Ms. Kitty Roberts
Superintendent
Glen Canyon National Recreation Area
National Park Service
PO Box 1507
Page, AZ 86040

Via Fax: 928-608-6212

RE: Antelope Point Marina Resort Development Project Environmental Assessment

Dear Ms. Roberts:

Living Rivers, on behalf of American Canoe Association, Bluewater Network, Center for Biological Diversity, Colorado Plateau River Guides, Diné Bidziil Coalition (representing 17 grassroots Navajo groups), Diné Medicinemens Association, Flagstaff Activist Network, Forest Conservation Council, Forest Guardians, Friends of Arizona's Rivers, Glen Canyon Institute, Grand Canyon Private Boaters Association, Great Salt Lake Audubon Society, Sierra Club, Utah Environmental Congress, Utah Rivers Council, and Utah Whitewater Club, submit the following comments on the italics Antelope Point Marina Resort Development Project Environmental Assessment dated March 20, 2002.

At the outset, we must stress our dissatisfaction with the public notification and comment periods established for review of this Environmental Assessment (EA), and project evaluation process as a whole. The publication was made available for distribution one week in advance of the public workshop and not received until four days prior to that scheduled public workshop. Similarly, short notification was granted for the scoping workshop. Less than 20 workdays has been available for public comment on this document. This is wholly inconsistent with the spirit of public participation as defined by the National Environmental Protection Act (NEPA) and the Council on Environmental Quality (CEQ) guidelines.

Summary

Significant procedural issues exist with respect to compliance with sound planning objectives and the requirements of NEPA that have not been adequately addressed in the EA.

Overall, we find the National Park Service (NPS) negligent in promoting the Antelope Point project at this time, as it should first update the Park's outdated General Management Plan (GMP), addressing current and future recreational and resource protection needs at Glen Canyon National Recreation Area (GCNRA). This document is out of date and out of step with declining trends in flat water recreation, concerns with regard to water quality, and the increasing role sediment accumulation is playing in reducing the reservoir's operating life span. The agency should also complete, prior to moving forward on Antelope Point, the Environmental Impact Statement (EIS) currently in preparation on personal watercraft (PWC) management at Glen Canyon. Approval of this project by the Park Service would mark a setback for the Park's efforts to protect water quality in the reservoir, ultimately a drinking water source for more than twenty million people downstream.

Living Rivers and seven other non-governmental organizations requested, in a letter (attached) to then Acting Superintendent Kathyrn Cook, and dated November 30, 2000, that an EIS be prepared for this project. Citing several examples of environmentally damaging actions, which would result from NPS approval of the marina and resort, we pointed out that an EIS would be required under the NEPA statute and its implementing regulations by the CEQ. We find the EA, as presently prepared, inadequate, addressing few of the issues raised in our previous letter on this matter. We again request that a full EIS be undertaken prior to any further contemplation of this project. Contrary to the EA's findings, the proposed alternative would cause significant environmental impacts and potential impacts, and these must be properly analyzed and evaluated in an EIS.

What follows are the procedural and substantive issues we have with the EA, as well as the Park Service's approach to evaluating the project:

1. Coordination with other park planning efforts
2. Protection of park resources
3. Purpose and need for the project
4. Alternatives analysis
5. Economic development and social impacts on Navajo people
6. Ethnographic resources & sacred sites impacts.
7. Cumulative impacts and reasonably foreseeable consequences
8. Site constraints and visitor safety issues
9. Water quality impacts
10. Air quality impacts
11. Recreation and noise impacts
12. Antelope Island management concerns
13. Endangered native Colorado River fish species
14. Environmental Impact Statement required
15. Public participation concerns

The GMP lacks substantive, relevant data and analysis of the purpose, and need for a marina at Antelope Point. Because the GMP lacks important, basic information that would inform current planning efforts for Antelope Point, the NPS must address these missing elements in detail within the Antelope Point NEPA process. The situation with personal watercraft is an excellent example.

