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COMMENTS, COLORADO GAME AND FISH COMMISSION

ALBERT M. DAY,

GAME AND FISH COMMISSION,
Denver, Colo., February 23, 1951.

Director, United States Fish and Wildlife Service,

Washington 25, D. C.

DEAR MR. DAY: Reference is made to a proposed supplement to the report of the Department of the Interior on the potential Colorado River storage project and participating projects, copy of which is enclosed herewith.

Careful scrutiny of the material contained in this supplement discloses that it presents an accurate and comprehensive summation of the responsibilities of the United States Fish and Wildlife Service. The State of Colorado, through the responsible agency, namely the Colorado Game and Fish Department, strongly urges that this supplement be included as a part of the departmental report mentioned above.

We cannot emphasize too strongly the importance of preserving and protecting the wildlife fisheries values of the upper Colorado River Basin.

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United States Bureau of Reclamation,

Washington 25, D. C.

DEAR MR. NELSON: This will acknowledge receipt of your letter dated January 30, 1951 (your reference 737) with which you transmitted two copies of the Department of the Interior's proposed report on the Colorado River storage project and participating projects.

We have examined this report and have no objections to offer to its publication as submitted. It is well prepared and the Bureau of Reclamation is to be complimented upon the vast amount of excellent work it has done in preparing the report for publication.

Very truly yours,

ALFRED MERRITT SMITH,
State Engineer.

NEVADA STATE ENGINEER ON EARLIER DRAFT OF REPORT

OFFICE OF STATE ENGINEER,
Carson City, Nev., October 24, 1950.

Re review of upper Colorado River report.

Mr. E. O. LARSON,

Regional Director, United States Bureau of Reclamation,

Region IV, Salt Lake City 8, Utah.

DEAR MR. LARSON: I have reviewed the Bureau of Reclamation's proposed report entitled "Colorado River Storage Project and Partici

pating Projects, Upper Colorado River Basin," and herewith submit comments on some of the material.

Mr. Michael W. Straus, commissioner, and yourself, who actively supervised the work, deserve the highest praise for this excellent survey and report. In particular we are pleased with the orderly and progressive manner in which it is proposed to construct the various unit dams beginning first with major units designed to protect and preserve existing downstream developments; to be timed over a period. of years to permit a gradual absorption of the electric power; and, further, to not burden too rapidly the already exceedingly heavy national budget.

The recommended upper Colorado River account, which is to be credited with profits from power revenues, appears to be a welldesigned part of your plan. It will assist the irrigation feature in projects that cannot repay all of their capital investment in 50 years. Disbursements from the river account will enable the more desirable power projects (those that are considered best from a financial view) to help the financially weak or marginal irrigation developments to repay capital investment.

However, I am not yet sold on irrigation projects that will be unable to repay construction costs within a reasonable period of years—if ever. I believe there is a necessity for the Nation to provide more agricultural opportunities for our increasing population, but these should be sound opportunities. We know, too, that various indirect benefits, impossible to precisely evaluate, will result from this new marginal agriculture but which cannot be counted on to directly repay capital investment. It would appear to be a sound business. procedure to fix a minimum ratio of capital costs that must be paid rather than to leave this open as suggested on page 10 (d) of the report, which reads:

*** based on the irrigator's ability to pay in a period of 50 years following a suitable development period at least part of the capital costs allocated to irrigation. It will certainly be argued that if any project is unable to pay all costs in 50 or 60 years it is a poor investment, and that the Bureau is only helping to promote such poor business in order to sustain and increase its personnel and prestige; and because it realizes that good. reclamation projects are not numerous.

We do not find in your report estimates of time periods for totally paying-off irrigation features. It may have been too soon to have worked this out, but I am of the opinion that it should be done and that some information should be supplied regarding the liquidation of capital costs of irrigation before Congress is asked to give approval to the comprehensive project. Probably the reclamation feature of some of these units should be reduced or omitted and there also should be a fixed limitation as to what extent the Nation will support marginal reclamation features.

