Mr. Michael Gabaldon
Deputy Director of Operations
U.S. Bureau of Reclamation
Department of Interior
1849 'C' Street, NW
Washington, DC 20240
Via Fax: 202-513-0308
RE: AMWG Public Participation
Dear Mr. Gabaldon,
Yesterday, the Bureau of Reclamation (BuRec) announced public meetings and its comment period for the Draft Environmental Assessment (DEA) of the proposed experimental flows from Glen Canyon Dam. BuRec has unnecessarily compressed the calendar for this public comment period, and in the process, further reinforced the continued disregard the Adaptive Management Working Group (AMWG) has for appropriate public participation.
- The public has been given only 8/9 days notice for the upcoming public meetings (Flagstaff, AZ on October 2 and Phoenix, AZ on October 3). At minimum the public should be given 30 days notice of upcoming meetings.
- The public will not be able to obtain the DEA, for which the public meetings are about, until the first of the two meetings. The DEA should be available for at least two weeks in advance of the first public meeting.
- The public has only 18 days following the release of the DEA to submit comments. The public should have 30 days following the final public meeting to submit comments, or at minimum, 30 days following the public release of the DEA.
- BuRec has scheduled the public meetings on the exact same days BuRec will be holding similar meetings on the Draft Environmental Impact Statement for the reoperations of Navajo Dam on the San Jaun River, making it difficult for members of the public to attend both.
To address these concerns, we respectfully request that you:
- Add additional public meetings in Phoenix and Flagstaff with at least 30 days advance notice.
- Extend the public comment period to 30 days after the final public meeting.
- Require the AMWG to adopt and adhere to reasonable policies for ensuring adequate time for the public to participate in NEPA processes, such as commenting on the proposed experimental flows.
As the monsoon season in the watershed of the Paria River will have nearly passed, prior to any final decision being issued on this matter, there is no compelling reason not to extend the public participation process to accommodate a more reasonable schedule.
Furthermore, as was outlined in Living River's letter to you of January 18, 2002, the lack of attention to public participation by the AMWG is of major concern to us and the eight other organizations that signed the letter. You assured us that public comment was indeed a requirement of the AMWG process and that we would receive a timely response, yet none has been received.
As also mentioned in the January 18 letter, AMWG has a tremendous public responsibility for ensuring the future health and vitality of Grand Canyon's river ecosystem. As such, we appreciate the opportunity to participate in the upcoming meetings. We are concerned, however, that this ongoing disregard for making reasonable allowances for public input, and ignoring that input once received, continues to plague the effectiveness of the AMWG.
We look forward both to your response concerning this request to expand the public participation process for the experimental flows, and to our letter of January 18, 2002.
cc: Hon. Gale Norton, Secretary of the Interior Hon. John Keys, Commissioner, U.S. Bureau of Reclamation
Mr. Rick Gold, Director, Upper Colorado Region, U.S. Bureau of Reclamation
Mr. Robert Johnston, Director, Lower Colorado Region, U.S. Bureau of Reclamation
Mr. Joseph Alston, Superintendent, Grand Canyon National Park
Ms. Kitty Roberts, Superintendent, Glen Canyon National Recreation Area
Mr. Denny Fenn, Director, Grand Canyon Monitoring & Research Center