GLEN CANYON
ENVIRONMENTAL STUDIES

EXECUTIVE REVIEW COMMITTEE
FINAL REPORT
MAY 1988

UNITED STATES DEPARTMENT OF THE INTERIOR
WESTERN AREA POWER ADMINISTRATION
FISH AND WILDLIFE SERVICE
NATIONAL PARK SERVICE
BUREAU OF RECLAMATION

a

•

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GLEN CANYON ENVIRONMENTAL STUDIES:
EXECUTIVE REVIEW COMMITTEE FINAL REPORT

Submitted to the Department of the Interior

MAY 1988

This report was prepared by individuals representing the following:
United States Department of the Interior
Fish and Wildlife Service
National Park Service
Bureau of Reclamation
Western Area Power Administration

TABLE OF CONTENTS

Page
I. INTRODUCTION
A. The Glen Canyon Environmental Studies
B. The Purpose and Composition of the Executive Review Committee
C. Why Further Action is Being Considered
II. EXECUTIVE REVIEW COMMITTEE DECISION MAKING PROCESS
A.
B.
C.
D.
E.

Review of the Technical Reports by Constituent Groups
Definition of Individual Bureau and Agency Objectives
Identification of Separate Findings
Development of Specific Recommendations
Development of Executive Review Committee Recommendations

III. EXECUTIVE REVIEW COMMITTEE RECOMMENDATIONS
A.
B.
C.
D.

Recommendations for Future Studies
Interim Operating Recommendations
Interim Coordination and Management
National Environmental Policy Act Compliance

Appendices: A - Individual Position Statements
B - Individual Recommendations
C - Individual Findings
D - Individual Management Objectives and Priorities
E - Constituent Group Comments
Part I:
Bureau of Reclamation Constituency
Part II:
Fish & Wildlife Service Constituency
Part III: National Park Service Constituency
Part IV: Western Area Power Administration Constituency

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GLEN CANYON ENVIRONMENTAL STUDIES:
EXECUTIVE REVIEW COMMITTEE FINAL REPORT

I. INTRODUCTION
A. The Glen Canyon Environmental Studies
This report contains recommendations of the Executive Review Committee (ERC) (a
management and policy level group representing the Bureau of Reclamation (BOR),
National Park Service (NPS), Fish & Wildlife Service (FWS), the Department of the
Interior (USDI), and the Western Area Power Administration (Western)) to the Department of the Interior regarding future actions to be taken based on the results of the
Glen Canyon Environmental Studies.
This document was developed over a 12 month period and represents those areas where
agreement could be reached and those areas where diverse opinion and management
objectives dictate disagreement. The information presented in this report outlines the
major areas of concern and the categories of recommendations that are necessary for
evaluation of future actions. The primary areas of concurrence and nonconcurrence are
presented in this initial section. Specific BOR, NPS, FWS, and Western concerns,
recommendations, and positions are presented in Appendices A and B.
The Glen Canyon Environmental Studies (GCES) were initiated by the Department of the
Interior on December 8, 1982, following considerable public controversy which resulted
from the proposed peaking power plan and from the Environmental Assessment developed
for the uprating and rewinding of the generators at Glen Canyon Dam. An analysis of
the public comments received during that period suggests that the controversy was less
about the uprating and rewinding than it was an expression of concern about the longand short-term environmental and recreational impacts associated with the operations of
Glen Canyon Dam.
The GCES program is a series of environmental and technical studies designed to clarify
whether the operations of Glen Canyon Dam do indeed impact the downstream natural
and recreational resources of the Glen Canyon National Recreation Area and Grand
Canyon National Park. A second objective of the GCES program was to determine
whether, within existing legal and operational mandates that define the management and
operation of Glen Canyon Dam, alternative operations could be identified that would
minimize the defined impacts.
The technical results of the GCES program are contained in the Glen Canyon Environmental Studies Final Report, which accompanies this document. The results in the GCES
Final Report are drawn from a series of technical reports which are available through
The GCES
the GCES project office and the National Technical Information Service.
Final Report is not a National Environmental Policy (NEPA) document, but a technical
information document. The report does not address the potential economic benefits or
costs associated with changes in operations nor does it include a full public review.
The technical adequacy of the individual research reports was reviewed by a wide range
of academic and management staff. The individual reports and the GCES Final Report
1

