The Colorado River Basin States Representa�ves of

Arizona, California, and Nevada

March 6, 2024

The Honorable Camille Calimlim Touton

Commissioner
Bureau of Reclama�on
1849 C Street, NW
Washington, DC 20240

Re: Lower Basin Alterna�ve for the Post-2026 Coordinated Opera�on of the Colorado River
Basin

Dear Commissioner Touton:

The undersigned Governors’ Representa�ves of Arizona, California, and Nevada

(Lower Division States) appreciate the opportunity to submit the atached alterna�ve (Lower
Basin Alterna�ve) for the Bureau of Reclama�on (Reclama�on) to analyze as part of
Reclama�on’s Na�onal Environmental Policy Act (NEPA) review to adopt guidelines and
coordinated reservoir management strategies to address future opera�ons of Lake Powell and
Lake Mead. These new guidelines will take effect when the 2007 Colorado River Interim
Guidelines for Lower Basin Shortages and Coordinated Opera�ons for Lake Powell and Lake
Mead (2007 Interim Guidelines) expire in 2026 as described in the Scoping Report for Post-2026
Colorado River Reservoir Opera�ons (88 FR 72535, October 20, 2023) (Scoping Report).

This Lower Basin Alterna�ve is designed to provide for the sustainable management of the
Colorado River system and its resources under a wide range of poten�al future system
condi�ons due to a changing climate, consistent with the Scoping Report. Since Reclama�on
ini�ated this ac�on in June 2023, the Colorado River Basin States (Basin States) have been
working to develop a consensus alterna�ve, as noted in the Basin States’ August 15, 2023,
scoping leter. Although there is agreement among the Basin States regarding the need to
provide for opera�ons of Lake Powell and Lake Mead under a wide range of poten�al future
system condi�ons due to a changing climate, at this point the seven Basin States have been
unable to agree on a consensus alterna�ve. The Lower Division States look forward to further
discussions with the Upper Division States, as well as Tribes, non-governmental organiza�ons,
and other stakeholders, to develop a consensus while Reclama�on evaluates alterna�ves.
Re: Lower Basin Alterna�ve
March 6, 2024
Page 2 of 7

Par�cipa�on by Mexico
The Lower Basin Alterna�ve includes assump�ons regarding par�cipa�on by Mexico in
reduc�ons; surplus deliveries; and the conserva�on, augmenta�on, and storage program
commensurate with prior Treaty Minutes. We recognize that any par�cipa�on by Mexico will be
determined in a separate process with Mexico. However, to provide sufficient informa�on for
analysis of the full range of impacts within the United States, changes in flows associated with
Mexico’s poten�al par�cipa�on in surpluses, reduc�ons, conserva�on and storage need to be
analyzed. We look forward to future collabora�on with Mexico in this work through the
Interna�onal Water and Boundary Commission and Reclama�on.

Background and Key Alterna�ve Concepts

When the Basin States worked with Reclama�on and the Department of the Interior
(Department) to develop the 2007 Interim Guidelines, the Colorado River Basin had been in
drought for seven years and Lake Powell and Lake Mead - nearly full in 2000 - had started to
decline. To address the drought and declining reservoirs, the 2007 Interim Guidelines
incen�vized conserva�on through the crea�on of Inten�onally Created Surplus and established
Lower Basin shortage provisions. But it soon became clear that the 2007 Interim Guidelines
were insufficient to reduce the risks of Lake Powell and Lake Mead declining to cri�cally low
eleva�ons. In response, the Basin States, Tribes, Mexico, water managers, Reclama�on, the
Department, and Congress took ac�on through a range of voluntary measures and the 2019
Drought Con�ngency Plan. These efforts were successful in stabilizing reservoir eleva�ons some
of the �me, but they have not adequately reduced the risk of the reservoirs declining to cri�cal
eleva�ons.

