August 1, 2002
Joseph F. Alston, Superintendent Grand Canyon National Park P.O. Box 129 Grand Canyon, AZ 86023
Dear Superintendent Alston:
Living Rivers appreciates the opportunity to provide scoping comments for the Colorado River Management Plan (CRMP). This is a critical time in the ecological history of Grand Canyon’s river corridor. The corridor has experienced extensive changes over the past 40 years, largely as a result of operations at Glen Canyon Dam. Some of these changes are causing potentially irreversible damage to this world-renowned ecosystem. As the National Park Service is the agency with the sole responsibility to protect the river’s natural integrity for present and future generations, it is vital that the new CRMP outline strategies to reverse the damage that has been occurring and to restore the river’s native habitat, species and natural processes.
The current CRMP, completed in 1989, states as its first goal, "To preserve the natural resources and environmental processes of the Colorado River corridor and the associated riparian and river environment." The Park Service has clearly failed in its efforts to fulfill this goal. The natural resources in the river corridor are now much worse off than before CRMP was developed. The principle fish species the Park Service and other agencies have been working to protect, the humpback chub, has declined more than 75% to just 2000 adult fish. Nothing has been done to address the need to recover the four native fish that have become extinct in the canyon: razorback sucker, bonytail chub, roundtail chub and Colorado pikeminnow. The Park Service has also been negligent in ensuring that two other species, the flannemouth sucker and bluehead sucker, are not suffering the same fate.
This decline in native fish populations is just one indicator of the extensive ecological damage taking place in Grand Canyon’s river corridor which the Park Service is neglecting. The entire food base for the river ecosystem has been dramatically altered. A green alga (cladophora) has displaced the natural carbon food base. None of the river’s indigenous aquatic insects exist in the Canyon any longer. Otters and muskrats are now gone from the canyon and native riparian vegetation is disappearing from the high water zones or is stunted due to the lack of nutrients and the invasion of competing non-native plants. Most, if not all, of these changes are a direct result of the operations of Glen Canyon Dam. These changes include:
* Ninety-five percent of the sediment and nutrients that once flowed into Grand Canyon’s riverine ecosystem are now trapped behind Glen Canyon Dam causing the beaches to erode away and the native vegetation to disappear, disrupting the historic food base.
* Seasonal water temperatures that previously fluctuated from freezing to 80 degrees Fahrenheit, now range from 43 to 55 degrees, eliminating the warm water temperatures necessary to trigger native animal reproduction and fostering non-native fish species at the expense of native species.
* Natural flows which fluctuated seasonally from 3,000 to 90,000 cubic feet per second now fluctuate only from 8,000 to 20,000, cubic feet per second, creating a near static flow regime for an ecosystem that is adapted to and dependent upon the dynamic pre-dam flow.
These changes represent a significant violation of the National Park Service’s Organic Act (1916) which requires that the National Park Service preserve its lands unimpaired for the enjoyment of current and future generations. The lack of any substantive action of late also represents a violation of the intent of the 1992 Grand Canyon Protection Act.
The Organic Act and the establishment of Grand Canyon National Park pre-date the decision to construct Glen Canyon Dam. Whereas numerous alternatives exist to provide for the societal needs associated with Glen Canyon Dam, there are no alternatives to the unique ecosystem that is the river corridor through Grand Canyon National Park. Moreover, the Organic Act compels the Park Service to act even if impacts result from activities taking place outside its boundaries, as is the case with Glen Canyon Dam.
Grand Canyon National Park cannot abdicate to the Adaptive Management Work Group (AMWG) its responsibility for management decisions pertaining to the ecological integrity of the river corridor even when such decisions relate to Glen Canyon Dam outside park boundaries. It is the Park Service’s responsibility to uphold the Organic Act, not the responsibility of the Bureau of Reclamation, Western Area Power Administration or any of the other AMWG participants. Furthermore, the AMWG has not demonstrated an ability to provide any lasting benefits to the Grand Canyon ecosystem. As noted above, AMWG and the Park Service have failed in the principle mission to recover populations of humpback chub at the Little Colorado River. Populations in the Little Colorado River have declined 75% and no gains have been made in the establishment of a second population of humpback chub in the Colorado River mainstem. While the Park Service is fully within its rights to participate in the AMWG, the Park Service alone has the responsibility to ensure the future integrity of Grand Canyon’s native river ecosystem.
As guardians of this critical component of world heritage, it is vital that the Park Service through the CRMP address all aspects of river management, especially the impacts to the integrity of the Park’s native ecology caused by the operation of Glen Canyon Dam. Specifically, the CRMP must address mechanisms to:
* Restore essential sediment and nutrient flows from the mainstem Colorado River into Grand Canyon.
* Restore natural flow regimes to properly transport this sediment within Grand Canyon, when and where the sediment belongs.
* Restore natural seasonally variable water temperatures in the mainstem Colorado River through Grand Canyon.
* Develop a restoration and recovery program for the Colorado River corridor in Grand Canyon that includes the full recovery of all species known to be native to Grand Canyon prior to the operation of Glen Canyon Dam.
* Implement a non-native eradication program to minimize alien species in the Grand Canyon River corridor with a priority on those that prey on, compete with or otherwise impair the health of native plants and animals.
We recognize that there are a variety of issues which the Park Service may be asked to address within the CRMP. However, none can be more important than those which relate directly to the Park Service’s mandate as prescribed in the 1916 Organic Act. Without the natural ecological integrity of the river which carved it, Grand Canyon itself loses its integrity as does the Park Service. The principle objective of the new CRMP must be the restoration and recovery of the natural processes and native species to Grand Canyon’s river corridor.
Thank you for the opportunity to submit these scoping comments.
Owen Lammers Executive Director