You are not to infer, however, that we do not favor any degree of such support. We do favor it, but believe all projects should be very carefully screened before approval by either the Bureau or Congress. Recommendation of irrigation projects by the Bureau, that cannot repay a reasonable part of capital costs, may cause the Bureau to be criticized as being a promotional agency.

We note that the Glen Canyon project as planned would provide 230,000 kilowatts of capacity in 1959 with ultimately completed installation of 800,000 kilowatts in 1964.

As outlined in your report and maps, it appears that all power to be generated at Glen Canyon will eventually be allocated to the Colorado River storage project, specifically in power market division IV. While no objection might be offered to the allocation of all power revenues from Glen Canyon Dam to the proposed upper Colorado River account, as the project is within the upper basin; the immediate and best market for the power would probably be within the lower basin at the rapidly expanding industrial center of basic magnesium project in Nevada and in densely populated southern California. It is suggested that a large portion of Glen Canyon Dam power should be allocated in perpetuity to this fully developed market, which is now extensively served by higher-cost, steam-generated power using oil as fuel. Conservation of the west coast oil reserves will probably be necessary in the interest of national defense as well as for other purposes.

The last paragraph on page 73 of the report states:

For a number of years energy production by the Glen Canyon unit would exceed by a substantial amount the energy requirements of the States of the upper division. Until required by these States this energy would be available to other States. From time to time, the amounts of energy supplied from within and without the States of the upper division would be adjusted as necessary to meet needs which develop in the States of the upper division.

In accordance with the precedent established with regard to Hoover Dam in the lower division by the Boulder Canyon Project Adjustment Act, whereby $500,000 per year of net power revenue was diverted into a Colorado River development fund for investigation and construction of projects mainly in States of the upper division until the year 1987; it might appear that some portion of power revenues from Glen Canyon project, as well as from other power projects to be constructed on the Colorado in both the upper and lower division States, should be set aside in a special fund for the same purpose.

Very truly yours,

ALFRED MERRITT SMITH, State Engineer.

COMMENTS, NEW MEXICO STATE ENGINEER

OFFICE OF STATE ENGINEER, Santa Fe, N. Mex., June 12, 1951.

Hon. OSCAR L. CHAPMAN,
Secretary of the Interior, Washington, D. C.

DEAR SECRETARY CHAPMAN: This letter contains the views and recommendations of the State of New Mexico with regard to project planning report No. 4-8a.81-1 entitled "Colorado River Storage Project and Participating Projects, Upper Colorado Basin States, December 1950." The report was transmitted by you in accordance with the provisions of section 1 of the Flood Control Act of 1944 (58 Stat. 887) and was received in this office on February 13, 1951. At the request of the Upper Colorado River Commission and some of the States individually, the 90-day period for review was extended by the Secretary of the Interior to June 15, 1951.

The report is an excellently prepared document evidencing a great deal of investigation and study over a period of years. The Department of the Interior and its various branches and employees are to be highly commended, particularly the Bureau of Reclamation which is largely responsible for the preparation of this fine report. During the investigation, the regional director of region 4 of the Bureau has kept the States of the upper Colorado Basin fully informed of the progress of the work and the problems encountered, in full compliance with the spirit and purposes of the Flood Control Act. The Department of the Interior has been particularly helpful to New Mexico by assisting in special studies of those phases of the upper Colorado River plan peculiar to our own State, which problems will be more fully discussed hereinafter. The State is most appreciative of that cooperation.

Subject to specific recommendations hereinafter made, the State of New Mexico approves the plan of development of the water resources of the Upper Colorado River Basin as described in this report and recommends that projects listed in paragraph (b) of the Commissioner's letter of December 22, 1950, be authorized for construction and thereafter operated in accordance with the Federal reclamation laws (act of June 17, 1902, 32 Stat. 388) and acts amendatory thereof or supplementary thereto.