The 2007 Interim Guidelines are expiring as the Colorado River now enters the twenty-fi�h year
of drought – condi�ons that have been exacerbated by climate change. Hoter and drier
condi�ons have resulted in reduced run-off into the River that has led to significant declines in
Colorado River system storage. The Lower Basin Alterna�ve is designed to address the impacts
of drought and climate change through a holis�c and sustainable approach to the coordinated
opera�ons of Lake Powell and Lake Mead that improves predictability for water users by:

1. Addressing the structural deficit in the Lower Basin. This Alterna�ve includes reduc�ons
from Lower Basin state appor�onments and deliveries to Mexico by 1.5 million acre-feet
(maf) (sta�c reduc�on) under most system condi�ons. The sta�c reduc�on is larger than
the structural deficit in the Lower Basin regardless of the various ways that the structural
deficit may be calculated.
2. Opera�ng the reservoirs based on system contents rather than eleva�ons at Lake Powell
and Lake Mead. The Lower Basin Alterna�ve shi�s to a more holis�c, system wide,
approach that is based on actual hydrology and total system contents instead of
forecasts and individual reservoir eleva�ons.
Re: Lower Basin Alterna�ve
March 6, 2024
Page 3 of 7

3. Sharing water use reduc�ons broadly. This Alterna�ve recognizes the need to make
water use reduc�ons from state appor�onments under most system condi�ons and
shares those reduc�ons predictably among the Lower Basin water users and Mexico.
Under the most cri�cal system condi�ons, the Alterna�ve shares water use reduc�ons
between the Upper Basin and Lower Basin including Mexico.
4. Including provisions for storage and delivery of stored water. The Lower Basin
Alterna�ve’s approach includes opportuni�es for storage and augmenta�on that will
encourage innova�on and investment.
5. Establishing releases from Lake Powell that are adaptable to a broad range of
hydrologies and respond to “hydrologic shortages.” This Alterna�ve adjusts releases to
respond to factors impac�ng Upper Basin use. Addi�onally, most balancing condi�ons
are removed to avoid conflict between the Upper and Lower Basins.

The Lower Basin Alterna�ve is designed to achieve a sustainable volume of water in system
storage. That storage will help to protect infrastructure and habitat and provide predictability
for water users. The Alterna�ve’s reduc�on framework is triggered by total system contents (as
opposed to forecasts) to determine the opera�ons of Lake Powell and Lake Mead. The
Alterna�ve also includes opportuni�es for storage, augmenta�on, demand management, and
other water management strategies.

The Lower Basin Alterna�ve represents a compila�on of strategies based on the lessons learned
from the 2007 Interim Guidelines as well as hydrologic supply and demand informa�on gleaned
over recent decades. The elements of this Alterna�ve are related and interdependent; removing
or replacing one or more of these elements without full considera�on of the en�re Alterna�ve
would likely diminish the management value.
This leter describes various aspects of the Lower Basin Alterna�ve and should be read in
conjunc�on with the atached technical document.
Total System Contents
The Lower Basin Alterna�ve shi�s away from the reliance in the 2007 Interim Guidelines on the
24-Month Study forecasts and eleva�ons in Lake Powell and Lake Mead to determine reservoir
releases and Lower Basin shortages. This Alterna�ve instead primarily uses actual hydrology and
total system contents—a recogni�on that, whatever the eleva�on of a par�cular reservoir in the
system may be, sustainable management must be focused on contents that are actually
available in the system as a whole. “Total system contents” includes the contents of Flaming
Gorge, Blue Mesa, Navajo, Powell, Mead, Mohave, and Havasu.1 In addi�on to more holis�cally

1
For purposes of this Lower Basin Alterna�ve, “total system contents” is the total volume of water in live
storage within Flaming Gorge Reservoir, Blue Mesa Reservoir, Navajo Reservoir, Lake Powell, Lake Mead,
Lake Mojave, and Lake Havasu. Inclusion of the Colorado River Storage Project Act Ini�al Units is not
intended to open the Records of Decision for those facili�es.
Re: Lower Basin Alterna�ve
March 6, 2024
Page 4 of 7

managing the system, moving away from forecasts and reservoir eleva�ons and instead relying
on actual hydrology and system contents should reduce disagreements among and between the
Basins that have resulted from reliance on Lake Powell and Lake Mead eleva�ons and 24-Month
Study forecasts in the past.

