Mr. John W. Keys, III
United States Bureau of Reclamation
Department of Interior
1849 'C' Street, NW
Washington, DC 20240-0001
Sent via fax: 202-513-0314
July 18, 2001
Dear Commissioner Keys:
We wish to congratulate you on your recent appointment and confirmation as Commissioner of Reclamation. You have undertaken an important challenge at a difficult time for the once-powerful Bureau of Reclamation, as the agency approaches the end of its first century. June 17, 2002 will mark the centennial anniversary of the federal Reclamation Act, which led to the creation of the Reclamation Service and the dramatic transformation of the rivers and landscapes of the American West that followed.
At this moment, irrigators in New Mexico are threatening to blow up Navajo Dam on the San Juan River, while in Oregon's Klamath basin, farmers are excavating a new channel bypass around the Reclamation-owned A-Canal Dam. Never before has the agency faced such criticism and anger from the very constituents that it was founded to serve. Clearly, your job will not be easy as you struggle to balance competing demands for protecting the environment while providing subsidized water and power to irrigators, cities, and industries in the West.
Major coalitions have formed over the last year, demanding that Reclamation implement basinwide environmental impact studies to restore endangered species throughout their historic ranges, decommission major dams like Glen Canyon on the Colorado River, and restore flows to the dried-up deltas of the Colorado and Rio Grande Rivers.
This letter is an invitation to work with you and your staff to address these concerns and to help shape the Bureau's future, to reflect the changing needs of our society and the needs of the rivers themselves.
Today, more than 450 Reclamation dams and diversions stand across our Western rivers in seventeen states, creating about 350 reservoirs that provide water for 180 irrigation projects and water supply for more than 30 million people. These structures and engineering achievements, some of which are among the largest in the world, store huge amounts of water and generate over forty thousand megawatts of electric power, combined. Over nine million acres of farmland are irrigated by Reclamation projects. The scope and magnitude of the public works undertaken by Reclamation is unsurpassed in terms of the effects these projects have had on the lives of the millions of people who depend in some way on the rivers of this arid region.
Certainly many associated with the Bureau of Reclamation will find cause for celebrating the upcoming centennial. But for those committed to the sound stewardship of the rivers of the West, the sentiment is reversed. This century of impounding and diverting has brought with it extensive environmental and social problems that only worsen with time.
Western rivers are critical to the protection of the region's biological diversity. Scientists tell us that many Reclamation projects are at least partly to blame for the near-extinction of many native fish and other river-dependent species across the West. Pressure is building to take down some Reclamation dams, in order to restore rivers' ecological health and recover populations of native fish and river-dependent wildlife.
A century after its founding, the agency finds itself facing declining budgets, increasing pressure to reduce the enormous subsidies to water and power users that have fueled the engine of political support for much of the Bureau's public works. Reclamation itself has said, "the arid West essentially has been reclaimed." Yet some politicians still look to Reclamation to fulfill the elusive dream of boundless resource use. While the West may have been reclaimed, its rivers are far from functioning as ecosystems and may best be described as plumbing systems.
To that end, we submit to you a summary of the key issues we look forward to addressing with you and your staff. They reflect the growing public concern that Reclamation's actions and polices are out-of-step with the environmental constraints and social demands of this modern era.
1) RECOGNIZE FEDERAL PRIMACY OF A PUBLIC RESOURCE: Reclamation must recognize that the rivers under its jurisdiction are not the property of water agencies under contract, the states, or even in some cases the United States alone, but are held in trust for the benefit of the public. Uniform leadership, authority and policy must come from the Bureau. Reclamation must begin working to overhaul antiquated laws such as the Colorado River Compact that no longer reflect current realities of the region's available water supplies or public demands for habitat preservation and social equity.
2) BASINWIDE EIS ON RIVER MANAGEMENT: Reclamation must conduct Environmental Impact Statements (EISs) on the operations and management of dams and diversions, on each river basin, for the purpose of restoring ecosystem function, to fully recover endangered native fish species throughout their historic ranges, and to address the cumulative impacts resulting from both subsidized water and hydropower development.
