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Part Two: Preparing Comments for Public Participation During the Reconsultation of Interim Guidelines

July 24, 2021
by John S. Weisheit

Hydropower cessation at Glen Canyon Dam is possible in Year 2022
Hydropower cessation at Glen Canyon Dam is possible in Year 2022

This Section is Part Two

  • Click here for Part One A: By date - News and Opinion
  • Click here for Part One B: By subject - News and Opinion
  • Click here for Part Two: Narratives - Old and New.
  • Click here for Part Three: The Physical and Social Sciences
  • Click here for Part Four: Solutions - Climate Adaptation, Sustainibility and Resilence.


PART TWO: Narratives Old and New

  • Daniel B. Luten, Jr: "I suggest to you that moving water is more to be admired than used, that the primary purpose of water is to beautify the earth."  Luten on Energy & Water (with kind permission from Guilford Press).
  • Wallace Stegner: "We need a Congress that will say no to any more water boondoggles in the West. We need a moratorium on boosters and developers and raiders who can’t or won’t see the consequences of their acts. We need to scale down our expectations and advise a lot of hopeful immigrants that what they seek is not here." LA Times Op Ed.
  • Luna Leopold: Water and the Conservation Movement & A Reverence for Rivers & Bibliography. "...we seem not to have learned how the political and economic aspects of our lives are related to geography and climate, nor have we been able to bend social custom to accept the constraints placed on us by geography and climate. One of the obvious constraints is the finite nature of nonrenewable resources. Even those resources that are not physically destroyed by use, as oil and coal are destroyed by burning, are usually so geographically dispersed by use that they can never again be collected together in usable concentrations."
  • Donald Worster: Epilogue (a vision statement). Rivers of Empire. Oxford Press; 1985. "A river, to be sure, is a means to economic production, but before that it is an entity unto itself, with its own processes, dynamics, and values. In a sense it is a sacred being, something we have not created, and therefore worthy of our respect and understanding. To use a river without violating its intrinsic qualities will require much of us. It will require our learning to think like a river, our trying to become a river-adaptive people."
  • Universities Council On Water Resources: Water Promises: Much Ado About Nothing, 2009. "...the manager’s challenge is to balance supply and demand in an ever-changing natural and social environment, with a constantly-moving target. In this respect, the expertise of hydrologists, fluvial geomorphologists and geo-hydrologists, is fundamental to any scientific modeling of the water world."


On The Colorado Narrative: It could be said that movements to create sustainable and resilient communities—which include functional ecosystems—are considered unAmerican, if not illegal, in the sense that legislators have yet to acknowledge that the planet's natural resources have transitioned from abundance, to scarcity and uncertainty. Moreover, that this transition period will carry a sizeable investment package and that cooperation with other states and sovereigns will be difficult (Griggs, 2014). That moving through this transition period, to unravel very complex issues, will require many decades of persistent hard work. This is why this country will need to develop an ethical national water policy, which was attempted in the mid-1960s and early 1970s, and with very limited success.

The purpose of 2007 Interim Guidelines was to generate a process in which shortage declarations could be avoided for the seven states of the Colorado River Basin (CRB) and Mexico, and simultaneously continue to be generous about providing more water uses for more people, and without changing the Law of the River. In other words, the proposed solution was a circle back.

Therefore, it is reasonable to conclude that to have sustainibility in the CRB, the growth paradigm is no longer feasible and the Law of the River must be changed.

In 2014 it was recognized that program accomplishments were insufficient and 5-years later the seven states and Mexico finally entered into emergency drought contingency planning contracts and treaty minutes, which also has not yet accomplished positive results, because mandatory shortages begin in January 1, 2022 for Arizona, Nevada and Mexico, and the amount of that shortage is 613,000 acre-feet (the monthly average of water passing through the turbines at Glen Canyon Dam is 685,833 acre-feet). Further cutbacks and hydropower cessation could happen in Water Year 2022 (October to September), should the basin's hydrology continue to be impacted by heat traps, dry soils, increased consumption by thristy plants and people, and all due to disrupted circulation patterns of ocean and atmosphere.