Water Use Reduc�ons

The Lower Basin Alterna�ve proposes a new framework for determining annual water use
reduc�ons when total system contents are:
• 69% - 58%: cuts to Lower Basin water uses increasing from 0 to 1.5 maf
• <58% - 38%: sta�c cut to Lower Basin water uses of 1.5 maf
• <38% - 23%: sta�c cut to Lower Basin water uses of 1.5 maf plus addi�onal, evenly split
cuts to Upper Basin and Lower Basin water uses as total system reduc�ons increase from
1.5 maf to 3.9 maf.2 Reduc�ons would remain at 3.9 maf below 23%.
This approach resolves the structural deficit in the system between Lee Ferry and the U.S.-
Mexico border, reduces the risk of the system declining to cri�cal levels, shares water use
reduc�ons broadly, improves predictability for water users, and includes the Upper Basin in
water reduc�ons under the most cri�cal system condi�ons. Most fundamentally, this
framework commits stakeholders to the simple principle that when less water is available in the
system, less water should be taken from the system.

Releases from Glen Canyon Dam

Linking Lower Basin water use reduc�ons to total system storage rather than the eleva�on of
Lake Mead reduces the significance of the rela�ve volumes of water in Lakes Powell and Mead.
The Lower Basin Alterna�ve includes a Glen Canyon Dam release regime designed to minimize
risk of noncompliance with the 1922 Compact while providing benefits to power genera�on, in-
stream resources at the Grand Canyon and habitat below Lake Powell, and the recrea�onal
atributes of Lakes Powell and Mead.

Like Lower Basin water use reduc�ons, annual release volumes from Lake Powell are set based
on live storage in the Colorado River Storage Project (CRSP) Ini�al Units: Flaming Gorge
Reservoir, Blue Mesa Reservoir, Navajo Reservoir, and Lake Powell (described in this Alterna�ve
as “Total UB System Contents”). In most years, Glen Canyon Dam releases will be determined by
a combina�on of Total UB System Contents and Upper Basin deple�ons in the previous three
years. When Upper Basin deple�ons decrease due to aridifica�on and/or “hydrologic shortage,”
releases from Lake Powell decrease as well.

2
The Lower Division States are also reques�ng that Reclama�on model a range of reduc�ons in the
Upper Basin up to 2.4 maf in this zone to provide a full range of analysis.
Re: Lower Basin Alterna�ve
March 6, 2024
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The atached technical document provides more detail, but in general the Glen Canyon Dam
annual release regime is based on four bands of Total UB System Contents, with a poten�al April
adjustment to protect Lake Mead eleva�on 1000 �. When Total UB System Contents are:
Greater than 80% (“Equaliza�on Release”). Balance the contents of Lakes Powell and
Mead as closely as prac�cable with releases between 8.5 maf to 11.0 maf.

Greater than 30% and less than or equal to 80% (“Hydrologic Shortage-Based Release”).
Releases vary in a stepwise fashion between 7.0 maf and 8.5 maf depending on the
extent of Upper Basin “hydrologic shortage.”

Greater than 20% and less than or equal to 30% (“Reduced Release Ramp”). Releases of
6.0 maf to 7.0 maf determined as a linear func�on.

Total UB System Contents less than or equal to 20% (“Sta�c Release”). Release of 6.0
maf.

Conserva�on, Innova�on, and Investment

Since the 2007 Interim Guidelines were adopted, water managers in the Lower Division States
have been working individually and in partnership to adapt to the stresses on the Colorado
River system resul�ng from drought and climate change. The Lower Basin, in partnership with
the United States and Mexico, has invested billions of dollars over the interim period to
conserve water for the benefit of the Colorado River system and the development of
inten�onally created surplus. Many of these investments are ongoing and will con�nue well
beyond 2026.

As a result of that investment, water users in the Lower Basin and Mexico have conserved
enough water to bolster the eleva�on in Lake Mead by 91 feet. The success of these
collabora�ve efforts enabled the Lower Division States to propose the Lower Basin Plan to
conserve 3 million acre-feet over 4 years to address short-term protec�on of the Colorado River
system, adopted as the preferred alterna�ve in the Supplemental Environmental Impact
Statement released yesterday. In 2023 alone, the Lower Basin reduced its consump�ve use to
5.8 million acre-feet – leaving 1.7 million acre-feet in the system.

The Lower Basin Alterna�ve seeks to retain the core concepts of conserva�on, augmenta�on,
and storage from the 2007 Interim Guidelines but will include updates to the program based on
opera�onal experience. The Lower Basin Alterna�ve recommends a broad range of parameters
for evalua�on at this �me. We are s�ll developing the details and expect to narrow the range as
we work with our respec�ve stakeholders in the coming months. Ul�mately, we support a
program that allows for the storage of conserved and augmenta�on water to incen�vize
Re: Lower Basin Alterna�ve
March 6, 2024
Page 6 of 7

conserva�on, innova�on, and investment that does not influence the coordinated opera�ons of
Lake Powell and Lake Mead.

