If we have learned anything from the current crisis on the Colorado River, it is that we have to know what we’ll do next if the current thing we’re doing isn’t enough.
That’s a bloggy shorthand for a deep argument that Eric Kuhn, Jack Schmidt, and I made in comments we submitted this week in response to the U.S. Department of Interior’s request for input on the development of new river operating guidelines.
As we begin discussing what replaces the soon-to-expire Colorado River operating guidelines, we argue that there are important lessons to be learned from a careful examination of the way the current guidelines have failed us.
The Failure of the 2007 Guidelines and Drought Contingency Plan(s)
In its Final Environmental Impact Statement in support of the 2007 Interim Guidelines, Interior identified the purpose and need of these Guidelines as an effort to provide “predictability” – “a greater degree of certainty to United States’ Colorado River water users and managers …, thereby allowing water users … to know when, and by how much, water deliveries will be reduced in drought and other low reservoir conditions.”
“Predictability”? “Certainty”? Crisis of 2022 says “nope”.
We’re trying to use language here – “purpose and need”, the National Environmental Policy Act terms of art – that burrows into the heads of the hard-working feds who will be reading it (we wave – you know who you are).
The failure, which Eric, Jack, and I talked about here in an argument developed while we were working on these comments, was a set of operating rules keyed on reservoir elevations in a way that managed to hold them steady, but never refilled them. That left us vulnerable to the crash that we’re now seeing.
Our immodest suggestion
New operating rules must be keyed to the actual flows of the river, not simply the levels of the reservoirs: “[S]tream flow should be used as a component in triggering different operating regimes, not solely reservoir elevation levels.” This was the great failing of the ’07 guidelines. We need to fix it.
In some sense this seems obvious, because hydrology is now imposing this constraint on us – “long-term average consumptive uses and losses will not exceed the average natural water supply provided by the watershed”.
We recognize that there are multiple devils in the details of this recommendation including the duration of years during which balance is sought and the mechanisms by which reductions in use must be implemented to maintain a balance. Nevertheless, there is no alternative to balancing the system. We estimate that the natural supply for the period 2000-2022, including inflows within Grand Canyon, has been 12.8 maf/yr, and there is no alternative but to at least reduce basinwide water use to that value. Should watershed runoff decline even further, then basin-wide use must be further reduced.
And if or when it gets wetter again?
[I]f relatively wetter periods return, consumptive uses must remain low to recover reservoir storage.
And all of this must be done in a way that recognizes who’s been left out of past discussions like this:
We are fully cognizant of the conflict between full development of currently unused or unquantified Tribal water rights and the need to reduce overall water uses in the Basin. We believe, however, that an appropriate balance of water supplies and uses cannot ignore the unquestioned right of Tribal nations to the water necessary to fulfill the purposes of their reservations.
And this (we wave again – you know who you are):
We recognize that these goals are broad, extending beyond what some in the basin are advocating – a narrow reconsideration of reservoir operations. We are sympathetic to the burden that the breadth of analysis we are advocating will place on the dedicated and hard-working staff at Reclamation and the Department of the Interior during the next years. But anything less than an expansive view of the task at hand will fall far short of what is needed at this moment in history.
There’s lots more in the way of specifics. We encourage those interested in river management to give it a look.