Dear Mr. Kubly,

On behalf of Living Rivers and the Center for Biological Diversity, we submit the following comments on the February 08, 2008 Environmental Assessment of Experimental Releases from Glen Canyon Dam, Arizona 2008 through 2012. While we appreciate Reclamation's intentions to potentially aid in the redistribution of sediment, such that it might improve habitat conditions for endangered native fish, we find this action insufficient on its own to offer any lasting benefits toward fulfilling this objective.

1. Sediment Augmentation

Past experience has already illustrated the limited benefits such experimentation can achieve. The 1996 and 2004 high flow experiments have revealed that there is not enough sediment entering the river ecosystem below Glen Canyon Dam to make up for the 44 million tons that would otherwise be entering the system on an annual basis were the dam not in place. In 2005, during the Science Symposium by Grand Canyon Monitoring and Research Center (GCMRC), and again in 2006 during meetings of the Technical Working Group, scientists discussed or recommended that the Adaptive Management Program should consider bringing additional sediment into the system through a mechanical augmentation plan. The public also recommended augmentation during the scoping period for the Long-Term Experimental Plan Environmental Impact Statement. Absent such augmentation, this proposed action will offer no lasting benefits, either to endangered fish or recreational beaches. As noted in the 2005 Score Report by the United States Geological Survey, Grand Canyon is running a sediment deficit, and no amount of experimental flows can fix this problem. Reclamation must explore sediment augmentation as a viable alternative to meeting the objectives of this action.

2. Seasonally Adjusted Steady Flows

As has been stated repeatedly, Reclamation is in violation of the terms set forth in the 1994 Biological Opinion requiring that Seasonally Adjusted Steady Flows be implemented from Glen Canyon Dam for reasons of insufficient progress to remove jeopardy to threatened and endangered species, and during minimal releases of 8.23 million acre feet (maf). Only when such flows are integrated with sediment augmentation, as noted above, will there be any real opportunity for species recovery.

We find it particularly unfortunate that the 2007 Biological Assessment also chose to ignore Seasonally Adjusted Steady Flows (SASF). It’s unfortunate that such operating criteria may offer the best opportunity for meeting the objectives of the Grand Canyon Protection Act, but continues to be shunned by the hydropower interests.

3. Declining Reservoir Levels

This action is wholly contingent on there being sufficient water in Lake Powell, such that flood flows greater than 41,500 to 45,000 cfs (cubic feet per second) can be created. However, should the reservoir elevation drop below 3,490 feet msl (mean sea level), this will be impossible. The maximum flow that could be achieved would be less than 15,000 cfs through the bypass tubes alone. While current snow pack indicates that for at least the next two years, there should be sufficient water in Lake Powell to undertake such experiments, there is no guarantee that this will be the case through the completion of the proposed action period in 2012. Lake Powell’s present elevation is 3,595 feet, meaning reduced inflows during the experiment period to 2012 of a net -6.8 maf will be sufficient to force the shut down the penstocks, and this proposed action. As you are well aware, in the three years after 2000, Lake Powell's level dropped 11 maf, thus history illustrates that such reductions have occurred, yet the EA assumes, without any justification, that they will not.

While section 3.1.1.1 discusses climate change, it relies on the same limited analysis undertaken by Reclamation for Shortage Criteria—analysis which Reclamation states does not take into account climate change. More importantly, isolating the ISM single trace (index sequential hydrologic modeling) that begin with water years 1950 or 2000, would clearly show the potential for Lake Powell dropping to levels near or below the 3,490 msl threshold. While Reclamation may wish to argue the likelihood of such an occurrence, it cannot ignore the prospect altogether.

4. Water Quality

The continued avoidance by Reclamation to address the likelihood of reservoir levels dropping significantly below their current levels, represents a potentially ticking time bomb for Grand Canyon. The implications are far greater than whether or not GCMRC scientists find more grains of sand near the Little Colorado River six months following a high-flow experiment. The quality of water entering Grand Canyon could become so poor as to pose a serious threat to Grand Canyon’s entire river ecosystem.

As the EA points out in section 3.1.3.1, dissolved oxygen levels at the upper portion of the reservoir are far greater than that of the water that is typically released from the penstocks. Even now, the levels flowing into Grand Canyon are higher than prior to the experimentation of 1996. This situation only worsens the lower the surface of the reservoir becomes and with the decreased volume of water generally. This issue has never been addressed by Reclamation, nor a number of other potential water quality impacts to Grand Canyon including: extreme water temperature, increased nutrient concentrations, higher salinity, high hydrogen sulfide, heavy metals such as mercury and selenium, and the pass through of exotic reservoir animals. This EA must therefore evaluate the potential water quality impacts the Grand Canyon ecosystem might face from decreasing reservoir levels during the period of the proposed action. More importantly, Reclamation must immediately undertake a comprehensive assessment of the potential water quality impacts on Grand Canyon should the reservoir drop to dead pool.

5. Archeology

As noted in section 3.2, this action is likely to cause harm to a number of archeology sites, as well as to cultural vegetation. Such a problem would not occur were Reclamation to implement SASF as noted above in combination with sediment augmentation. Reclamation continues to make archeology a low priority, preferring to dig and relocate sites and artifacts than preserve them in situ as is their mandate.

Lastly, we remain frustrated by Reclamation’s ongoing policy of unnecessarily limiting public comment periods. This action has been contemplated by Reclamation since December of 2007, yet the Environmental Assessment is offered for public comment less than one month prior to the scheduled date of the proposed action. Additionally, a federal action of this magnitude deserves a proper Federal Register notice, which Reclamation has failed to do.

Whether it’s poor management on behalf of the AMP and the GCMRC, an intentional disregard for public participation, or both, Reclamation must correct this problem, beginning with extending the deadline for comments on this EA an additional 15 days.

As evidenced by the ramping up of publicity for the first experimental flow contemplated with this action on March 4, it appears Reclamation is more interested in mobilizing media interest in support of Reclamation’s own interpretation of this action, than it is on assuring the public has an opportunity to evaluate it for themselves and draw their own conclusions.

In conclusion, we view this EA as merely one more volume in the unfortunate history the Bureau of Reclamation and the Adaptive Management Program has visited on Grand Canyon. Until such time as Reclamation and the AMP makes a commitment to restoring the natural process that nurtured the evolution of Grand Canyon’s river ecosystem, no possibility exists for the ecosystem itself to be restored consistent with intent of the 1992 Grand Canyon Protection Act.

Sincerely,

John Weisheit, Conservation Director, Living Rivers
Michelle Harrington, Rivers Conservation Manager, Center for Biological Diversity

Additional Information:
Bureau of Reclamation EA Documents

Living Rivers scoping letter LTEP EIS

Living Rivers letter Shortage Criteria DEIS

Use the Colorado River Open Source Simulator (CROSS) to perform hydrological modeling yourself.

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Last Update: October 30, 2007