Intrastate Processes and Federal Support

Although we have proposed the Lower Basin Alterna�ve, we s�ll have work to achieve
consensus support within our respec�ve states, allocate reduc�ons within our states, and seek
support from the Upper Division States, Basin Tribes, non-governmental organiza�ons, and
Mexico. Throughout the Lower Basin both tribal and non-tribal water users will be significantly
affected by water supply reduc�ons.

To achieve the necessary stakeholder support within our respec�ve states, we will likely need to
work together to find partnership and funding opportuni�es to further the conserva�on
programs and augmenta�on projects necessary to achieve the Alterna�ve’s water use
reduc�ons. We are seeking federal support in those intrastate conversa�ons, including federal
resources to reduce the impacts to both tribal and non-tribal water users.

Analysis of Alterna�ves with Respect to Glen Canyon Dam Infrastructure

The Lower Basin Alterna�ve was designed to meet the purpose and need as described by
Reclama�on in the Scoping Report. Reclama�on more recently has ar�culated concerns
regarding poten�al cavita�on in the river outlet works and scouring in the river botom below
the river outlet works that may occur with greater intensity at lower Lake Powell eleva�ons. We
understand the following based on the 38 Sovereigns webinar discussion led by Reclama�on on
February 28, 2024:
i. Reclama�on con�nues to evaluate the extent of its Glen Canyon Dam infrastructure
concerns through both physical and computer modeling and will invite stakeholder
technical support in comple�ng its reviews.
ii. For purposes of the Post-2026 coordinated river opera�ons NEPA process, Reclama�on
will neither set a floor for Lake Powell opera�ons in its “No-Ac�on” alterna�ve nor
screen any reasonable alterna�ve from considera�on that does not maintain Lake
Powell above any par�cular eleva�on.
iii. Reclama�on is considering several poten�al infrastructure modifica�ons that may
mi�gate or eliminate concerns with opera�ons occurring at Lake Powell eleva�ons
requiring use of the river outlet works.
We look forward to working with Reclama�on to evaluate the infrastructure vulnerabili�es
men�oned and help develop solu�ons. We an�cipate that protec�ng Glen Canyon
Infrastructure may involve a host of strategies including infrastructure modifica�ons, strategic
releases from CRSP units, and water use reduc�ons in both the Upper and Lower Basins.

Importantly, however, based on our preliminary reviews, the Lower Basin Alterna�ve is highly
effec�ve at keeping Lake Powell above cri�cal eleva�ons. Even during drier hydrologies, when
Re: Lower Basin Alterna�ve
March 6, 2024
Page 7 of 7

Lake Powell’s eleva�on may temporarily fall below 3500 feet, the use of total system contents in
the Lower Basin Alterna�ve improves flexibility to protect cri�cal infrastructure by enabling the
movement of water through the system as necessary for infrastructure protec�on and
environmental flows while sa�sfying water delivery requirements and Compact obliga�ons.

Reserva�on of Rights
By providing this alterna�ve, we do not waive any rights, including any claims or defenses, we
may have or that may accrue under federal or state law. Recommenda�on by the undersigned
that Reclama�on analyze the Lower Basin Alterna�ve shall not be construed as an endorsement
or an admission with respect to any factual or legal issue for the purposes of any future legal,
administra�ve, or other proceeding. Moreover, we reserve the right to provide further
comments and engage with Reclama�on as it proceeds with subsequent phases of the NEPA
process.

Conclusion
We appreciate your considera�on of the atached Lower Basin Alterna�ve, and we are available
to discuss the details with you and with other stakeholders as appropriate. We remain
commited to collabora�ng with other stakeholders, including the Upper Division States, the
Republic of Mexico through the Interna�onal Boundary and Water Commission, Tribes, non-
governmental organiza�ons, and other water users in the Colorado River Basin. The Lower Basin
States look forward to working with Reclama�on through the next steps of developing the Post-
2026 Opera�onal Guidelines and Strategies.

