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LR Letter
September 23, 2004

Comments: Living Rivers to EcoPlan Associates

Living Rivers
Colorado Riverkeeper
PO Box 466
Moab, UT 84532

September 23, 2004

Mr. Don Smith
EcoPlan Associates, Inc.
701 W. Southern Avenue
Suite 203
Mesa, AZ 85210


RE: Environmental Assessment (EA) for proposed water intake structures at Navajo Generation Station near Page, Arizona.

Dear Mr. Smith:

Thank you for allowing Living Rivers and Colorado Riverkeeper this opportunity to provide public comments for the proposed construction of water intake structures at Navajo Generation Station (NGS). This facility is administratively managed by Salt River Project (SRP). The facility adjoins lands administered by the National Park Service and the tribal government of the Navajo Nation.

Concerns for better due process

We are very dissatisfied in the minimalist approach concerning due process for this environmental assessment. We feel that the general public was not adequately informed about this EA and hope that public notification from the National Park Service and the Salt River Project will improve in the future, and will also include more accessibility to information. For example, this would include more contact information with the administrative agencies, and include resource information for public dissemination through the Worldwide Web and local public libraries.

We therefore ask formally that the process for gathering public comments be extended for 30 days and that measures are taken to better engage the public within this 30-day extension.

Concerns about SRP energy policy

The need and purpose for this proposed construction project is the result of climate change. Climate change has produced an unprecedented, but not unexpected, drought in the Colorado River basin. The average Colorado River flow has been reduced by 50 percent in the last six years. Climate change occurs naturally, but it is now accepted that humans do impact climate through the consumption of fossil fuels, which increases the temperature of the atmosphere and the surface of the oceans. NGS burns fossil fuel and thus contributes to the degradation of the world’s climate. The management of NGS must be aggressive and accountable in their policies concerning a positive transition from burning fossil fuels to providing alternative energy programs that will eliminate toxic pollution and greenhouse gases from the atmosphere.

This would also include eliminating impacts from fossil fuel consumption and how it affects local and regional residents as it relates to known health problems such as asthma and exposure to toxic heavy metals such as mercury.

We ask that SRP conduct public meetings and to specifically consult with all regional stakeholders with the purpose of developing a progressive policy for providing an alternative to fossil fuel consumption that will protect the atmosphere from further degradation and to improve human health.

Concerns about water rights

The contract for the water rights at NGS is to be renewed in 2009. It would be reasonable and prudent that SRP first secure their water rights before investing a significant amount of money to finance this proposed construction project.

Concerns about bore drilling

The diameter and quantity of the drilling bores appears excessive. Please explain why five bores must be drilled and why at 54 inches in diameter?

Impacts to Traditional Cultural Properties and critical wildlife habitat

It is not clear that new lands are to be developed for the pumping station, service roads or waste facilities for this proposed construction project. We ask that the specialists at the National Park Service and Navajo Nation be consulted and provide clearance for this project’s proposal as it relates to the cultural resources of the First Nations in the region of the Colorado Plateau.

We also ask that the US Fish and Wildlife Service be consulted concerning impacts to threatened and endangered species. This would include the potential mortality the intake structures would pose to endangered fish species.

Concerns for the geologic integrity of the host rock

There is considerable spalling of rock that is naturally occurring along the margins of the reservoir due to drought-diminished reservoir levels. We are assuming that the strength of the host rock of Lake Powell reservoir has weakened due to decades of water saturation from the reservoir. We would ask that if construction does proceed at NGS that the core samples from the drilling operations be analyzed by a professional consultant to determine how much structural integrity in the host rock has been lost. We believe this knowledge can be extrapolated for the structural integrity of man-made structures such as Glen Canyon Dam, and natural features that are federally protected, such as Rainbow Bridge.

Impacts from sediment storage in Lake Powell reservoir

The NGS facility is located downstream of Navajo Canyon, which is a large tributary drainage that erodes considerable amounts of soft Mesozoic shale and sandstone into Lake Powell reservoir. A sediment study should be conducted to determine when sediment from Navajo Canyon would impact the water intake structures at NGS.

This would also include the sediment accumulation due to natural turbidity flows along the inundated river channel of the Colorado River. This information on sediment fill should be shared with the National Park Service and with Bureau of Reclamation to provide to them better information in the management of their facilities. Especially as it relates to safety at Glen Canyon Dam.

Impacts to visitors at Glen Canyon National Recreation Area

The impacts to noise levels, the view shed and light pollution should also be addressed at the pumping station. Visitors and campers to Glen Canyon National Recreation Area would appreciate that such impacts be eliminated.

Thank you for this opportunity to provide comments and questions. Please do not hesitate to contact us should you require further assistance.

Sincerely yours,

John Weisheit Conservation Director

Cc: Ms. Barbara Wilson Environmental Specialist Glen Canyon National Recreation Area

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Living Rivers    PO Box 466     Moab, UT 84532     435.259.1063