One More...

   The Grand Canyon Trust would like to once again thank the Bureau for conducting an open and responsible process, one that included many parties: environmental, recreational, water and power interests, Native Americans, and other resource managers. We commend the Cooperating Agencies for their efforts as well.

   The Preferred Alternative Final Environmental Impact Statement should, above all, meet the mandate of the Grand Canyon Protection Act to operate Glen Canyon Dam “...in such a manner as to protect, mitigate adverse impacts to, and improve the value for which Grand Canyon National Park and Glen Canyon National Recreation Area were established, including, but not limited to natural and cultural resources and visitor use.”

   Now that this important document is completed, it is in the best interest of us all to move quickly ahead. We urge the Secretary of the Interior to call for an efficient and timely audit by the General Accounting Office as mandated by the Grand Canyon Protection Act and to issue a Record of Decision well before the end of 1996.

   We would like to make the following specific comments on the Final eis.

   Preferred Alternative Flows

   The Grand Canyon Trust supports the limits on minimum flows, downramp rates, and daily fluctuations as described in the preferred alternative. We cannot, however, support the increase in upramp rates or maximum releases without credible proof, based on the testing of a specific scientific hypothesis, that these alterations in operating procedures at Glen Canyon Dam follow the spirit and intent of the Grand Canyon Protection Act. At the very least, the implementation of two parameters at once sacrifices the ability to scientifically monitor future impacts.

   Four years of monitoring flows similar to those described in the draft eis have shown these flows to be beneficial to the river’s downstream resources. We suggest that a more formal assessment be made of the benefits and impacts of any changes to these flows before they be implemented. We suggest that they be treated in the same manner in which changes will be addressed under adaptive management and that a thorough assessment be produced similar to that envisioned in annual reports from the Adaptive Management Work Group to the Secretary of the Interior. This assessment should, as a minimum, include the following:

   1) The background and assumptions under which the changes are being proposed,

   2) Specific resources that could be impacted positively or negatively,

   3) Specific studies already completed that best address these impacts and paraphrase the arguments pro and con,

   4) Identify resources and resource systems to which long-term impacts might be expected to occur,

   5) Identify the monitoring criteria necessary to measure the success or failure of the proposed changes,

   6) A peer-reviewed final recommendation for: a) further research before implementation, b) trial implementation with specific monitoring goals, and/or c) implementation with long-term monitoring. 

   Habitat Maintenance and Beach Building Flows

   We support the annual habitat maintenance flows designed to maintain the critical habitats and the dynamics of the natural system and habitat/beach building flows designed to redeposit sediment and reshape the river’s topography much like the Canyon’s historic floods. We are disappointed in the recent postponement of the spike flow scheduled for this spring and urge Reclamation, in conjunction with the scientists, the upper basin states, and environmental groups, to work toward implementation of an experimental habitat/beach building flow for spring 1996. A critical evaluation of its flow size, timing, impact on fisheries, and a comprehensive research and monitoring plan should be completed prior to implementation.

   Endangered Fish Research

   We support experimental steady flows to benefit endangered fish species, subject to the results of a risk/benefit analysis now in progress. We recognize that there are inherent risks in any change to the present system. Efforts to help the humpback chub risk helping non native predators as well. This possibility and clearly defined standards by which to measure the success or failure of the experiment must be considered and identified in the final research plan.

   Flood Frequency Reduction

   While we applaud the recognition of the need to apply the nepa process to any decision to raise the level of the spillways at Glen Canyon Dam, we urge that the Secretary instead achieve the same flood frequency reduction by reserving greater reservoir storage. According to the eis it would not measurably increase the likelihood for future water shortages in the upper basin States, would cost nothing, would result in a net gain in water by reducing losses to evaporation and bank storage, and would not further impact natural and cultural sites on and around Lake Powell. 

   Adaptive Management and Management Objectives

   We support the proposed Adaptive Management Program (amp) and agree that the Adaptive Management Work Group should be set up as a Federal Advisory Committee chaired by a representative of the Secretary of Interior with membership from the Cooperating Agencies and members of the environmental, recreation, and power-user groups.

    The amp should be funded and implemented immediately. Several important issues remain and it provides the most appropriate forum in which to address them. One unresolved issue is agreement on the priority of management objectives and a clear set of substantive resource-based standards by which to measure the adequacy, as a legal and policy matter, of Glen Canyon Dam operations. Without these to provide guidance, Adaptive Management will be frustrating and ineffective.

   The Grand Canyon Protection Act requires, among other things, that the Secretary of the Interior operate Glen Canyon Dam to protect, mitigate adverse impacts to, and improve downstream natural and cultural resources. These broad goals can be achieved only if the Secretary defines with specificity the character and desired condition of those resources. In other words, the Secretary needs resource standards—something to manage dam operations for, a defineable goal. A set of guidelines or criteria should be developed, consistent with the environmental goals of the Grand Canyon Protection Act, the Endangered Species Act, the Clean Water Act, and others, and integrated, to the maximum extent possible, with the administration of those goals by the managing agencies. The Adaptive Management Program should use, whenever possible, the natural processes of the Colorado River to achieve specific objectives. The decision document should either set specific downstream resource standards or mandate a process by which those standards will be set. If the first course is selected, we recommend that the Secretary adopt standards such as, but not limited to, the following:

   Beaches, backwaters, and sediment transport: A positive sediment budget should be maintained on a rolling ten-year basis. Surface area and volume of beaches and backwaters shall be maintained at or above amounts observed on average over the last ten years, and shall be measured on a rolling ten-year average. Separate minimum criteria shall be established and maintained for each geomorphic river reach. Critical emphasis shall be placed on maintenance and improvement of beaches and backwaters in those areas of the river corridor that provide habitat for threatened or endangered native species.

   Threatened and Endangered Species: Native species and populations thereof shall be maintained at or above levels observed on average over the last ten years, and shall be measured on a rolling ten-year average.

   Water Quality: The quality of water released from Glen Canyon Dam shall comply with applicable standards established by the Administrator of the Environmental Protection Agency. The individual qualitative attributes of water released from Glen Canyon Dam (e.g., temperature, turbidity, nutrient load) will be maintained at levels no less favorable to the survival and recruitment of threatened or endangered native species than the levels observed on average over the past ten years.

   Cultural Resources: Cultural resource sites and values will be maintained in accord with the inter agency agreement executed by the Advisory Council on Historic Preservation, Arizona State Historic Preservation Officer, Reclamation, National Park Service, and Indian Tribes.

   If the secretary chooses not to identify specific resource standards and criteria as a part of the record of decision, he should instruct the Adaptive Management Working Group to develop and submit for the secretary’s review within 90 days of the groups’ designation the following items:

   • Quantifiable standards for evaluating the condition of downstream natural and cultural resources;

   • Procedures for reviewing and, if necessary, revising those standards on a periodic basis;

   • Procedures for integrating compliance with the natural and cultural resource standards with other Glen Canyon Dam operational criteria;

   • General administrative procedures and protocols for the working groups and panel, including dispute resolution procedures; and,

   • Procedures for responding to environmental or cultural resource emergencies.

   Thank you for entering our thoughts into the public record.

Tom Moody