Stratecon’s public comment on the Bureau of Reclamation’s Draft Environmental Impact Statement for post-2026 Colorado River operations argues that the basin faces a structural water imbalance and requires immediate policy change rather than incremental adjustments. The analysis shows that existing legal apportionments total 16.5 million acre-feet per year, while long-term natural flows average only about 14.3 million acre-feet, and after evaporation losses the effective supply is closer to 12.3 million acre-feet, leaving the system fundamentally overallocated. Stratecon proposes a five-year federal emergency management plan centered on rebuilding storage in Lake Powell and Lake Mead, potentially requiring roughly 2–3 million acre-feet of annual curtailments to restore reservoir levels toward about 50% of capacity. The comment supports Reclamation’s use of Decision-Making Under Deep Uncertainty (DMDU) and adaptive management but warns against policies that undermine the priority system or treaty obligations. Ultimately, Stratecon argues that sustainable management will depend on transparent federal rules, voluntary water transfers, and basin-wide cooperation—including Mexico—to stabilize storage and restore long-term reliability in the Colorado River system.