were also reviewed by the National Academy of Sciences, Glen Canyon Environmental
Studies Review Committee.
B. The Purpose and Composition of the Executive Review Committee
In 1987, as the technical studies were being concluded and the summary reports were
being prepared, it became clear that while the technical studies resolved some issues,
there were still many basic management and policy decisions that could not be resolved
by the technical studies. Given the different mandates of the affected Federal and State
agencies, it was clear that no one office could make management and policy decisions
which would be acceptable to all. The GCES Executive Review Committee (ERC) was
established to take the technical study results and findings of the GCES program and
translate them into a series of policy options upon which the Department of the Interior
could act.
The ERC has as its objective:
To review the GCES Final Report and determine if impacts of the
operations of Glen Canyon Dam to the Glen and Grand Canyon
environments are significant and whether changes in the operation
of Glen Canyon Dam can be supported.
The ERC was charged by the Regional Director of the Upper Colorado Region of the
Bureau of Reclamation with the completion of four products:
1. Definition of the management objectives of each of the Department of the
Interior bureaus and Western in the management of the Colorado River through
Glen and Grand Canyons.
2. Development of a matrix of management areas of concurrence and nonconcurrence.
3. Determination of the need for additional monitoring and/or study.
4. Development of a report to the Department of the Interior with recommendations for Secretarial consideration.
The composition of the ERC includes those bureaus within the Department of the
Interior (DOI) which have water and power management responsibilities for the Colorado
River; those which manage the natural and recreational resources of the Colorado River,
Glen Canyon National Recreation Area, and Grand Canyon National Park; and the agency
within the Department of Energy (DOE) that has an institutional focus on the power
resources. The ERC is composed of representatives from:
Bureau of Reclamation (Upper Colorado Region)
National Park Service (Western Region)
Fish and Wildlife Service (Region 2)
Department of the Interior (Office of Environmental Project Review)
Western Area Power Administration (Salt Lake City Area Office)

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In addition to participating in the policy discussions of the ERC, each representative
also accepted responsibility for communicating with the other agencies, public groups,
and private individuals concerned with the specific missions and management objectives
of the individual bureaus within the DOT and Western.
C. Why Further Action Is Being Considered
The Department of the Interior directive letter initiating the GCES states that, "Should
alternatives that meet the above criteria be identified (i.e., that it has been demonstrated that the operations of Glen Canyon Dam do have an impact on downstream
resources, and that the dam can be operated in ways that could reduce those impacts),
an environmental assessment should be prepared. This would lead to a decision process
to determine appropriate long-term operating criteria for Glen Canyon Powerplant."
The bureaus/agency represented on the ERC concur that the GCES have shown that the
operations of Glen Canyon Dam do affect the natural and recreational resources
downstream from the dam, and that some ways of operating the dam have more negative
impact than others.
The GCES also identified operational options, within existing legal and operational
mandates, that could reduce impacts as related to selected resources.
There is not unanimous agreement that the negative impacts are sufficient to justify a
decision to adopt these changes at this time. There is agreement that further studies
need to be undertaken to assess the significance of these impacts.
This report contains recommendations of the ERC for additional studies, interim flow
levels for study purposes, and mechanisms for coordination and decision-making among
the affected bureaus and Western during the period of the studies. The result of the
studies would be a decision regarding more significant recommendations for changes in
operations. This report defines alternative courses of action which DOT may choose to
take, and provides information about the position of each office regarding the alternative
courses of action.
II. EXECUTIVE REVIEW COMMITTEE DECISION MAKING PROCESS
The ERC pursued the following processes in arriving at its recommendations:
A. Review of Technical Reports by Constituent Groups
Recognizing the political sensitivity of the GCES issues, each member of the ERC
accepted the responsibility to meet with those groups and interests (constituents) most
concerned with the mandates of management. Responsibility was assumed as follows:

Bureau of Reclamation: Upper Colorado River Commission
Upper Colorado River Basin States
Lower Colorado River Basin States

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National Park Service:

Environmental Groups
Conservation Organizations
River Concessionaires

Fish & Wildlife Service: Arizona Game & Fish Department
Conservation Groups
Fishing Organizations
Department of the Interior:

Additional Conservation Groups
Indian Tribes

Western Area Power Administration: Electric Power Organizations
Each constituent group identified by the ERC was provided a briefing on the major
findings of the GCES Technical Reports and GCES Final Report and was encouraged to
ask questions or request clarifications. Initially, four meetings were scheduled for the
constituent groups. They were:
Western
FWS
BOR
NPS

October 20, 1987
October 20, 1987
October 22, 1987
October 28, 1987

Salt Lake City, UT
Phoenix, AZ
Denver, CO
Flagstaff, AZ

It also became clear that constituents in the lower basin states were interested in the
studies, so an additional BOR constituent meeting was held for the Lower Colorado
River Basin States on December 9, 1987 in Las Vegas, NV. A summary of the written
comments from the constituent groups is shown in Appendix E.
B. Definition of Individual Bureau and Agency Objectives
Each member of the ERC developed a statement of objectives reflecting its specific
management responsibilities along the Colorado River, or in the Glen Canyon National
Recreation Area or Grand Canyon National Park. A full statement of these objectives
is shown in Appendix D and summarized in Figure I.
As can be seen in Figure 1, some element of conflict is inherent between the missions of
the entities. Western is essentially a single purpose agency, with operations and power
marketing as its primary focus. In this geographic area, the missions of the NPS and
FWS overlap, although the NPS has a recreational mission not shared by FWS.
However, there is competition even within environmental missions.
For example,
operations which are beneficial for the humpback chub and other native fish species are
not beneficial for trout fisheries and vice versa. The mission of BOR overlaps with all
other bureaus, although the BOR qualified its mission responsibilities as being contingent
upon its primary mission.

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Figure 1
SUMMARY OF AGENCY OBJECTIVES
.

OBJECTIVES

EXECUTIVE REVIEW COMMITTEE
BOR NPS FWS
WESTERN

Store water for beneficial use.
Provide flood control.
Operate dams to generate
hydroelectric power.
Market hydroelectric power.
Comply with Endangered Species
Act.
Protect humpback chub.
Maintain alluvial deposits.
Perpetuate and enhance
white-water boating.
Protect other native fish species.
Perpetuate recreational trout
fishery.
Maintain and enhance habitat
for fish and wildlife.

