On December 20th, the Upper Division States acting through the Upper Colorado River Commission provided collective comments to Reclamation regarding the Notice of Intent (NOI) to proceed with the preparation of a Supplemental EIS for the 2007 Interim Guidelines. The UCRC comment letter is HERE. In general, the UCRC commented on the sections of the 2007 Guidelines under consideration in the SEIS, specifically Sections 2.D, 6.C, 6.D, and 7.C. In addition, the UCRC outlined:
- The need for depletion-based accounting and assessments in the Lower Basin;
- The ongoing Upper Division States’ efforts to address the current drought impacts;
- The necessary limitations in the scope of SEIS analysis;
- The process considerations regarding engagement with Mexico and Tribes;
- A commitment of the Upper Division States to work with Lower Division States to prepare a Framework Agreement Alternative by February 1, 2023, for consideration in the SEIS analysis.
Reclamation is attempting to provide a SEIS draft in March for review and consideration.
The Upper Division States also provided Reclamation with their own letters on the NOI: