OPINION: Comments on the Draft Upper Basin Drought Response Operations Plan

To: Robert Henrie and Valerie Deppe, U.S. Bureau of Reclamation

Re: Comments on the Draft Upper Basin Drought Response Operations Plan

Mr. Henrie and Ms. Deppe,

Save the Colorado greatly appreciates the opportunity to comment on your Draft Upper Basin Drought Response Operations Plan, dated January 3, 2022, shared with the NGO community on January 11, 2022, (and posted here: SaveTheColorado).

First, in the Plan and the appendices, nowhere does the Bureau mention the cause of the “drought”. The cause of the drought is “climate change”. Further, the best available science and scientists indicate that this is not actually a “drought”, but is “aridification” caused by climate change. “Drought” is a temporary phenomenon, whereas “aridification” caused by climate change is permanent. By misnaming the problem, your Plan avoids or completely disregards the solution. You can’t fix that which you do not name.

Second, your Plan clearly and purposely attempts to uphold every tenet of the status quo in Upper Basin Colorado River Management. The status quo is all of the RODs, all of the previous management plans, all of the Biological Opinions, and most of all, all of the diversions by the Upper Basin and Lower Basin states. Your Plan simply cannot work if it requires that the status quo be maintained because the status quo is what has caused the problem. Something consequential and systemic has to change; an ox has to be gored.

Third, the phrase “Target Elevation” at Lake Powell is written 35 times in the draft Plan, and the entire Plan is organized around “protecting” the Target Elevation. Thus, this entire Plan is a “Save Lake Powell and Glen Canyon Dam Plan”; it is not a “Drought Response Operations Plan”. The Plan itself is misnamed, and again, by misnaming the Plan, it fails at finding a solution.

Fourth, your Plan never once mentions buying massive amounts of water from farmers in the Upper Basin, which is the only way that the Target Elevation can be protected and Lake Powell and Glen Canyon Dam be saved. Absent consequential and systemic change – which must include buying hundreds of thousands of acre feet of water (or a few million) from farmers in the Upper Basin – we believe this Plan will fail, and may fail in the very short-term if hydrology resembling 2021 continues.

Finally, we do not support buying hundreds of thousands of acre feet of water from farmers to try and save Lake Powell and Glen Canyon Dam. The ox that drives the entire wagon train is Lake Powell and Glen Canyon Dam, and the ox that must be gored is Lake Powell and Glen Canyon Dam. We request that a new “Plan” be developed that includes another alternative – abandoning the status quo and abandoning Lake Powell and Glen Canyon Dam.

We are happy to discuss our comments at any time. Thank you for your work.