X Primary missions.
0 To the extent possible, consistent with primary missions.

C. Identification of Separate Findings
Each member of the ERC reviewed the GCES Final Report and the comments received
from the constituent groups and identified specific findings from his/her perspective.
These findings are listed in Appendix C.
None of the ERC members contest the basic findings that the operation of Glen Canyon
Dam has an impact on the downstream resources and could be changed in ways which
provide greater protection for the resources. However, these changes would impact on
other missions and management responsibilities. Therefore, the discussion now centers
around (1) whether or not the impacts are sufficiently significant to justify changes in
operations, and (2) whether or not the studies were sufficiently complete so that it is
possible to accurately determine the significance of impacts.
D. Development of Specific Recommendations
As a first step in developing group recommendations, each member of the ERC developed
recommendations specific to his/her bureau or agency. These recommendations are
shown in Appendix B.
E. Development of Executive Review Committee Recommendations
Finally, the ERC developed group recommendations, based on extensive discussion and
negotiation. These recommendations are described in the following section.
III. EXECUTIVE REVIEW COMMITTEE RECOMMENDATIONS
The recommendations of the ERC fall into four general areas:
* Recommendations for future studies.
* Recommendations for interim operations plan designed to reduce impacts
upon downstream resources while further studies are being conducted.
•

Recommended mechanisms for coordination and decision-making among
affected groups during the period of study.

* Recommendations regarding NEPA compliance.
The members of the ERC Committee concur in most of the recommendations shown. In
those cases where there is not complete concurrence, the conflicting positions are
identified.
A. Recommendations for Future Studies
It was agreed that additional studies are needed. The topics which require the most
immediate research attention are the impact of fluctuating flows upon the aquatic
habitat and beach building and degradation. Specifically, the ERC recommends that the
Department of the Interior authorize the following:

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Immediate fluctuating flow research and monitoring studies for the
(1)
purpose of determining impacts on the aquatic habitat, including endangered
species.
(2) Immediate fluctuating flow research and monitoring studies for the purpose
of determining the relationship between fluctuating flows and beach building
and degradation.
(3) Implementation of Conservation Measures and studies for the endangered
humpback chub (Gila cvpha).
A major topic of discussion within the ERC was the source of funding for these studies.
After extended discussion the members of the ERC concurred that:
(4)
Studies necessary to monitor the effects of the operations of Glen
Canyon Dam should be a normal part of the operating costs associated with
the management of Glen Canyon Dam.
However, the specific funding levels and associated changes would have to be approved
annually as appropriate and within the context of management needs.
B. Interim Operating Recommendations
The operations of Glen Canyon Dam will continue to have impacts during the period that
the studies are being conducted. During this interim period, specific flow levels will be
studied. The specific test periods and levels will be determined by the technical research
group which coordinates the research effort. The test period of flows will be coordinated with the operations of Western and BOR.
The ERC agrees that some actions are prudent to protect downstream resources during
the test period when the studies are being conducted. Those recommendations agreed
upon by all members of the ERC include:
During the study test period, Glen Canyon Dam should be operated so as to:
(1) Maintain the 31,500 cubic feet per second (cfs) powerplant limit until
NEPA compliance for the Uprating Program can be reevaluated.
(2) Restrict future use of the powerplant capacity to 31,500 cfs or less
except under the following circumstances:
(a)

If used to reduce the use of bypasses (greater than 31,500
cfs),

(b)

If used only for power emergency purposes (time periods of
less than six hours), and

(c)

If used for emergencies in the power grid.

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(3) Ensure that flood frequency is less than one-in-twenty years with formalized
operating criteria that are distributed and reviewed by the other members of the
ERC.
The ERC could not come to concurrence on several issues regarding interim operations
at Glen Canyon Dam. Those issues are:
(4) Establishment of a minimum flow release.
(5)

Establishment of an acceptable load following (fluctuating flow) schedule.

A decision to adopt these two changes in current operations has sufficient impact on
the existing programs of Western and BOR that no agreement is possible without
Departmental direction or further studies to quantify the significance of fluctuating flow
impacts. A summary of the positions of the individual bureaus and Western regarding
this issue follows, with a full discussion included in Appendix A.
B.1 Minimum Flows
The Interior members of the ERC recommend that an INTERIM minimum flow level be
established at Glen Canyon Dam. The interim level, which will be studied over a range
of low flow levels and will be studied on a test basis, are as follows:
April 15 through October 30:
(I) All weekends with a minimum flow of 5,000 cfs.
(2) Weekdays with a minimum flow of 3,000 cfs and a daily average of
8,000 cfs or greater and a requirement to match historic load following
(fluctuating flows).
October 30 through April 15:
(1) An actual minimum flow of 5,000 cfs.
During the time of interim flow levels, specific studies would be conducted to verify the
actual level and rate of change necessary to specifically identify actual operational and
environmental needs. Additionally, Western would conduct a complete analysis of the
impacts associated with the actual customer markets.
These minimum flows would be adhered to except under the following conditions: When
Lake Powell meets the January 1 storage target of 22.6 million acre-feet and a large
snowpack is expected in the Upper Colorado River Basin, operations are oriented to
expectation of high runoff. Consequently, high releases are made in anticipation of
excess water flowing into Lake Powell.
However, if the forecast runoff is less than expected due to lack of snow or miscalculated snowpack, the actual runoff is less than anticipated. Releases would then be
curtailed to ensure the filling of Glen Canyon Dam and the 5,000 cfs minimum flow level