Respec�ully Submited,

____________________________________ ____________________________________
Thomas Buschatzke, Director J.B. Hamby, Chairman & Commissioner
Arizona Department of Water Resources Colorado River Board of California

____________________________________
John J. Entsminger, General Manager
Southern Nevada Water Authority
Attachment to March 6, 2024, Letter

Attachment: Lower Basin Alternative

1. Introduction
Arizona, California, and Nevada (collectively referred to as the Lower Division States) have
developed this alternative for analysis and consideration as part of the preparation of an
Environmental Impact Statement (EIS) for the development of the Post-2026 Operational
Guidelines and Strategies for Lake Powell and Lake Mead. This alternative meets the purpose
and need of the EIS by updating and expanding management guidelines for Colorado River
reservoirs, improving predictability of reductions for Lower Basin water users and water supply
reliability, and providing additional mechanisms for conservation, storage, and delivery under a
wide range of potential future system conditions due to a changing climate. Moreover, this
alternative takes into consideration the imbalance between water supply and demand below
Lee Ferry, as climate change continues to impact temperatures, precipitation, and run-off in the
Basin. This document should be read and considered in conjunction with the letter to which it is
attached.

As explained in the letter, the Lower Basin Alternative incorporates assumptions regarding
Mexico’s participation in reductions, surplus deliveries, and the conservation, augmentation,
and storage program. The assumptions regarding Mexico are commensurate with provisions in
past minutes to the 1944 Treaty. While we recognize that any participation by Mexico in these
components will be determined in a separate process through the International Boundary and
Water Commission with Reclamation’s assistance, the impact analysis must consider the
cumulative effects of the contemplated actions.

2. Lower Basin Alternative

The Lower Basin Alternative proposes total system contents as a trigger mechanism for water
use (including reductions) to provide predictability to Colorado River water users and to address
the structural deficit.
Total System Contents Approach
Under the Lower Basin Alternative, the permitted consumptive use of Colorado River water is a
function of the total volume of water in live storage (water above deadpool) within Flaming
Gorge Reservoir, Blue Mesa Reservoir, Navajo Reservoir, Lake Powell, Lake Mead, Lake Mojave,
and Lake Havasu (hereinafter referred to as “total system contents”) so that hydrology and
system contents dictate water availability rather than forecasts and individual reservoir
elevations. Under most hydrologic conditions, these actions are sufficient to protect
approximately 13 million acre-feet of water in live storage (23% of total system contents), a
necessary buffer against future hydrologic and operational uncertainties, including potential
infrastructure issues.

1
Attachment to March 6, 2024, Letter

The Lower Basin Alternative will address water use at all reservoir conditions: Surplus, Normal,
and during reductions. The formulation of the three operational elements of the proposed
federal action are as follows:

a. Reductions
The Lower Basin Alternative provides discrete levels of reductions associated with specific levels
of total system contents as presented below. These reductions are based on decreases in
consumptive use for the specified state1 or reductions in deliveries to Mexico. In some cases,
these reductions may be “pre-conserved,” as discussed in section (e). The alternative provides
criteria for annual basin-wide reductions up to a maximum of 3.9 million acre-feet (MAF).
Reductions under the Lower Basin Alternative follow a rule curve (colloquially referred to as the
“Z-curve”) illustrated below.

1
At this time, we are proposing reductions to the apportionment of each of the Lower Division States. Intra-state
discussion will be necessary to determine how reductions are distributed among water users.

2
Attachment to March 6, 2024, Letter

The Z-curve identifies the total system contents of the reservoirs and five distinct reduction
zones: No Reduction, Initial Reduction, Static Reduction, Basin-wide Reduction, and Basin-wide
Maximum Reduction. Each reduction zone is described below. Reduction volumes should be
rounded to the nearest acre-foot and two decimal places should be used to compute total
system contents. Reductions in consumptive use resulting from “Bucket 2” projects should also
count towards the reductions described below.

i. Initial Reduction Zone

When the total system contents are at or below 69% on August 1, but at or above 58%, the
reduction volume for water users in the Lower Division States and Mexico for the
subsequent calendar year would be a linear function of total system contents increasing
from 0 at 69% to 1.5 million acre-feet at 58%.

