alea-institute/kl3m-data-sample-004-shuffled huggingface dataset:
DIRECTORS 

W. BRUCE HEIDEN, PRESIDENT

K.C. GINGG 

BRANDON LEISTER 

JASON ROVEY 

JOHN K. VANDERWEY

SUPERINTENDENT 

DONOVAN L. NEESE 

103 WEST BASELINE ROAD 

BUCKEYE, ARIZONA 85326 

TELEPHONE (623) 386-2046 

FAX (623) 386-4360

P:\OPERATIONS\Power\Correspondence\2024-03-22 BoR Draft LTEMP SEIS.doc Page 1 of 2 

March 22, 2024 

Bureau of Reclamation 

Attn: LTEMP SEIS Project Manager 

125 S State, Suite 800 

Salt Lake City, UT 84138 

LTEMPSEIS@usbr.gov

Re: Comments to the Glen Canyon Dam Long-Term Experimental and Management Plan 

(LTEMP) Draft Supplemental Environmental Impact Statement (DSEIS) 

The Roosevelt Irrigation District (RID) appreciates the opportunity to provide comments on the 

important issues in the DSEIS. The RID provides electric service to customers in Maricopa 

County, Arizona west of Phoenix. RID is a long-time Firm Electric Service contractor with 

Western Area Power Administration (WAPA) for capacity and energy provided by the Colorado 

River Storage Project (CRSP). RID endorses the breadth of comments submitted by CREDA, IEDA 

and SRP. 

The limited view of the impacts of the alternatives are disappointing. The DSEIS must be revised 

to consider accurate evaluations of a wider range of solutions to prevent the establishment of 

smallmouth bass and other nonnative warm water invasive fish. The DSEIS omits reasonable 

alternatives that could disrupt the establishment of smallmouth bass below GCD without flow 

modifications that diminish GCD electric generation. More critically the DSEIS fails to 

adequately assess the environmental and public safety effects that the alternatives will impose 

on the ultimate electric customers that are served from this resource. 

The DSEIS does not consider non-flow alternatives to disrupt smallmouth bass populations, 

rather it leaves this analysis for future NEPA actions. Such non-flow options have already been 

identified by IEDA, SRP and the GCD Adaptive Management Work Group. This narrow focus of 

alternatives indicates a bias for a particular outcome. 

The DSEIS analysis does not properly evaluate the impacts to electric generation. The costs of 

the replacement power and transmission are grossly underestimated and the proposed flow 

modifications will directly impact reliability. Loss of delivery to our communities due to 
P:\OPERATIONS\Power\Correspondence\2024-03-22 BoR Draft LTEMP SEIS.doc Page 2 of 2 

reliability issues will threaten public safety. The costs of the flow-based alternatives need more 

rigorous analysis. 

Reclamation must critically analyze available alternatives to disrupt smallmouth bass 

populations below GCD include nonflow options. The inclusion of one non-bypass flow 

alternative is insufficient to fully address the requirements of an EIS. More critically the DSEIS 

fails to mitigate the effects on regional grid reliability caused by the loss of GCD generation or 

the costs of replacement power and transmission. Please revise the DSEIS such that it meets all 

applicable requirements. 

Sincerely, 

Donovan L. Neese 

Superintendent