8

would be violated to achieve the filling target. This situation is anticipated to occur
once out of every ten years and only when Lake Powell is scheduled to fill.
B.2 Fluctuating Flows
The Interior members of the ERC recommend on an INTERIM basis that specific
fluctuating flow studies be initiated to determine the positive and negative impacts
associated with set boundaries of operation. The ERC further recommends that specific
flow boundaries be determined by the technical support staff and that, concurrently,
i mpacts associated with power, recreation, and other environmental aspects be determined. The studies will focus on the two key areas of aquatic resources and beach
dynamics.
C. Interim Coordination and Management
One outgrowth of the work of the ERC is the recognition that all members have a
vested interest in the management of the Colorado River, Glen Canyon National
Recreation Area, and Grand Canyon National Park, and that they need to work together
in a coordinated manner to protect these resources. The ERC recommends the following
aspects be addressed during the completion of the defined studies:
The NPS and FWS review the Secretary of the Interior's ,Annual
(1)
...,..,,
Operating Plan for Glen Canyon Dam to determine the impact on e Upper
Colorado endangered species, the riparian zone, fish and wildlife esources,
and recreational components.
(2) A steering/coordinating committee be established to set research goals
and conduct an annual assessment for these research and monitoring goals.
(3) A cooperative effort to provide an explanation to the constituent groups
of the relationship of operating criteria and power benefits be undertaken.
D. National Environmental Policy Act Compliance
The GCES program is a technically oriented effort to determine if the operation of Glen
Canyon Dam is having a quantifiable impact on the downstream resources. The original
directive was to collect and analyze the information to determine whether specific
operational changes could be made at Glen Canyon Dam.
The decision options that now exist for the Department of the Interior include: (1) no
change, (2) completion of additional interim studies, and/or (3) initiation of NEPA
compliance. The first option (no change) would be indicated if no quantifiable impacts
could be identified and/or no changes in the operations of Glen Canyon Dam could
reduce those impacts.
The second option (interim studies) would be indicated if critical decision-making
information were still lacking. The third option (initiate NEPA compliance) would
necessitate the identification of specific operational changes, including a no change
option, and would require that additional studies of the economic relationships be

9

initiated. Further, under NEPA compliance, a full public involvement program would be
required.
The ERC could not come to concurrence on the need to initiate the third option (NEPA
compliance). They were in full agreement however, that Glen Canyon Dam does have an
impact on the downstream resources. Several areas of concern must be resolved prior
to a decision on the initiation of NEPA compliance:
1. Should NEPA be initiated in a piecemeal approach or should it include all
operational options?
2. Which priorities drive the decision process (endangered fish, downstream
water requirements, implicit water rights, and/or power contracts)?
3. Does any change in operations dictate the necessity for NEPA compliance
or does enough flexibility exist within present Colorado River operational
mandates to allow for changes internally?
4. Should NEPA be initiated for the interim studies and used in the scoping
process or should the decision be delayed until the additional studies are
completed?
The ERC has determined that it cannot develop a recommendation until additional review
is made of the legal requirements defined for the Department of the Interior. The
Solicitors for the Department of the Interior and general legal counsel for Western have
made initial rulings which are included in Appendix A.

10

APPENDIX A
.

Individual Position Statements

•

GLEN CANYON ENVIRONMENTAL STUDIES
EXECUTIVE REVIEW COMMITTEE REPORT
BUREAU OF RECLAMATION POSITION STATEMENT

The members of the Glen Canyon Environmental Studies, (GCES)
Executive Review Committee have agreed to and recommended
further studies. These additional studies would be directed
towards two aspects of operational impacts;
(1) The impacts of both minimum and fluctuating flows
(load following) on the Endangered species habitat in
the Grand Canyon,
The impacts of load following on beach development
(2)
and erosion, and
The impacts associated with minimum flows on the
(3)
recreational use and sport fishery.
Continued studies on fluctuating flow impacts would not
require changes in present operational criteria. The impacts
of these flows would be studied in the Lower Colorado River
habitat and on the beaches as these flows occur under the
present operational criteria.
The National Park Service and the Fish & Wildlife Service
recommend that minimum flow studies be accomplished by
establishing an interim change in minimum flow criteria to
5,000 cubic feet per second (of s).
Present criteria require 1,000 cfs during the non recreation
season (September 1 to June 1) and 3,000 cfs during the
recreation season. The analysis of benefits of this change
over existing criteria and historical operations would be
completed prior to the recommendations for long-term changes.
Also to be analyzed would be the losses to the Colorado River
Storage Project (CRSP) system power customers either in
meeting peak demand or the increased cost of CRS? energy.
Reclamation supports the need to do additional analysis on
these aspects of Glen Canyon Dam operations. It is important
to remember that a significant part of the proposed work must
be completed to comply with the Section 7 of the Endangered
Species Act of 1973 (16 U.S.C. $$ 1531-1543) and would be
done independently of the additional GCES studies if
necessary. We are concerned that impacts of these studies be
11

minimized to the extent possible from the standpoint of the
CRSP system users. In order to do this, we beleive that:
1.