The proliferation of such machinery was never contemplated in the 1979 plan and now a full EIS is being undertaken to determine how, and if, PWCs should continue to operate on the reservoir. Waiting until this EIS is complete, before moving forward on Antelope Point, would provide an opportunity to incorporate the findings of the PWC study in to the Antelope Point alternatives analysis. One alternative NPS is reportedly considering, in the PWC EIS, is to restrict jet skis from designated areas of the reservoir-to provide "jet ski-free" quiet zones. The narrow, old river channel at Antelope Point, on the south side of Antelope Island, would be an ideal area for such restricted uses. In its alternatives analysis, NPS should consider the value of the Antelope Point area to non-motorized recreation use.

2) Protection of park resources

The laws, regulations and policies that govern management of national parklands, including GCNRA, require the NPS to make protection of park resources a top priority. The Organic Act of 1916 and the Redwood Park Amendments Act of 1978, in particular, require NPS to manage park resources to a "non-impairment" or "non-derogation" standard. Contrary to the EA's conclusions, a major development project, such as the Antelope Point marina, risks degrading water quality and air quality, significantly increasing noise and visitor crowding, and decreasing opportunities for solitude and low-impact, non-motorized recreation. The need to provide such areas was not fully contemplated when the GMP was developed, but is a critical factor that must now be addressed prior to potentially exacerbating these problems by approving the Antelope Point Marina Resort Development project.

NPS has no legal justification or authority to favor motorized recreation over non-motorized. Given the growing impairment of park resources caused by motorboats, the burden is on NPS to explain how each recreational alternative considered in the broader sense, Antelope Point, Hite Marina expansion and etc., complies with the non-impairment standard. This should be a key component of the revised GMP and which must be addressed prior to any decision on Antelope Point.

Furthermore, as noted in our scoping comments dated January 14, 2002 (attached) related to Hite Marina DCP/EA, GCNRA planners are demonstrating a bias toward further development of park resources for motorized flat water recreation, while ignoring its obligation to maintain access for other users, such as river rafters.

3) Purpose and need for the project

As stated above, the purpose and need for new development in national parks should be justified by, and tiered to, the Park's GMP. However, the Park's outdated GMP lacks important information. The Antelope Point EA is addressing a perceived need that is nearly 25 years old. Demand for any new marina development at GCNRA, in close proximity to the existing Wahweap Marina in particular, must be well documented. NPS must show: why existing facilities at Wahweap cannot meet that demand; why a new facility is needed so close to Wahweap Marina when so many public services and facilities would have to be duplicated and; why constructing a new facility would be preferable to expanding existing facilities, especially at a time when visitation is on the decline. As regards to addressing Navajo Nation economic development needs, there are a variety of other, more environmentally and economically sustainable means for GCNRA to accommodate this, as outlined in our letter of November 30, 2000 and noted below.

4) Alternatives analysis

Because of the outdated GMP, the Antelope Point EA failed to analyze possible alternative uses for the site (other than the marina). Given water quality concerns, demand for quiet areas, potential changes in watercraft usage and any demonstrated need for the proliferation of more marina facilities at this time, it is imprudent to restrict such a unique area as Antelope Point to the findings of an outdated GMP. An updated GMP may reveal that management alternatives for serving marina demand through (expanded) existing facilities is not only feasible, but desirable, and that alternative uses for the Antelope Point site other than a resort marina development would be a better fit for present and future trends.

The Diné Medicinemens Association, Inc. (DMAI) has proposed that NPS study the possibility of establishing a traditional healing center for Navajo people and others, rather than a marina, on the Antelope Point project site. NPS must consider this proposal in detail. The DMAI represents the interests of traditional religious healers and cultural practitioners, whose interests must also be protected and respected under Executive Order 13007, Indian Sacred Sites (May 24, 1996). The DMAI, and other Navajo groups, could contribute significantly to a new GMP, whereas such voices were absent 23 years ago. This would seem particularly important in the case of Antelope Point. The alternatives some Navajo interests have proposed were never contemplated by the 1979 GMP, and not inconsistent with NRA goals. Such uses might include traditional healing centers, retreat/conference center and educational facilities for both local Navajo, and tourists alike.

In addressing NPS' interest in aiding the Navajo Nation, the Park Service should not restrict its evaluation to Antelope Point. NPS should consider the possibility of the tribal government taking over management and operation of existing GCNRA marinas including Wahweap. This would meet the economic development criteria without additional environmental impacts.

5) Economic development and social impacts on Navajo people

The proposed marina is being promoted in part as a means of providing economic development opportunities for members of the Navajo Nation, and of the nearby LeChee Chapter in particular. While no one would dispute the need for additional opportunities for tribal members, the EA has not demonstrated how the Navajo Nation's desires for a revenue stream from a project that would negatively impact the Park's shoreline and waters, against NPS' legal duty to protect park resources from impairment. Navajo Nation economic development goals may not always be consistent with park management objectives. If NPS determines that the purpose and need for the project include providing economic development opportunities for the Navajo people, then NPS must demonstrate that legal authority exists for the agency to undertake development projects or other management activities on that basis. NPS must also explain how such projects are consistent with the agency's legal mandates to ensure non-impairment of park resources.

6) Ethnographic resources & sacred sites impacts

The EA asserts that only two ceremonial sites have been identified, and that both do not qualify for National Register of Historical Places, as they were not used prior the inundation of Glen Canyon. Further, the EA states "Despite this determination, an attempt was made to accommodate the needs of the Diné Medicineman's [sic] Association, Inc. and further consultation identified an acceptable alternative to the original ceremonial location."

The Diné Medicinemens Association, Inc. has identified numerous ceremonial and sacred sites in and around the project area. The Association's president, Mr. Thomas Morris, is unaware of any contact with Antelope Point planning officials regarding the applicability of these or any other sites to the National Register of Historic Places, nor discussions regarding "suitable" alternatives.

NPS must consult with all appropriate traditional practitioners, including the DMAI to address these issues. NPS must explain how it intends to comply with Executive Order 13007, Indian Sacred Sites (May 24, 1996), that requires agencies including NPS to "... accommodate access to and ceremonial use of Indian sacred sites by Indian religious practitioners and ... avoid adversely affecting the physical integrity of such sacred sites." By dramatically increasing visitation to the area, it will become very difficult for NPS to accomplish the objectives of the Executive Order. NPS must avoid damaging any such sites and provide a range of alternatives for ensuring the sites' protection under a range of alternative development scenarios for the project. NPS should publish a full accounting of the consultation efforts and mitigation plans for the archeological, cultural and sacred sites.

Furthermore, it is the position of the DMAI that the Antelope Point Marina Resort Development not be built, but that a traditional healing center be established at that location should NPS be interested in assisting with sustainable economic development on the Navajo reservation.

7) Cumulative impacts and reasonably foreseeable consequences

NEPA requires analysis of reasonably foreseeable consequences of projects and the cumulative effects of specific impacts over time. Development of a new marina would likely lead to additional construction of tourist-oriented business and industry in the vicinity of Antelope Point. For example, the act of providing utility services to Antelope Point-an area that is currently not served by utilities-will create opportunities for additional development and land use changes outside the project boundary, changes that would be very unlikely to occur without the project. The Navajo Nation and LeChee Chapter are reportedly studying the feasibility of building a casino and shopping center along the Antelope Point access road. Such construction, if undertaken, would likely be feasible only if the marina were built.

The EA has not addressed these cumulative impacts, despite noting that the proposed project will increase the area's employment by upwards of eight percent. The EA has not identified the land-use control and regulatory mechanisms that may exist, if any, to limit sprawling strip development in the vicinity of Antelope Point. By approving this project, NPS would be effectively facilitating the development of many additional acres of land on the approach to Antelope Point. NPS must investigate and evaluate these reasonably foreseeable consequences of the Antelope Point project. Issues such as water supplies, power supplies and sewage disposal (that NPS must study for the marina proper) must also be considered in light of likely adjacent development. Basic services such as police and fire protection must have facilities appropriate to the anticipated need over time. NPS must address these infrastructure questions in a quantitative way.

8) Site constraints and visitor safety issues

The EA gave no consideration to the unique geography associated with Antelope Point, as it may affect public safety. Antelope Point is located on the south shoreline of a narrow bend in the old river channel, with the undeveloped Antelope Island on the opposite shore. There is limited space for large watercraft such as tour boats to maneuver in the narrow channel, especially in the presence of other boats. Site constraints make the area prone to potential user conflicts. Because Antelope Point is on a sweeping bend in the channel, line of sight and visibility are reduced. During heavy use periods, any combination of large tour boats, powerboats, houseboats, high-performance "cigarette" boats and jet skis could be in the immediate vicinity, negotiating the narrow, bending channel, on the way to or from the marina. Swimmers, wake-boarders and water-skiers may be in the water. Anglers may stand on the shoreline or fish from boats. Antelope Island's shoreline provides camping and picnicking opportunities, and boats are often tied along the shore. With the establishment of a marina, it is likely that such use will only increase. The potential for serious visitor safety conflicts and boating accidents at Antelope Point appears to be great. The ready availability of alcoholic beverages for sale from the nearby marina would only exacerbate the risk of serious accidents. Vessel fires, a fairly common occurrence at GCNRA, can significantly increase risk of injury to bystanders and boaters, especially in a constricted channel environment with heavy traffic.

NPS must assess the expected near-term and long-term (cumulative) impacts on visitor safety and public health, resulting from funneling a large number of disparately-sized motor vessels into a narrow channel that is frequently used by families and children for water contact sports.

9) Water quality impacts

The reservoir at GCNRA is an artificial feature that is part of the Colorado River, which is in turn a primary source of drinking water for millions of people downstream in Arizona, California, Nevada and Mexico. In addition to its obligation to protect park resources, including water bodies from non-impairment, NPS has an obligation to ensure the protection of water quality at GCNRA for downstream users. This issue was not given sufficient consideration in the EA.

NPS must consider the cumulative downstream impacts resulting from polluted runoff from streets, parking lots and lawn areas entering the reservoir and which may percolate directly into groundwater. Contamination of groundwater supplies at Antelope Point could be potentially disastrous, since NPS is considering onsite wells as the sole source of the marina's water supply system. Combined, the potential for local and downstream impacts associated with water quality warrant a much more comprehensive examination than offered in the EA.

The US Environmental Protection Agency (EPA) has estimated that roughly 25 percent, on average, of the fuel mixture that drives two-cycle motors is emitted through the vehicle's exhaust system, unburned. Two-cycle motors are commonly used at GCNRA in powerboats as well as in PWCs. NPS should be concerned about petroleum pollution from all powerboats, but especially that from PWCs, where the oily exhaust is essentially injected (mixed) directly into a stream of water (the "jet"), and thence into the reservoir. While open-water areas may offer some advantage in terms of diluting petroleum pollution, the narrow channel at Antelope Point and the anticipated high traffic volume may lead to significant accumulations of petroleum on or in the water, which may be less likely to disperse than more open areas. If such impacts are sufficient to warrant an EIS on PWCs, then certainly a similar level of analysis should be conducted for a major marina development as proposed for Antelope Point.

10) Air quality impacts

The Antelope Point project area is in close proximity to Navajo Generating Station (NGS), one of the largest sources of carbon dioxide and oxides of nitrogen in the Southwest. Data published by the Public Interest Research Group in 2000 indicate that more than 700 pounds of mercury were emitted from NGS in one year. The EA did not sufficiently address the long-term human health impacts of prolonged exposure to NGS power plant emissions on visitors and marina employees; especially those who work a significant portion of their time outdoors, where they would be considered to be at higher risk from long-term exposure.

