February 1, 2005
Mr. Joseph Alston, Superintendent
Grand Canyon National Park
P.O. Box 129
Grand Canyon, AZ 86023
Re: Draft Environmental Impact Statement for the Colorado River Management Plan at Grand Canyon National Park
Dear Mr. Alston,
Living Rivers and Colorado Riverkeeper submit the following as comments on Grand Canyon National Park's Draft Environmental Impact Statement (DEIS) for the Colorado River Management Plan.
On August 1, 2002, Living Rivers provided scoping comments for the DEIS process (see attached), which specified that it was paramount that the National Park Service (Park Service) not limit the DEIS scope to merely addressing human activity in the river corridor of Grand Canyon National Park (Grand Canyon). The ecological and cultural integrity of the river corridor is in serious decline, and its must not be ignored by any management plan pertaining to the river. Such an omission violates the spirit of, if not the letter of, the Organic Act, Endangered Species Act, National Historic Preservation Act and Grand Canyon Protection Act.
These earlier comments also stressed that the stewardship goals of the Park Service for this EIS include necessary criteria to restore critical river corridor habitat of the threatened and endangered species within the Park's jurisdiction, and that this responsibility be tiered with the stakeholders of the Adaptive Management Program, especially the Fish and Wildlife Service, the Bureau of Reclamation, and First Nations.
The DEIS, however, has ignored this responsibility. It considers the fate of the Grand Canyon's broad ecosystem problems to be subservient to the Park Service's views on the needs and expectations of human visitation within the river corridor. This approach wholly ignores resource protection, the Park Service's prime directive.
As a result, the deteriorating river ecology in Grand Canyon will be exacerbated should Preferred Alternative H (Alternative H), as presented in the DEIS, be implemented. This alternative should be abandoned, and the Park Service should refocus the plan on developing a management plan that will first satisfy the urgent needs of the ecosystem, then address how visitors should interact with it.
To achieve this, the Park Service should implement the following:
1. Properly Define the Problem
This public process has been a valuable opportunity for the Park Service to build support for the prudent management of the resource. Indeed, most participants have indicated a strong preference for a healthy Grand Canyon ecosystem. What is controversial is the role humans will play in the management of Grand Canyon, and this must not be limited to visitation but other impacts as well, especially Glen Canyon Dam. Alternative H is a marginal job addressing the former, and pays little attention to other impacts.
Alternative H attempts merely to placate the wishes of non-commercial and commercial boaters, while doing nothing to benefit the resource. Indeed, Alternative H is little more than a political compromise arising from the historical controversy regarding human access to the river, with no regard for the health of the river itself.
Alternative H will not unite human interests behind the critical management goal of placing the resource first. What is good for the river is good for its visitors, but not vice-versa. The Grand Canyon cannot adjust to the demands of people, but people can and must adjust to the demands of the Grand Canyon. This is especially true now as the Grand Canyon's native river ecosystem is nearing a state of total collapse, and it's the job of the Park Service to reverse this. It is the resource that the public comes to visit. It should not be devoid of the ecology, which belongs there, because the Park Service is too focused on whom, how and for how long humans can play on the river. The Park Service has the legal, scientific, and public responsibility to redirect its approach to correct this.
2. Wilderness Management as a Preferred Alternative
Considering that the Wilderness Act contains provisions to improve the ecological integrity of wilderness areas such as Grand Canyon, Alternative B provides a more logical choice from which to develop the management plan. But this too, will require some enhancement.
For example, beaches and sandbars have diminished significantly because of Glen Canyon Dam operations. These sand deposits are essential for the recovery of endangered native fish, for preserving Traditional Cultural Properties (in-situ), and for human recreation. Guidelines must be established regarding the level of impact these critical habitat components can sustain. Alternative H wholly ignores this and advocates increasing use contrary to published reports from the Grand Canyon Monitoring and Research Center (GCMRC), and others, that conclude the habitat is degraded. If the resource cannot be sustained under the present use, how can this use be increased?
When looking at the sandbar situation alone, visitor numbers must be reduced. Moreover, as the beach habitat continues to decline, so should the number of visitors present in the river corridor. Visitor numbers must be determined by the amount of available sand in the system as determined by GCMRC monitoring information.