The minimum flows must be provided within the flexibility
of the existing operating criteria, in consultation with
representatives from the seven Colorado River Basin
States, and that the interem minimums not be established.
The required flows can be provided under properly
designed studies that will verify the hoped for benefits
that enhanced long-term minimum flows could provide.

2.

The risk of these study flows causing signficant loss in
power benefits or excessive costs of purchasing by
Western Area Power Administration (Western) to meet
contractual committments nees to be carefully evaluated.
The tests would need to be discontinued if river system
hydraulic conditions warrant. (ie. extremely high or low
water years)

3.

If conditions as discussed in (2) occur, the tests would
be postponed to a more favorable time.

4.

A specific design and length of study must be identified
and agreed to in order to limit the use of the power
system revenues. Support will be limited to an
appropriate and supportable level.

5.

By conducting the test within existing operating criteria
and in consultation with the seven Colorado River Basin
states, no additional National Environmental Policy Act
( NEPA) would be necessary to conduct the tests.

We believe the opportunity to conduct these additional GCES
studies concurrently with our Section 7 consultation
committments at Glen Canyon Dam will minimize the cost of any
additional work required before final recommendations can be
provided to the Secretary of the Interior regarding future
operational strategies and criteria.
BORERCPS - DLWegner 04/29/88

United States Department of the Interior
FISH AND WILDLIFE SERVICE
POST OFFICE BOX 1306
ALBUQUERQUE, N.M. 87103
In Reply Refer To:
Region 2, FWE/HC

MAY

- 4 1988

MEMORANDUM
TO:

Regional Director, Bureau of Reclamation, Salt Lake City, Utah

FROM:

Regional Director, Region 2

SUBJECT: Agency Position on Draft Executive Review Committee Report--Glen
Canyon Environmental Studies
This memorandum presents the position of the Fish and Wildlife Service (Service)
with regard to the Glen Canyon Executive Review Committee's report on the
operation of Glen Canyon Dam. It Is provided In accordance with agreements
made during the April 11, 1988, meeting to brief the Assistant Secretaries of
Interior on the Glen Canyon Environmental Studies and Executive Review Committee reports.
The Service fully supports the recommendations presented in the draft Executive
Review Committee Report. Due to conditions beyond the control of those responsible for operation of Glen Canyon and those carrying out the Glen Canyon Dam
Environmental Studies, (high water) study results were, In several cases, inconclusive. However, the studies do bring out several adverse effects resulting from
flooding and minimum flows below 5,000 cfs. Such impacts include impaired
access to tributary streams for fish spawning purposes, reduced backwaters for
rearing humpback chubs and other native fishes, severe dewatering and desiccation of Cladophora beds from the darn to the Little Colorado River, dewatering
of trout spawning beds, reduced fisherman access, destruction of riparian habitat,
and beach reduction.
Additional studies as recommended in the Committee's report are necessary to
more clearly define impacts and to establish a fluctuating flows regime which
minimizes impacts to the greatest extent possible while meeting the primary
purpose of the dam. These studies should be designed to determine the impacts
of various increased/decreased flow patterns with the agreed-upon flow patterns
provided for study purposes as part of project operations. It will also be necessary to determine the impacts of modified operation of Glen Canyon Dam on
upper basin project operations and related fish, wildlife, and recreational resources Including endangered species. These studies should be a normal part of the
operating costs associated with the management of Glen Canyon Dam.
The Service supports the Interim operating recommendations as presented in the
April 1988 draft committee report. The Glen Canyon Environmental Studies
documents the impact of flooding on bottom sediment and beaches within the
canyon. Stream sediments are essential to the well-being of the riparian and
aquatic resources of the system and must be maintained if these resources are to
exist at acceptable levels.
13

-2The interim minimum flows as recommended by the Interior members of the
Committee would serve to reduce dam operational impacts on aquatic and recreational resources. An estimated 70 percent of the trout spawning beds would be
functional under these flows. Recommended flow would help provide a stable
aquatic habitat base, improve tributary access and backwater maintenance, and
provide stable Ciadophora beds. These flows would also improve fisherman access
at the low end of the flow pattern providing safe passage over 3-mile bar. The
Service believes that there is sufficient data to support using the recommended
flows as the base study flow for the next 2 years. During this period, specific
studies should be conducted to verify the long-term effects on the aquatic
environment including endangered species.
Coordination is essential in carrying out the additional studies recommended by
the Committee. Establishment of the interagency steering/coordinating committee
should be the first step in achieving an acceptable coordinated effort. This
coordinating committee should establish basic research goals and study design and
access research progress.
National Environmental Policy Act (Act) compliance must be met for proposed
operational changes. The public interest in this segment of the Colorado River
and its associated resources were brought to the forefront with the proposals to
Increase generation at Glen Canyon Dam. This process is essential to provide full
consideration of all impacts and to allow full public considerations of the tradeoff which must be made. Compliance with the Act should be carried out when
final operational changes are proposed.
In summary, the Service is in full support of the recommended interim operational
guidelines and continued studies to further refine the impacts of minimum and
fluctuating flows on resources within the canyon.