What this means is that the approaches of the last 14-years, which truly range from kick-the-can to gradualism, are not the energetic strategies required to inspire the public's trust toward management in the Colorado River Basin; the very river management paradigm that the rest of the world has decided to emulate.

The essence of the problem is the Colorado River Compact of 1922 and the language of compromise that it contains; it is an unfinished document; it was the best effort under the circumstances of it's time; it is a document destined for circle back discussions.

Though this formative document has never been changed, a compilation of surrogate laws, agreements and policies were created and called, at first, "The Hoover Dam Documents," and now more commonly called, "The Law of the River." This layered stack of legal papers has not solved the water security problems of our times, and neither do the public laws and codes of the state and federal governments. In other words, we just aren't prepared for the pace of change that is quickening with every passing decade.

The single-most controversial topic of 1922 was the water budget of the entire Colorado River Basin. The deficits that were intentionally embedded into this document still remain the dominate issue today, after four generations of passing time. The second issue was how will the real-time water budget, which is variable by decade and century, be equitably allocated amongst the seven states, Mexico, the tribes, and wildlife. See: OTC Discussion about Northcutt Ely, co-author of the Hoover Dam Documents.

Why is this so difficult? Everybody knows how to balance a checkbook and create a household budget, and everybody understands the consequences when acccidental and deliberate blunders occur. What this history suggests is that the principle of precautionary planning was not addressed at the front ends of these negotiations, and that the back end negotiations are merely ineffectual stop gap measures that waste money and time.

"Creative" water marketing contracts and various engineering solutions to augment the supply have been proposed, but it is vitally important to understand that the completion of these solutions will take many decades to implement, and then, it is highly likely that the water budget will be exceeded yet again, and yet another circle back.

This is why sustainibility and resilency goals are just words, rather than vigorous action items. If substanative reform does not happen in the next five years, then the basin's only assurrance is this: it works, until it doesn't. This is also known as reckless abandon and if it does unravel, it is entirely deserved.

The Eventualities and Imperatives
  • The first step is to accept that the system has been broken for many decades and water managers have failed to balance the water budget in the upper basin and the lower basin; the pace of this growing deficit is quickening.
               In the 20th century, this imbalance grew negative 1 million acre-feet every 50-years.
               In the 21st century, this imbalance has grown negative 1 million acre-feet per decade.
  • The second step is a walk back to Year 2006 and completely abandon the miscalculations for the Preferred Alternative of the Seven States.
  • The third step is to recognize that in addition to having a water scarcity issue, the basin has serious planning and zoning problems.
  1. What the future NEPA process should be: basin-wide in scope, programmatic, comprehensive, well-funded and well-staffed.
  2. Prioritize the natural environment and include conservation biologists as consultants.
  3. Prioritize consultation with the sovereign tribes and the Republic of Mexico.
  4. Initiate a focus on developing local, regional, national, and international climate adaption programs.
  5. Work with nature and focus attention on rehabiliting the functions of the natural watershed.
  6. Abandon the preferred and myopic climate record from 1906 to 2019 (stationarity is dead). The natural supply data of the 20th century is skewed. 
  7. Incorporate the long-term paleoclimate record with the purpose of preparing management plans to prevent the consequences of "mega-drought" and "mega-flood." Enduring aridity and floods were persistent during the Medieval Warm Period (+1 degree C) and the Little Ice Age (-1 degree C).
  8. Expand the information initally provided in Appendix N and U from 2007 Interim Guidelines EIS and use this information to produce fresh narratives about cumulative impacts and affected environments for multiple centuries.
  9. We suggest that prioritizing the care and health of wildlife, is what will accomplish resiliency and sustainibility for humans.


This page is Part Two (narratives old and new)

  • Click here for Part One A: By date - News and Opinion
  • Click here for Part One B: By subject - News and Opinion
  • Click here for Part Two: Narratives - Old and New.
  • Click here for Part Three: The Physical and Social Sciences
  • Click here for Part Four: Solutions - Climate Adaptation, Sustainibility and Resilence

Discussion:   Talk about this article...


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