11) Recreation and noise impacts

The EA discounts the noise impacts as they relate to the objective of a marina resort operation, but as noted earlier, a revised GMP reflecting contemporary issues would generate a greater range of alternatives to be investigated in and around Antelope Point. In particular, GCNRA currently provides no designated "quiet zones" on or near the water for non-motorized recreation activities (e.g., "sea" kayaking, canoeing, swimming or camping). There are virtually no places on the reservoir with more than 1900 miles of shoreline where families and others may enjoy water sports and other recreation activities free from the sights, sounds, and intrusions of houseboats, powerboats, high-performance "cigarette" boats and jet skis. Despite the growing popularity of non-motorized recreation, a legislative mandate to provide for a broad spectrum of recreation opportunities and the generally benign environmental impact of non-motorized recreation activities, NPS has mostly ignored the interests and needs of those who prefer human-powered water sports at GCNRA.

In the case of Antelope Point, the narrow, bending river channel offers ideal conditions for such low-impact, non-motorized recreation. There are few places on the reservoir's shoreline with easy auto access that could easily accommodate these recreational activities with few conflicts with motorboat users. Antelope Point's new launch ramp and close proximity to the town of Page make it perhaps the best choice for a facility that would cater to non-motorized users. Antelope Island, on the opposite side of the channel from the launch ramp at Antelope Point, provides readily accessible camping and shoreline hiking opportunities, while the island's hilly landform offers effective screening from the noise of motorized watercraft traffic traveling uplake around the north side of the island. But just as a "quiet zone" in the Antelope Point channel reach would be protected by the topographic screening afforded by the island, the channel would likely be subjected to near-constant noise levels if Antelope Point marina were built. The island's topography would tend to reflect noise back to the water and the south shore, virtually guaranteeing that the passing motorboats and tour boats would make camping and non-motorized water sports unpleasant at the very least.

Through a revision of the GMP, NPS should identify and characterize the range of alternatives available within the NRA to provide accessible and adequate quiet zones, such as may be available around Antelope Point. Additionally, noise is a major issue being addressed by the PWC EIS. Noise should receive no less consideration for a major marina development, yet here again NPS has relegated the issue and the entire analysis to EA status.

12) Antelope Island management concerns

In the GMP for GCNRA, Antelope Island is zoned for "wilderness," i.e., non-motorized use. NPS has not analyzed expected impacts that the Antelope Point marina would have on naturalness, wildlife, and primitive camping at Antelope Island. NPS must explain the management rationale that justifies placing a marina in such close proximity to an area that is to be managed in an undeveloped state. NPS must also describe how it intends to ensure that Antelope Island will remain a low-impact, protected environment in light of the heavy boat traffic that will bring additional noise, air and water quality degradation, and people to the area, especially during heavy use periods.

13) Endangered native Colorado River fish species

NPS has an obligation to support recovery of endangered species that are native to the parklands under NPS jurisdiction. In the context of an updated GMP, NPS could consider utilizing the Antelope Point channel zone as a protected rearing area for some or all of the four listed, Colorado River native endangered fish (bonytail chub, Colorado pikeminnow, humpback chub and razorback sucker). Few endangered fish are known to currently inhabit Lake Powell reservoir. The only referenced in the EA was the razorback sucker. These native fish have had their habitat dramatically altered and invaded by striped bass, carp, and other introduced game fish species. While GCNRA has done little to reintroduce listed endangered fish into the reservoir, there are indications that under protected conditions, a limited number of individuals could survive. The razorback sucker in particular survives in low numbers in several lower basin reservoirs, mainly in response to ongoing U.S. Fish & Wildlife Service (USFWS) hatchery rearing efforts. A major challenge in ensuring these fish reach reproducing age is predation by and competition with introduced non-native fish including trout, catfish, bass and carp. In at least one Colorado River reservoir, a screen or curtain has been put in place to separate the endangered native fish from the game fish, and initial reports indicate that the system is working.

