Central Utah Water Conservancy District repayment contract, Bonneville Unit, Central Utah Project

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IN REPLY REFER TO: 440 832. United States Department of the Interior WATER AND POWER RESOURCES SERVICE WASHINGTON, D.C. 20240 19JUN1980 Mr. Peter Carlson Washington Representative Environmental Policy Center 317 Pennsylvania Avenue, SE. Washington, DC 20003 Dear Mr. Carlson: Prior to finalizing our response to your letter of May 12, 1980, we received your subsequent letter of May 22, 1980, cosigned by Mr. Brent Blackwelder. I would like to respond to your comments and observations concerning recent events surrounding the repayment contract for the Bonneville Unit of the Central Utah Project. First, let me say that after reading your analysis of our actions surrounding the potential renegotiation of an amendment or supplement to the existing repayment contract it is evident that, as a member of the public for which we are trying to open the contracting process, you have been less than satisfied with our public disclosure process. Our public participation procedures for contract negotiations were developed prior to finalizing our overall Water and Power Resources Service (Service) guidelines. We felt the three were consis­tent. It may be necessary to revise our contracting procedures with respect to public participation. During our review of this matter, your comments will certainly be considered. I believe that all of our recent activities on the Bonneville contract have been conducted in accordance with our published procedures. Our public participation program has been conducted from the standpoint that the first public "airing" of the issues should take place at the time that the Service and the contractor are ready to begin the negotiation of specific terms and conditions of a proposed contract. We have not been so concerned with prelim­inary steps leading to such negotiations. In fact, we were concerned that early disclosure of options might jeopardize our negotiating position with a potential or existing contractor. In reviewing your chronology of events, I believe that our current public participation guidelines for water service and repayment contract negotiations did not relate to the consideration of the district's initial proposal on use of power revenues to assist in the repayment of the unit's municipal and industrial (M&I) function. Any decision to allow the use of power revenues for such a purpose would not have led to a new or amendatory contract. Even under the interim guidelines issued by the Department, we would have only put this issue before the public if we had seriously considered allowing power