(cLA

cc:
Mr. Dick Marks, National Park Service, Grand Canyon National Park. Grand
Canyon, AZ 86023
Ms. Patricia Port, Office of Environmental Project Review, USDI, San Francisco,
CA 94102
Ms. Marlene A. Moody, Western Area Power Administration, DOE, Salt Lake City,
UT 84147
Director, Arizona Game and Fish Department, Phoenix, AZ
Assistant Regional Director, Fish and Wildlife Service, Albuquerque, NM (FWE)
Regional Director, Fish and Wildlife Service, Denver, CO (FWE)
Field Supervisor, Ecological Services, Fish and Wildlife Service, Phoenix, AZ

NATIONAL PARS $8,31VICE ROSMORI -STATIEMENT
GCZS IOCECUTIvs REVIEW COMMITTEZ /WORT

Nrring meetings vith.Assistant secretary'latInterior's office
Learned that NAPA and USER intend to attach minority -opinions
the ERC report. . hough NPS is satisfied with the mum'
recomMendations that were forged 4Uring -sevaral ERC meetings,
FEEL IT IS necessary to clarify the MPS POSITION ON SEVERAL
issues in RESPONSE TO NEW OPINIONS VERBALLY EXPRESSED BY USER
WAPA.

we
to
we
-

and

We HAVE SEVERAL GENERAL concerns:
1.

No changes will be made to the April 3.988 draft of the
ERC report without agreement by the ERG menbers.

2.

NPS must have an opportunity to review and respond to
written opinions by other agencies.

3.

NPS must be directly involved in the preparation of
Guidance Documents for the Secretary Of Interior's
Office

4.

ERC report review and interim research must follow a
well-defined schedule and process that are coordinated
with and agreed to by ERC members.

S.

NPS feela that THERE IS NO LEGAL BASIS FOR THE
OPERATIONAL PRECEDENCE OF POWER generation over the
other legally defined "incidental objectives" of Glen
Canyon Dam (including flood control, river regulation,
water quality control, recreation, enhancement of fish
and wildlife resources, and ENHANCEMENT OF OTHER
environmental factory). The PRECEDENCE of incidental
objectives of Glen Camial Dam NEED TO BE LEGALLY
evaluated.

OTHER significant CONCERNS relate to Section III regarding_ERC
recommendations:

A.

Recommendations -for Future Studies.
1. NPS supports the need for immediate fluctuating
flow research on the aquatic habitat and beach
building and degradation, and the implementation
of Conservation Measures UNDER SECTION 7
legislation for the ENDLINGEREDT'HUMPBECK CHUB and
other species of concern including the bald eagle
and peregrine falcon.
15

2.

The Modified operating criteria to reduce flooding
need to be evaluated by NPS with regard to the
effects of CHANGING LAKE LEVEL O* recreation and
natural resources at Glen Cinyon National
Recreation Area. 'To this end, MPS needs written
documentation of the USBR modified operating plan

TO REDUCE FLOODING FOR REVIEW. SHOULD RESEARCH BE
DETERMINED NECESSARY the IMPACTS WILL BE ANALYSED
and documented through U3BA'authomisation AND

fanding.

5.

APB supports the ERG recommendation that !studies
NECESSARY TO MONITOR THE EFFECTS of the operations
OF GLEN CANYON DAM SHOULD BE A NORMAL PART OF THE

operating costs associated with the management of
Glen CANYON Dam" until mitigating actions ARE
implemented.
4.

5.

SPECIFIC-RESEARCH PROJECTS NEED TO BE DEFINED AND

integrated THROUGH the involvement of 10S, JAS,
researchers, and other concerned agencies.

Specific flaw regimes identified in the research
plan must be provided by USSR and agreed to by
NAPA. Seasonally specific flow regimes based on
research needs must be set, and adhered to by an
interagency coordination group. A letter of
agreement specifying THE TIMING and duration of
SPECIFIC FLOWS SHOULD BE DEVELOPED between MPS,
US, AND FWS.

B.

Interim Operating Recommendations.
1

2.

NPS supports the interim flaw LEVELS RECOMMENDED
by the Interior members of the ERC, including the
MINIMUM FLOW levels described in the BBC April
1988 draft. However, the interim flow levels
should not limit seasonal flow regimes established
for research purposes. In addition, during the
test period for interim operations, seasonally
specific flow levels must be provided by USER and
'NAPA to complete studies of flow impacts on
resources. The tent period must extend over at
least two life cycles of species of CONCERN TO
adequately &ems operational impacts. Anextension of research may be required it specific
flow regimes are not provided.
Bconaiic analysis of impacts of minimum flaws an
customer markets should be conducted by recognised
outside exports. In additional, currant NAPA and
USBM estimates of revenue lessen due to "animus'
flows need to be documented and reviewed by
experts.
16

;
XEROX TELECOPIER 45t 4-78,

e4./2 /198

" QR,2 629
15 : 46

wr-cc

65654

AMON

85885499;# )4
004

N'S feels that the criteria that-allow Use of
poverplant capacity above 31,500 iifs are NOT
restrictive enough. Exception 2c_that allows AN
increase in capacity *if used for emergenCies in
the power ..grid should be deleted
in addition,
this *power emergenay purposes° referred to in
section 2b need to be clarified and limited.
C.