NPS should investigate, in collaboration with USFWS, the possibility of creating a similar type of curtain that could be employed at GCNRA (perhaps in a number of locations) to create protected rearing zones for endangered native fish. NPS should give serious consideration to experimenting with the Antelope Point channel area for this purpose. The narrow, deep channel could afford a unique opportunity for providing at relatively low cost a controlled, easily monitored, predator-free environment. A curtain or screen dropped across the channel on both ends of Antelope Island would provide a very deep area in the old, river channel, as well as extensive, shallower habitat in the Antelope Creek bay.

Pursuing a more detailed study of the potential benefits of such an experiment would require consultation with fish biologists and with the two USFWS-sponsored endangered fish recovery implementation programs in the Upper Colorado River and San Juan River watersheds. NPS should give this consideration in conjunction with future management plans and not unnecessarily compromise potentially suitable habitat like Antelope Point prior to completion of such an evaluation.

14) Environmental Impact Statement required

Given the extensive and controversial nature of the project impacts expressed herein, NPS is required by CEQ guidelines to abandon the EA process and conduct an EIS on the Antelope Point Marina Resort Development Project. There is clear, current precedent for doing so. As noted above, GCNRA is currently preparing an EIS for PWC management. It is difficult to imagine a rationale that would justify an EIS for jet skis while preparing only an EA for a large marina complex. A decision by NPS to move forward with an EA and a Finding of No Significant Impact, without preparing an EIS for this complex project would appear to be an arbitrary and capricious act by the agency.

15) Public participation concerns

Public involvement in planning by federal agencies is a key element of the NEPA process. NPS should endeavor to improve its outreach and public involvement efforts related to the Antelope Point project. In particular, NPS should conduct public hearings on the project in diverse communities throughout the region. NPS must avoid the appearance that it is interested in receiving input from only a narrow demographic audience. The NEPA process requires federal agencies to promote public involvement in project planning. We were therefore profoundly disappointed to learn that, despite our requests for multiple scoping meetings, NPS chose to hold only one such public meeting for Antelope Point and now only one public workshop on the EA, both in Page, AZ. In both instances there was less than two weeks advance notice, which does not typify the sort of public participation effort envisioned by NEPA.

In contrast to what appears to be NPS' intent to restrict the audience for its Antelope Point project, NPS recently held scoping meetings for the PWC EIS in the Salt Lake City and Phoenix metropolitan areas, as well as in Page. There is a growing perception and concern that NPS may be using scoping meetings in an arbitrary and capricious manner. At the very least, there is an apparent lack of consistency in the agency's selection of communities for public involvement activities. NPS should hold future public meetings on Antelope Point in the following locations at least, to ensure a well-informed public: Page AZ, Salt Lake City UT, Phoenix AZ and Flagstaff AZ. Consideration should be given to also conducting meetings in Gallup NM, Moab UT, Durango CO and Las Vegas NV, to ensure broad geographic coverage.

Finally, the quantity and quality of materials and information about the project provided by NPS to attendees to the scoping meeting, through the EA process and the EA itself has been disappointing. There has been precious little useful information in the materials to explain the controversial nature of the environmental, social and economic impacts of this project. Part of the public involvement process is informing the public well in advance of the issues that have been raised, to encourage additional public response and understanding. NPS should dramatically improve the information provided the public in future communications, on the Internet, via the US Mail, and especially in public meetings.

Thank you for your consideration of our concerns, and we look forward to your reply.

Sincerely,

Owen Lammers
Executive Director

On behlaf of:

American Canoe Association
Bluewater Network
Center for Biological Diversity
Colorado Plateau River Guides
Diné Bidziil Coalition (representing 17 grassroots Navajo groups)
Diné Medicinemens Association
Flagstaff Activist Network
Forest Conservation Council
Forest Guardians
Friends of Arizona's Rivers
Glen Canyon Institute
Grand Canyon Private Boaters Association
Great Salt Lake Audubon Society
Sierra Club
Utah Environmental Congress
Utah Rivers Council
Utah Whitewater Club

cc: Edward S. Richards, Navajo Nation Division of Economic Development

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Last Update: October 30, 2007