The proposed storage project and the plan of financially assisting participating projects are vital, necessary factors in the development of the water resources of the upper basin. The plan is in accord with the provisions of the upper Colorado River compact and will be invaluable in assisting the upper division States to fulfill the delivery obligations at Lee Ferry called for by the Colorado River compact of 1922. It will also permit them to accomplish in full measure the development provided for through the apportionment made by the original Colorado River compact.

The State of New Mexico is in accord with and recommends the plan for a basin account as set forth in the Commissioner's letter and explained in detail in the report of the regional director. It is the opinion of the State that such an account is consistent with the policies and procedures previously adopted for other projects constructed by the Bureau of Reclamation and carried out within the existing reclamation law. It is consistent with the principle that mutually dependent projects should participate in the benefits of basin development, including, when necessary and with proper safeguards, financial aid from those projects which produce surplus revenues. It is strongly urged that the provisions for assistance to irrigation projects through the basin account method be incorporated as an essential part of the authorization bill.

New Mexico recommends that the hydroelectric plants comprehended within the plan should be operated in conjunction with other Federal powerplants, present and potential, on the Colorado River and tributaries so as to produce the greatest practicable amount of power and energy that can be sold at firm power and energy rates. New Mexico is frankly concerned that such power and energy may be sold to users outside of the upper basin and the States of the upper division in accordance with current demands which in the future may be necessary to provide essential power development to the State. Accomplishment of this objective involves considerations which, at this time, cannot be foreseen. New Mexico requests the privilege of

seeking, at an appropriate time, adequate provisions of law, or procedures for such power operation, as will insure the greatest future benefits for the upper basin and the States of the upper division from the power produced by the Colorado River storage project.

Chapter V of the substantiating materials accompanying the regional director's report deals with power resources available to the power market area, including the potential needs for additional power and energy in the power market area which may be served by the Colorado River storage project. The table on page 70 indicates that for New Mexico (fringe area C) additional power needed by 1970 will amount to 220,000 kilowatts. Preliminary information from the regional office of the Federal Power Commission at Fort Worth, Tex., indicates that the demand for additional dependable power capacity may be even larger than that shown in the regional director's report. New Mexico recommends that the power and energy needs in this State be given careful review and consideration before power contracts are entered into which might leave the State in the position of having to obtain power from other sources at rates which might be considerably larger than those which could be obtained from the storage project. It is realized that as and when the San Juan-Chama transmountain diversion is authorized and constructed there will be a substantial quantity of power and energy available from that source. It is our opinion, however, that the power market needs of the State will far outstrip any power which may be made available by the San Juan-Chama installation and will coincide more nearly with the power which will become available from the storage project.

New Mexico has concurred in the actions taken by the States of the upper basin from time to time through the Upper Colorado River Commission and the Colorado River Basin States Committee looking toward a plan which will insure orderly development so that all of the States will move forward on an even basis insofar as the solution of each State's problems will permit, and it is found practicable so to do. The storage project plan is a flexible one which permits, from time to time, the addition of other storage units and other participating projects, as plans are completed and as the necessary project reports indicate that such projects qualify for authorization within the provisions of the plan.

In recognition of the peculiarity and individuality of each State's problems New Mexico does not oppose any recommendations for changes in the plans within any State from those recommended by the report which may be made by such State or States of the Upper Basin so long as such changes are consistent with the best interests of the basin and with the ultimate plan of development. It has been brought to our attention that the State of Colorado may request the selection of the Curecanti storage unit on the Gunnison River for initial authorization in lieu of the Whitewater unit proposed in the report. It is recognized that such a change may well be in the best interests of the basin and of the State of Colorado and it is, therefore, recommended, should the State of Colorado make such a request for revision, that it have your careful consideration.

At the time the Upper Colorado River Commission and the Colorado River Basin States Committee were considering the preliminary draft of the subject report, a report on the La Plata unit of the Animas-La Plata project had been completed by the Bureau and the

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