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May 23, 2023

Our thoughts on Reclamation's Supplemental EIS process

May 22, 2023: Update from Reclamation about the Supplemental EIS

The Department of the Interior today announced that it is temporarily withdrawing the draft Supplemental Environmental Impact Statement published last month so that it can fully analyze the effects of the proposal under the National Environmental Policy Act.

Reclamation will then publish an updated draft SEIS for public comment with the consensus-based proposal as an action alternative. Accordingly, the original May 30, 2023, deadline for the submission of comments on the draft SEIS is no longer in effect.

The Department plans to finalize the SEIS process later this year.

For more information: Press Release

Marcie Bainson
SEIS Team Member
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States issue formal plans on May 22, 2023



How the Colorado River Basin is managed in the next three years by this SEIS process, or how it is managed in the next 3 decades by the pending process to develop new guidelines by 2026, the outcomes will not be significantly different. There is only one goal: how will water reduction programs be equitably distributed to humans without ecosystem or societal collapse?

The intent, since 2007, has always been about avoiding water shortages due to human accountability errors that have already disrupted the economy and the environment of our homeland inheritance. The collaborative solutions provided since the initiation of 2007 Guidelines were grossly insufficient and the sixteen years of potential progress hence, was squandered.

The narrrative of the SEIS does acknowledge that...

  • The hydrology of the Colorado River Basin is impacted by heat, evaporation, dry soils and by sublimation (implied); specifically a 20% reduction in annual streamflow, and that this negative consequence wiil continue to increase.
  • Proposed construction projects for water diversions and water augmentation are speculative.
  • The characteristics of groundwater resources are important.

The narrative of the SEIS does not acknowledge that...

  • Human behaviours have become problematic. For example: denial, recalcitrance, procrastination and gradualism.
  • Leadership to reduce global greenhouse gas emissions is not a shared responsibility for water managers.
  • The decomposition of organic materials in reservoirs do emit greenhouse gases.
  • The negative characteristics of vacated reservoirs will compromise the downstream ecosystems of our national parks and wildlife refuges.
  • Dams and powerplants have lifespans; a day of reckoning will confront future generations; the cost will exceed the benefits.


  • Previous scenario planning documents predict Upper Basin shortages will range between 2 to 3 million acre-feet between now and Year 2060.
  • The first priority to consider are the arrival times of approaching deadlines, as mandated by the 1922 Colorado River Compact and the 1944 Mexican Treaty (a "Compact Call").
  • The approaching Lower Basin deadline: When will 75 million acre-feet in a ten-year period fail to pass the Compact Point, located one mile below the mouth of the Paria River near Lee's Ferry, Arizona? This is a fixed number set in perpetuity; see Article IIId of the 1922 Compact.
  • The approaching deadline to Mexico: When will half of the annual water treaty allocation to Mexico, which is 750,000 acre-feet per year, fail to pass the Compact Point near Lee's Ferry, Arizona? See Article IIIc of the 1922 Compact. This amount must be adjusted down to 675,000 acre-feet, to honor a present-day shortage agreement with Mexico called Minute 323.
  • Water demand reduction programs, such as Demand Management and System Conservation, are not producing significant contributions in the range of the required 2 to 3 million acre-feet.
  • The accounting systems to measure water consumption is yet to be perfected.
  • Glen Canyon Dam was not engineered for the extremes of the natural hydrology, augmented by climate disruptions from greenhouse gas emissions.


  • Previous scenario planning documents predict Lower Basin shortagers will be 3 to 4 million acre-feet between now and Year 2060.
  • Not subtracting the evaporation and transit losses from the fixed allocations that happens between Hoover Dam and Morelos Dam (the "structural deficit") and estimated to range as high as 1.5 million acre-feet


  • Efficiency programs are confined by the limits of Nature. Perpetual growth was never an option; there is no physical law that supports such a concept.
  • There is a planning and zoning problem, more than a water resource problem.
  • Is this river basin based on a prior appropriation system, or not? If not, then the legal foundations must be changed.
  • Sustainability, resilence and equity is achieved by respecting the merits of functioning ecosystems; work with Nature.
  • The floodplain is occupied by critical infrastructure, which includes an immense structural depression below sea level called the Salton Through.






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Last Update: October 30, 2007

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