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Telephone: 307 - 334 - 2170 -- Fax: 307 - 334 - 2407 

041 U.S. Highway 20 -- Post Office Box 900 -- Lusk, Wyoming 82225-0900 

Bureau of Reclamation 

Attn: LTEMP SEIS Manager 

125 South State Street, Suite 800 

Salt Lake City, UT 84138 

Via Email Only - LTEMPSEIS@usbr.gov 

RE: GLEN CANYON DAM LONG-TERM EXPERIMENTAL AND MANAGEMENT PLAN 

(LTEMP) DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT (DSEIS) 

- 89FR 28, February 9, 2024 

Wyoming Municipal Power Agency (WMPA) formed by a Joint Powers Board Agreement 

due to the community's needs for power to supplement their federal hydropower contract 

with the United States Bureau of Reclamation (USBR) (now Western Area Power 

Administration - WAPA). In the early 1970s, Reclamation informed communities with 

federal power allocations that the hydroelectric resources had been fully utilized. Thus, 

communities had to evaluate other options for future power supply. The Wyoming 

communities of Cody, Fort Laramie, Guernsey, Lingle, Lusk, Pine Bluffs, Powell, and 

Wheatland established WMPA to provide all the electricity necessary for the communities. 

WMPA currently provides electricity to approximately 24,000 Wyomingites. 

The Joint Powers Board Agreement states that WMPA is to provide electricity in the most 

economic and feasible manner. Additionally, WMPA's mission is "to provide Wyomingites 

with affordable, reliable electric power while being good stewards of the natural resources 

and land." WMPA's long term federal hydroelectric contracts have been an important 

aspect of meeting its mission and fulfilling its obligation under the Joint Powers Board 

Agreement. 

While WMPA understands that the purpose and need must be defined to meet certain 

NEPA requirements of the LTEMP DSEIS, broader implications and potential unintended 

consequences should also be considered. From WMPA's perspective, the impacts on 

human lives should be considered. Affordable, reliable electricity is vital to human life. 

Wyoming, as a state with abundant natural resources and with citizens whose livelihoods 

depend on their land and environment, is uniquely positioned to understand the 

importance of carefully balancing actions that have vast implications for the environment 

and the people who live there. 
The importance of available, affordable electricity can be illustrated by one Wyomingite 

who sent a message to WMPA asking for help. The substance of the message was that 

this person lives on a fixed income and was unable to pay for both groceries and the 

electricity bill. As it was winter, this person faced the dilemma of choosing between having 

a hungry child or frigid child. This message exemplifies the importance of managing 

WMPA's resources and electric costs. Certainly, there are federal and state programs 

that assist people, but that fact doesn't mean that this person's financial struggle should 

be ignored. WMPA ratepayers pay WMPA's cost based rates. Entities such as 

Reclamation that make decisions that impact WAPA's and WMPA's costs need to keep 

firmly in mind the impacts to the lives of the people that pay for electricity. 

The ratepayer's perspective needs to be considered in the discussions of how to mitigate 

the smallmouth bass threat because the ratepayer ultimately pays for these mitigation 

efforts, whether it be directly or indirectly. Generally, Wyomingites have a strong desire 

to maintain balance in the ecosystem. They know this balance better than most because 

so many Wyomingites work outside directly in their ecosystems. Often, they have a 

connection to the environment that can't be duplicated by studying the environment from 

a climate-controlled building. Most Wyomingites want to protect threatened and 

endangered species because of their connection to the environment and their firsthand 

knowledge of ecosystems. Many Wyomingites benefit from hydropower generation as 

well as enjoy fishing and outdoor recreation. Determining the best solutions and 

managing costs is vital. While many entities are interested in mitigating the smallmouth 

bass threat, the DSEIS does not state how that mitigation will be funded. It should be 

funded by federal non-reimbursable appropriations, not by WAPA or its customers. 

WMPA is concerned about unintended consequences due to the desire to act quickly 

without considering the optimal long-term goals regarding non-native fish. The very 

presence of smallmouth bass in the Colorado River is an unintended consequence of 

stocking smallmouth bass in the river several decades ago. Now, it is easy to see this as 

an error, but unfortunately, people didn't understand the risk in the past. This unintended 

consequence also underscores WMPA's recommendation about funding mitigation, 

because hydropower customers didn't stock smallmouth bass in the river and should not 

bear the obligation to mitigate for their presence. 

WMPA is concerned that the -12 mile slough is not addressed in this draft. The slough is 

a spawning location for non-native fish like the green sunfish and smallmouth bass. This 

slough issue has been discussed for years and solutions have been proposed, but no 

action has been taken to mitigate this problem. WMPA strongly believes that removing 

this smallmouth bass spawning area is very important to the long-term success of 

mitigating threats from non-native fish. 

Additionally, WMPA is concerned that temperature control through changing the flows 

from the dam are the only options considered in the current draft. The DSEIS states that 

"(s)pecific data on these fish have been collected but are not available or citable at this 

time." As temperature control is the main premise and the sole mitigation action 

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considered in the DSEIS, WMPA is concerned that this experimental attempt at 

temperature control will not have the desired effect. Additionally, based on Reclamation's 

recent 24-month study, the temperature triggers may not occur this summer. Given that 

information, WMPA believes that other options such as physical barriers and slough 

modification should be considered and undertaken as soon as possible. The DSEIS 

should be modified to include other than flow-only actions. 

Reliable electricity is essential to human life and livelihoods. From a social justice 

perspective, providing reliable electricity is a moral obligation. Providing reliable 

electricity is WMPA's highest priority. Generally, electricity is generated exactly when 

humans want it because electricity is expensive and relatively difficult to store. 

Dispatchable generation, such as hydroelectric, gas, coal, nuclear, and diesel, produce 

power based on when people want it. Non-dispatchable generation, such as solar and 

wind, produce power based on weather conditions. Dispatchable generation is vital to 

providing reliable electricity. WMPA is deeply concerned about the reduction of 

dispatchable generation from Glen Canyon Dam when the generators are bypassed. As 

dispatchable generation becomes more scarce, WMPA is concerned about the availability 

of replacement power. Also, from an environmental perspective and as noted in the 

DSEIS, it is likely that most of the replacement power will come from sources with more 

carbon emissions than hydropower. 

Additionally, WMPA strongly believes that WAPA should be the federal agency to provide 

the hydropower and grid reliability studies for the DSEIS. While other agencies can create 

models, WAPA, as a grid operator, has decades of practical experience. It's important 

that peer-reviewed, published models, such as those used by WAPA in the original 

L TEMP EIS and other Reclamation NEPA processes be used in the DSEIS for clarity and 

consistency. WMPA also recommends that any untested experiment must include 

specific implementation triggers and offramps that incorporate species as well as financial 

and grid considerations. 

WMPA is a member of the Colorado River Energy Distributors Association (CREDA) and 

supports CREDA's very in depth and thorough comments. 

WMPA appreciates Reclamation holding three public webinars and the opportunity to 

comment. Given a significant amount of incomplete and missing information in the 

DSEIS, WMPA asks that Reclamation provide a redrafted SEIS for public review and 

comment prior to issuing a final EIS. 

Respectfully Submitted, 

Rosemary Henry 

Executive Director 

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