Conversely, the Grand Canyon beaches can only sustain more use if more sediment is supplied. The experimental flows of 1996 failed to provide any lasting sediment augmentation, and there is yet no evidence to suggest that further experimental flows will improve the situation. The Park Service has done little to assert its role as guardian of this critical habitat component. At minimum, the management plan should be arguing ways to improve the sediment/beach situation. The management plan should argue for seasonally adjusted steady flows while opposing load following generator operations, which have proven to be more detrimental to maintaining a minimal sand balance.
Given the extensive new information since new Glen Canyon Dam operational guidelines were first established, mainly the continued decline of endangered fish populations and the conservation of sediment, this management plan should establish as a priority an aggressive advocacy position for the river corridor within its capacity as a member of the Glen Canyon Dam Adaptive Management Program. The CRMP should demand that the river corridor receive the necessary sediment, and other habitat modifications, to allow for the recovery of endangered fish as directed by science.
Recognizing the inherent constraints built into the Glen Canyon Dam Adaptive Management Program, the CRMP should also require the Park Service to engage the Secretary directly if recovery efforts continue to fail. Specifically, the Park Service should advocate for a supplemental EIS on the operations of Glen Canyon Dam, to explore the full range of alternatives available to achieve endangered fish recovery in the Grand Canyon, including decommissioning the dam.
Another means of increasing camping sites within the river corridor is to more aggressively pursue the eradication of exotic vegetation, which has encroached on camping areas. The management plan should explore programs to engage river runners in such activities. Special permits should be available for river runners who want to participate in such restoration efforts. With proper training, supervision and tools, the exotic plant problems could be managed in a matter of years, at a limited cost. When completed, the camping carrying capacity could be adjusted upward accordingly.
3. Concerns for Threatened and Endangered Native Fish
a. The Refuge at the Little Colorado River
Since Glen Canyon Dam became operational the sole remaining rearing habitat for endangered Humpback Chub has been the Little Colorado River (LCR). In addition to the Park Service’s recommendation to change human use regulations as described in the DEIS, swimming in the LCR should be eliminated until which time the recovery goals for the endangered fish of the Colorado River has been achieved. The only exceptions to this rule should be provided to the reasonable needs of the First Nations and the fishery biologists.
Living Rivers does not concur with the Park Service view that motorized trips have less impact on Humpback Chub than oar trips. A motorized boat should never approach the Little Colorado River for any purpose, including scientific research. Moving parts and accidents from petroleum products must be avoided at all costs, especially until such time as it is demonstrated that the Humpback Chub is in full recovery.
Additionally, a component of this management plan should include an action item to mitigate toxic spills that might occur in the drainage of the Little Colorado River in and above the Grand Canyon.
b. Consultation by US Fish and Wildlife Service
The consideration of endangered and threatened native fish in the Colorado River at Grand Canyon within the DEIS is not adequate and requires consultation with the US Fish and Wildlife Service.
4. Climate Change and Global Warming
The Park Service must evaluate the impacts, and the Colorado River corridor management actions to be taken, should reduced water releases from Glen Canyon Dam occur as a result of drought and climate change.
The Department of Energy and others have advised water managers to expect the volume of water produced by the Colorado’s watershed to be reduced significantly and progressively due to climate change. Their reports state that the Colorado River reservoir levels will be reduced by more than one-third and water releases by as much as 17 percent, which will result in reductions in hydropower generation by as much as 40 percent. Scientists have also warned that the Upper Basin may not meet its obligation to deliver its full requirement of water to the Lower Basin before 2010. Such changes in Grand Canyon will reduce fine sediment storage, concentrate rocks and boulders at rapids, degrade water quality and compromise fish recovery plans. They may also impact the types and number of boats the run the river, and the number of days it may take them to complete the trip.
5. Recreational Access to the River Corridor
The DEIS fails to solve the disparity of the access issue between commercial and non-commercial river runners. The DEIS largely favors access for concession contractors in the summer and non-commercial river runners in the winter. This suggests segregation and discrimination. Access should be equitable for all users and at all times. A common pool system, such as has been implemented at the Boundary Waters and the Deschutes River, is the access model that should be pursued by the Park Service in Grand Canyon.
Living Rivers recognizes the effort the Park Service has made in developing this DEIS. But it’s clear that despite all the hard work, the Park Service has ignored its stewardship 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 and the stakeholders in this process. The principle objective of the Final EIS must be the restoration and recovery of the natural processes and native species to Grand Canyon’s river corridor that are impacted by the activities of humans, and with a management plan that articulates how this can best be achieved.
Thank you again for the opportunity to submit these comments on the DEIS.
Living Rivers, conservation director
Scoping comments by Living Rivers, August 1, 2002.