The reductions in this zone would be shared as follows: Once the total reduction has been
calculated, AZ, NV, and Mexico would share proportionally in reductions up to 300,000 acre-
feet, distributed 80.00%, 3.33%, and 16.67%, respectively. For reduction volumes above
300,000 acre-feet, the first 300,000 acre-feet would be calculated as previously mentioned
and the incremental reduction above 300,000 acre-feet would be shared proportionally
among AZ, CA, NV, and Mexico at a rate of 43.33%, 36.67%, 3.33%, and 16.67%,
respectively.

ii. Static Reduction Zone

When the total system contents are below 58% on August 1, but at or above 38% the
reduction volume imposed on water users in the Lower Division States and Mexico for the
subsequent calendar year would be 1.5 million acre-feet, distributed as follows:

State/Country Reduction Volume (AF)

Arizona 760,000
California 440,000
Nevada 50,000
Mexico 250,000

iii. Basin-wide Reduction Zone

When the total system contents are below 38% on August 1, but at or above 23%, the
reduction volume that would be imposed on water users in the Lower Division States, the
Upper Division States, and Mexico for the subsequent calendar year would be a linear
function of total system contents increasing from 1.5 million acre-feet at 38% to 3.9 million
acre-feet at 23%.

3
Attachment to March 6, 2024, Letter

The reductions in this zone above 1.5 million acre-feet would be shared so that 50% is
allocated to the Lower Division States and Mexico and 50% is allocated to the Upper Division
States. For example, if the calculated reduction is 2.0 million acre-feet, the first 1.5 million
acre-feet would be contributed as described in section ii above. The additional 500,000 acre-
feet would be shared with the Lower Division States and Mexico reducing use by 250,000
acre-feet and the Upper Division States reducing use by 250,000 acre-feet. At this time, we
are not proposing a distribution of the Lower Basin and Mexico share of the additional
reduction volume.

Additionally, the Lower Division States request that Reclamation model reductions in the
Upper Basin of up to 2.4 million acre-feet per year on the Second Linear Ramp. This will
provide a full range of analysis for compliance purposes.

iv. Basin-wide Maximum Reduction Zone

When the total system contents are below 23% on August 1, the reduction volume imposed
on water users in the Lower Division States, the Upper Division States, and Mexico for the
subsequent calendar year would be 3.9 million acre-feet, to be distributed as described in
part 2(a)(iii).

b. Lower Division States and Mexico Surplus

Surplus would occur under a narrower range of conditions than the current operating rules.
These rules need further refinement. However, the Lower Basin Alternative envisions surplus
would increase as a part of a linear function instead of in step-wise fashion. Surplus would also
start occurring with more water in storage. During these surplus conditions, Arizona will receive
240,000 acre-feet of surplus before California receives access to surplus. The Lower Basin
Alternative assumes that Mexico will participate in surplus volumes commensurate with
Minutes 319 and 323 to the 1944 Treaty.

The Lower Basin States would like Reclamation’s assistance in further refining the proposed
surplus criteria to evaluate the appropriate triggers, given the total system contents approach
for reductions. Because surplus is, at least in part, intended to offset the risk of spilling water, it
is important to fully explore how Lake Mead’s elevation relates to total system contents and
surplus triggers and volumes. We would also like to explore and understand the drivers of the
70R criteria to ensure they are appropriate for our current understanding of hydrologic
projections and associated risks.

c. Coordinated Operations of Lake Powell and Lake Mead

Lake Powell’s release to Lake Mead will also use a broader system contents approach than the
current guidelines that is more consistent with section 602(a) of the Colorado River Basin
Project Act. The elements of these releases are described below the following summary table.

4
Attachment to March 6, 2024, Letter

5
Attachment to March 6, 2024, Letter

i. Equalization release
The total system contents approach to reductions reduces the urgency of equalization as it
no longer directly affects the Lower Basin’s shortage risk. As such, equalization rules could
be simplified to provide more flexibility for releases to protect water deliveries, critical
infrastructure, power, and Glen and Grand Canyon resources.

If the live storage in the Colorado River Storage Project (“CRSP”) Initial Units (Flaming Gorge
Reservoir, Blue Mesa Reservoir, Navajo Reservoir, and Lake Powell) on October 1 exceeds
80%, the water-year release will range between 8.5 million acre-feet and 11.0 million acre-
feet to equalize live contents in Lake Powell and Lake Mead at the end of the water year to
the greatest extent practicable. Should flood control criteria be activated, that criteria will
then control the release.

ii. Hydrologic Shortage-Based Release Regime

The Lower Basin Alternative would result in most releases occurring in the “Hydrologic
shortage-based release regime.” During this operating condition, Upper Basin use is a proxy
for ongoing aridification and “hydrologic shortages”2 occurring within the Upper Basin. As
Upper Basin use decreases due to aridification and/or “hydrologic shortages” the volume of
water released from Lake Powell decreases as well. If conditions are dry, releases will be
less, holding other variables constant.