Interim Coordination and MANAGESENT.
1. NPS supports the ERC-reconmendations FOR INTERIM
coordination and management.
In PARTICULAR,
research plans and .9ae research coordination

1

SHOTAARSI'VELL-DEFIHED AND SHOULD BE REVIEWED BY

the managing agenci44. Plans to inform
constituent groups should also be well-defined and
follow NEPA process.
D.

NEPA Compliance
1.

NPS BELIEVES THAT GLEN CANYON DAM HAS SIGNIFICANT

adverse effects on resources below the dam. ?or
THESE REASONS NPS SUPPORTS THE need for THE NEPA
compliance process in current and future planning
of research and modifications to operations at
Glen Canyon Dam.

17

Western Area Power Administration
Minority Opinion on the Glen Canyon Environmental Studies
and Executive Review Committee Report
May 4, 1988
The Executive Review Committee

(ERC) Final (draft) Report dated April 1988

contains recommendations by the Interior members of the
studies be made,

ERC (1) that additional

(2) that new minimum flow levels below Glen Canyon Dam be

instituted for recreational purposes, and

(3) that a mechanism be developed for

coordination and decision making among affected bureaus and Western during the
period of the studies.
Western Area Power Administration (Western) concurs with the Interior members of
the

ERC on the need for additional studies on the effects of fluctuating flows,

with the qualification that such additional studies be focused on data collection and monitoring of existing conditions. Western also agrees that Reclamation should continue to operate Glen Canyon Dam so as to reduce the likelihood
of flood control releases that result in spills, and that a mechanism should be
established for coordination and decision making among the affected agencies and
Western during these additional studies.
However, Western strongly objects to the recommendation for interim changes to
the existing operation criteria for Glen Canyon Dam and the implementation of
proposed new minimum flow levels for additional studies. Western's objections
to these proposed new minimum levels are based upon the following reasons:

18

1. The proposed new minimum flow levels violate the provisions of the Colorado
River Storage Project (CRSP) Act, 43 U.S.C. Sections 620-6200.
The three primary purposes of the CRSP Act are (1) storage of water to meet
terms of the compacts, (2) use of the water for agricultural and domestic
purposes, and (3) for the generation of power. The language in Section 7 of
the CRSP Act (43 U.S.C. Section 620f) prioritizes the three primary project
purposes; the first priority is compliance with provisions of the Law of the
River and related legislation, the second priority is to the appropriation
of water for domestic or agricultural purposes, and the third priority is
the production of the maximum "practicable" firm hydroelectric power and
energy. Conservation of the nature and wildlife on project lands, and
recreational uses of the water areas created as a result of the CRSP Act is
authorized in Section 8 (43 U.S.C. Section 620g) which requires that these
purposes be consistent with, i.e. subservient to, the primary purposes of
the Act.
Equally important, the language of Section 7 of the CRSP Act requires that
the CRSP powerplants be operated so as to produce the maximum possible firm
capacity and energy. This requirement is limited only insofar as necessary
to comply with the Law of the River, and with the appropriation of water for
domestic or agricultural purposes. The reasons for this requirement were
(1) the importance of power to repay most of the project costs, and (2) to
reassure the Upper Basin States that sufficient revenues would accrue to
allow for repayment of construction costs of participating projects within
these states.

19

Therefore, implementation of proposed minimum flow levels for recreational
purposes, which would cause significant reductions in the amounts of shortterm and long-term firm capacity and energy that would otherwise be produced
b. :he CRSP powerplants, would violate both the established priority of
,.ower over recreation and the requirement to maximize hydroelectric firm
power and energy.
Further, it was intended by Congress that after repayment of project costs,
power revenues would flow into the Treasury as an additional benefit to the
United States. This intended benefit would also be impaired because, to the
extent that power operations are reduced, the net revenues returned to the
Treasury after repayment would also be reduced. The economic benefit that
Congress intended power consumers in the Colorado River Basin states to
receive from the project power operations would likewise be reduced.
A more detailed discussion of Western's legal opinion on the priorities of
project purposes, dated April 26, 1988, is attached and is incorporated in
this minority opinion by reference.

Moreover, it should be noted that historically, a significant portion of
Western's nighttime or offpeak electric load has been served through
economic purchases of thermal or coal-fired generation from other sources.
Such purchases have a dual benefit (1) by allowing the storing of water in
Lake Powell for later release during daytime or peak hours when the
resultant hydroelectricity has greatest value, and (2) by allowing more
efficient operation of coal-fired generators by avoidance of costly
variations in generation levels. With increased offpeak minimum release
requirements in the winter, Reclamation would generate greater amounts of
20

hydroelectricity during offpeak hours. Thermal power producers would then
be required to vary their coal-fired generation levels to account for this
loss of offpeak load, thereby resulting in less efficient or economic
operation for both parties.
2. The implementation of interim operating requirements, specifically "test'
minimum releases at Glen Canyon, are unsupported by the conclusions of the

