge you to adopt the "None-Bypass 

Option" to avoid these significant risks to power supply. 

Sincerely, 

V 

Cc: Layne Burningham, UMP A 

Kevin Garlick, UMPA 

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