When the live storage in the CRSP Initial Units on October 1 is greater than 30% but less
than or equal to 80%, the release from Lake Powell will vary between 7.0 and 8.5 million
acre-feet per water- year based on the average amount of Upper Basin depletions over the
three prior water years (including net evaporation from reservoirs) as described further in
the table below:

UB Depletions*
(3-yr Avg) Release
(MAF) (MAF)
< 3.80 7.0
3.81 - 4.30 7.5
4.31 - 4.80 8.0
> 4.80 8.5
*Includes net reservoir evaporation from
Colorado River mainstem reservoirs.
2
There is no agreed upon definition of the term “hydrologic shortage.” It is used colloquially herein to describe a
broad range of factors that affect water supply availability in the Upper Division states without taking a position on
which of these factors are “shortages.”

6
Attachment to March 6, 2024, Letter

iii. Reduced Release Ramp

When the live storage in CRSP Initial Units on October 1 is greater than 20% but less than or
equal to 30%, the water year release volume from Lake Powell shall be a linear function of
live storage in the CRSP Initial Units increasing from 6.0 million acre-feet at 20% to 7.0
million acre-feet at 30%.

iv. Static Releases

When the live storage in the CRSP Initial Units on October 1 is less than or equal to 20%, the
water year release volume from Lake Powell shall be 6.0 million acre-feet unless such
release volume is not physically possible.

v. April Adjustment
Except during equalization conditions, if on April 1 Lake Mead is projected to end the water-
year below elevation 1,000 feet and Lake Powell is projected to end the water-year above
elevation 3,510 feet, the water-year release will be adjusted to range between 8.5 million
acre-feet and 11.0 million acre-feet to achieve as practicable equal live contents in Lake
Powell and Lake Mead at the end of the water year. Once triggered, the release shall be
adjusted monthly and occur through the end of the water year.

vi. Emergency Response Actions

The Lower Basin Alternative assumes that the United States will incorporate response
operations at upstream Colorado River reservoirs, consistent with their statutory purposes,
to protect critical infrastructure at Glen Canyon Dam.

d. Storage and Delivery

The current Intentionally Created Surplus (ICS) Program has proven to be a valuable tool by
encouraging water conservation and helping to bolster reservoir elevations. However, there are
also inequities (both real and perceived) in access to and accounting for ICS. As such, the Lower
Basin Alternative proposes concluding the ICS program and developing a new set of rules for
future conservation, augmentation and storage.

i. Existing ICS
There are existing provisions for the post-2026 management of ICS created prior to 2026
(“Existing ICS”). The Lower Basin Alternative also contemplates additional rules to allow
Existing ICS to be used to offset a portion of the required reductions. The Lower Division

7
Attachment to March 6, 2024, Letter

States would like to work with Reclamation to analyze different approaches to the
outstanding variables.
ii. Post-2026 Conservation, Augmentation and Storage Program
The Lower Basin Alternative proposes a new program to incentivize conservation and
augmentation by allowing storage of that water. The Lower Division States have identified
certain parameters for consideration, while others remain under discussion.
The Lower Basin Alternative includes the following parameters for conservation,
augmentation and storage:

• The Lower Division States propose that Reclamation analyze accumulation volumes
ranging from 5.0 – 10.0 million acre-feet of water for storage by water users in the Lower
Division States and Mexico based on conservation and augmentation. The Lower
Division States intend to continue our discussions with Reclamation and Mexico, as we
determine the appropriate parameters for storage based on conservation and
augmentation.
• This stored water will provide flexibility in managing reductions, including allowing for
the “pre-conservation” of reductions so that water stored in a previous year could be
delivered to offset reduction volumes and/or to avoid inadvertent overruns.
• Delivery of stored water should not allow any state to exceed its basic apportionment
when reductions apply in the Lower Basin (except limited inadvertent overruns,
augmentation, and tributary conservation water).
• The volume of water stored should be subtracted from the total system contents before
reductions are calculated so as not to diminish the volume of reduction that would
otherwise occur absent the stored water.