3) BUILD NO NEW DIVERSION OR DAMS: Reclamation must focus its attention on reversing the environmental damage and social inequities brought on by its projects. Building new infrastructure will only exacerbate existing problems and conflicts. Reclamation must support de-authorization of the proposed Animas-La Plata water project in southwestern Colorado, for which no need has been identified for the water that would be diverted from the Animas River, and which is estimated to cost federal taxpayers at least a half-billion dollars.
4) REDUCE THE NUMBER OF DAMS AND DIVERSIONS: Reclamation must conduct regular reviews in accordance with NEPA guidelines of the operations of Bureau dams, as is required of private dams under FERC. Prepare decommissioning plans for all Bureau dams, so the public is aware of direct and indirect costs that will need to be incurred once decommissioning is technically, economically, or politically deemed necessary.
5) UPHOLD INDIAN RIGHTS: Reclamation must fully and fairly compensate Indian Nations for their water rights and offer attractive financial incentives for these Nations to dedicate a portion of their water for instream flows for habitat protection. Reclamation must ensure that all traditional fishing rights are restored and maintained, and that efforts are made to restore sacred sites impacted by Bureau infrastructure.
6) ASSURE INSTREAM FLOW RIGHTS: Reclamation must establish basinwide accounting systems that establish instream flows as beneficial uses and guarantee that water left in the rivers as a result of implementing conservation programs will not be available for appropriation by other users.
7) DELTA RESTORATION: Reclamation must allocate necessary water and sediment flows to restore and protect river deltas, with immediate action for the Colorado and Rio Grande Rivers.
8) MANDATORY WATER CONSERVATION & RECYCLING: Reclamation must mandate all users of federal water projects, regardless of water rights priority status, to meet mandated targeted reductions in water consumption, by implementing water conservation and recycling programs and promoting efficient technologies in municipal, industrial, and agricultural sectors. Reclamation must mandate shifts in cropping patterns by requiring irrigators to replace water-wasting, low-value alfalfa, hay, and other livestock feed crops grown on lands served by Reclamation irrigation contracts, with vegetable and other crops that use significantly less water per acre. Reclamation must work to revive the spirit of the Reclamation Act to support only family-owned farms with federal project water.
9) REFORM HYDROPOWER MARKETING: Reclamation must adjust subsidized rates for hydropower generated at federal dams to reflect current national-average wholesale price for electricity. Require retailers of federal power to meet mandated targeted reductions in customer consumption by implementing aggressive demand-side management and energy conservation programs, including providing low-cost loans to all ratepayers for installing their own renewable energy supply infrastructure.
10) ENFORCE ENVIRONMENTAL LAWS: Reclamation must assist in the aggressive enforcement of environmental laws including the Clean Water Act, Endangered Species Act, and other laws, to stop the point and nonpoint sources of pollution, and ensure clean-up of all known pollution sources by 2010, and recognize a right to clean drinking water for all people in the watershed.
Too many dams have been built across the over-allocated rivers of the West, and too much water is being diverted from them. Outdated laws discourage water users from conserving and stand in the way of restoring water flows to stressed streambeds. The dried-up deltas of the Colorado and Rio Grande Rivers bear silent testimony to Reclamation's failure to act as responsible stewards of the rivers it has developed.
Living Rivers looks forward to working with you to bring about the long-needed changes at the Bureau of Reclamation. We look forward to a meeting with you at your earliest convenience.
But please also understand that the rivers of the West can't survive much longer the bureaucratic inertia and neglect that has characterized Reclamation's first century. If the agency is unwilling to change, then conflicts such as those currently being played out in the Klamath Basin and the San Juan River are bound to continue. For the sake of rivers and the people and other life that depends upon them, we look forward to working with you as you face this challenge of leading the Bureau of Reclamation into its second century.
On behalf of:
Utah Environmental Congress
Salt Lake City, Utah
Friends of the Earth
Center for Biological Diversity
Commissioner Keys responds