Another Point...

   I've learned over the years of fishing that it's real easy to sit on the bank in a white shirt and look pretty. It's another thing get into the water, retrieve the net, and pull some fish out of a muddy, torrential river. I support Seasonally Adjusted Steady Flows (sasf). It is the closest mimic to predam flows of any alternative. Ultimately, it is to the benefit of the resources to remain as closely attuned to the natural hydrograph as is possible. In the long run, the river will prevail.

   sasf is supported by the United States Fish & Wildlife Service, whose mission is to protect and enhance fish and wildlife populations. The Biological Opinion should be viewed as professional advice. Support for sasf was also shown by the National Research Council (who reviewed the draft eis), and by a number of fish researchers and managers in Grand Canyon.

   sasf offers a wide range of benefits to the resources compared to the Modified Low Fluctuating Flow alternative (mlff), including benefits to endangered fishes, sport fishes, conservation of riverbed sand, boating and angling safety, available area for beach camping, recreational economics, and to the aesthetic and wilderness values of Grand Canyon. These advantages are spelled out in the eis. The advantages over mlff are very likely even more dramatic given the latest incorporation of higher peak flows and upramp rates in mlff.

   sasf offers a safe strategy for the protection of the humpback chub, and should be fully implemented before experimentation with warm-water releases via selective withdrawal. It has been argued that sasf should not be implemented because it may result in increased trout abundance, which could be detrimental to the chub. The rationale continues that warming the water through selective withdrawal will far outweigh any benefits to the chub,that may accrue through sasf. In my opinion, this is a thinly veiled attempt to dodge sasf by those interests wishing to maintain the status quo of fluctuating flows.

   Chub are safe from cold-water predators in the Little Colorado River (lcr). Unlike other tributaries in Grand Canyon, the lcr is exceedingly inhospitable to trout. While warming the water does provide potential for mainstem spawning of chub, it also opens the door for invasion of additional warm-water predators, to which lcr is not immune. If sasf is not implemented, warming the water will be one of the next options available to try and improve the humpback chub situation, and it is a much riskier strategy.

   sasf has the clear potential to increase survivorship of chub fry in the mainstem over fluctuating flow alternatives. It is common knowledge among field investigators that flood events do transport small chub downriver. Flood events in the Little Colorado River transport very young chub out into the mainstem. Fluctuating flows in the mainstem are daily flood events, and can be expected to strongly compound the problem of mortality through displacement, wash-down, and predation of young chub.

   The faster the upramp rate, the quicker a fish needs to respond. It can be expected that higher upramp rates will result in less successful response and greater mortality, especially to small fish that have just undergone cold-water temperature shock.

   With increased survivorship of young chub in the mainstem, sasf could lead to lcr reaching its full carrying capacity for chub (no one knows whether or not lcr is at full capacity or not), and could even lead to colonization of chub into other tributaries. I strongly doubt that these potentials would be realized through sporadic, steady flow experiments, but will require full implementation of Seasonally Adjusted Steady Flows.

   I urge supporting the sasf alternative now. Waiting until steady flow experiments are done through Adaptive Management is uncertain, and risky. At present, amp is neither chartered nor appropriated. With the present national budget crunch, I would expect some difficulty getting Adaptive Management funded.

   Reclamation and Western could both be expected to push strongly for amp funding with sasf in place. Naturally, they'll want to experiment to see if they can get fluctuating flows back without harming the resources. However, they are not likely to push Adaptive Management to see if steady flow experiments are better for the chub, or other natural resources.

  Ultimately, a level of power resource available for marketing will be reached in the Operations of Glen Canyon Dam eis (gcdeis). The gcdeis will be followed two other eiss being prepared by Western. One is the Salt Lake City Area Integrated Projects Electric Power Marketing eis (scla/ip eis), and the other is an Energy Planning and Management Program eis (epamp eis). The scla/ip eis will “establish its commitment level for sales of long term firm electrical capacity and energy to its scla/lp customers". The epamp eis will place power under contract. Basically, it will bind utilities to comply with stipulations set by Western, or penalties can be placed on the utilities. It will also set a time frame on how often power contracts will be renewed. This can be from 5-35 years, depending on which alternative is chosen.

   The concern is that once power commitment levels are established, and the contracts are drawn up, Grand Canyon will be “locked in” to delivery of a power resource, potentially for a very long time. It is to the benefit of Grand Canyon National Park to support an alternative that offers a low power resource, and offers the most advantages to the natural resources and recreational aspects in Grand Canyon. sasf offers this exact choice.

   If a higher power resource is chosen, such as the "new" mlff alternative, it is doubtful that any return to a lower power resource, such as sasf, would ever occur. I would expect that even experimental steady flow experiments would be subject to cancellation, much like the beach flows were this year.

   The National Academy of Science suggested incorporation of “non-use values” in 1987. Despite this, non-use values were not incorporated into the final eis, but will be published in a separate document. I suspect this is because non users would likely care most about the natural resources and Native Americans, rather than power marketing. The answer we continually hear is that the cooperating agencies broadly support the preferred alternative. As we’ve all read, the purpose of the eis “is to determine specific options that could be implemented-consistent with law-to minimize adverse impacts on the downstream environmental and cultural resources and Native American interests in Glen and Grand Canyons”. I don’t see anything in that sentence about minimizing adverse impacts to power marketing. I do agree that the cultural resources of Native American interests were addressed professionally, and the people involved in the Programmatic Agreement should be recognized for a job well done. However, power politics again enters the picture. One of the concerns of the Navajo Nation (and I assume other Native American interests) is economics. The Navajo Tribal Utility Authority purchases about a fourth of its power from Western. As such, it is a high reliance utility subject to increased power rates under sasf. Despite these facts, there is no mitigation in the eis to insure Native American economic interests are met. This leads me to believe that the real interests being protected are those of high reliance Salt Lake City area power utilities, and not Native American interests. Under any operational scenario at Glen Canyon Dam, Native American interests should be guaranteed the same stable, long-term firm power rates. Maybe Salt Lake City should be looking at Hoover dam for peak power, give the base power load of sasf to the Tribes, and give the natural resources in Grand Canyon National Park back to the American public.

   Chubs and cheers,

David R. Van Haverbeke