GCES Integration Report.
Western's detailed comments to Reclamation on the final GCES Integrated
Report, dated December 11, 1987, reiterated serious concerns with the
findings of the GCES. These concerns focused on the use of an idealized
optimum as the assumed baseline condition, and the so-called "impacts"
identified when this ideal baseline was compared to alternative operational
scenarios. Western's position was, and remains, that present operations
should have been considered as part of the existing baseline conditions, and
that the use of the term "impacts", which has significant NEPA connotations,
is inappropriate. It is Western's belief that the GCES have failed to
properly identify true impacts. Further, since effects on water regulation
to meet compact terms, water deliveries for irrigation and domestic
purposes, and power generation were not addressed in the technical studies,
the GCES are incomplete.
Western therefore contends that the unresolved question regarding the
significance of the "impacts" identified by the GCES can not be answered
until additional baseline data has been collected on existing conditions and
effects have been appropriately quantified, including the impacts to water
regulation and deliveries and power generation. Further, Western maintains

21

that these "impacts" are not sufficient to justify a decision to adopt a
change in existing operations on an interim basis.
The ERG Final Report also has not adequately addressed the significant potential loss in power benefits due to the proposed changes in minimum flow
releases for this study period. The annual reduction in revenues due to
implementing proposed new interim minimum releases for an assumed two-year
period are estimated by Western to be roughly $10 million, based upon
simulation of historic monthly pattern of water releases from Glen Canyon
under the proposed higher minimum release rates and median hydrologic
conditions. At this time, it is unknown what impact such a decrease in
available capacity and shift in available energy due to changes in minimum
flow requirements might have on the short-term to firm power customers. Also
unknown is what additional economic impact would occur given the assumption
of drier-than-median hydrologic conditions, as is currently the case in the
Upper Colorado River Basin. However, should the operating criteria be
revised to continue these release restrictions indefinitely, the estimated
lost power benefits to Western's firm power customers would be an estimated
$21.8 million per year beyond 1999. These estimates represent a significant
and widespread financial loss to the firm power customers throughout
Western's seven-state market area. This real economic impact further erodes
any justification for changes to existing operations at this time.
Further, since the GCES are incomplete, it can only be speculated as to
whether the proposed new minimum release levels which would result in additional benefit to recreational resources (sport fisheries and white water
rafting) might possibly result in adverse impacts to aquatic habitat for
endangered fish species and beach building and degradation.
22

3.

Before any proposal to alter the present operating pattern of Glen Canyon Dam
is implemented, NEPA compliance at an appropriate level must be completed.
This includes the proposal to change minimum flows, as well as any proposed
change to the long-term operating criteria.

The Executive Review Committee report recommends a change in operations by
increasing minimum flows to 5,000 cfs for most winter months, without
supporting the recommendation with an analysis of the pluses and minuses of
this action, and other possible alternatives. Such options would be brought
out in a NEPA analysis, which should include a rigorous investigation of the
comparative costs and benefits of the proposed action and alternatives, and
provide a framework for informed decision-making.
Presently, the recommended proposed action is advanced with little measure of
benefit while very real negative impacts and legal requirements, within which
the agencies' actions are bounded, are essentially ignored. Many more hard
facts are needed before an informed and legally sound decision can be made.
The suggestion that changes should be made first, and then the results
studied, is contrary to the provisions of NEPA and CEQ regulations. Failure
to incorporate a NEPA process at the earliest possible moment in the planning
of a proposed action is also contrary to CEQ regulations.

The implementation of interim flow requirements would clearly prejudice the
collection of data on fluctuating flows and any future NEPA compliance
documentation. By imposing interim flow releases in advance of the
definition of current conditions, consideration of a modified baseline
condition, and alternatives would most definitely be biased.

23

Western is not promoting a Colorado River Upper Basin Environmental Impact
Statement. We are, however, noting that a properly scoped NEPA process must
be completed before any new minimum flow proposals or before any proposed
modification to the long-term operating criteria are implemented.

As stated before, Western supports additional data collection and monitoring of
all critical resources below Glen Canyon dam based upon current operations so
that baseline effects of operations under a reasonable spectrum of water conditions can be evaluated. The collection of data on fluctuating flows and on
varying alternative minimum releases could still be accomplished without
modification of existing release restrictions. Such additional studies should be
focused and over a sufficient length of time to assure that the financial burden
of such studies would be held to a reasonable level.
The EIC Final (draft) Report states that Western ". . . would conduct a complete
analy is of the impacts associated with the actual impacted customer markets . . ."
as a result of implementation of interim minimum flow releases. Western maintains that possible impacts to existing conditions should be identified prior to
dec,sion making, rather than the contrary, as proposed.
A !Aimmary of Western's position and recommendations regarding the ERC Final
(draft) Report is then:

1.

The proposed minimum-flow changes in operation of the Glen Canyon Dam are
intended to further improve the quality of two already outstanding
recreational resources. To the extent that the change in operation reduces

24

the firm capacity and energy that could be produced by the Glen Canyon
powerplant, it conflicts with the provisions of the CRSP Act and the intent
of Congress concerning powerplant operations as reflected in the CRSP Act and
Its legislative history.

2.

Western does not support the implementation of proposed interim or "test"
minimum flow levels. However, Western does support additional data
collection and monitoring of existing baseline operations at Glen Canyon,
though such studies should be clearly defined and focused with due
consideration of annual hydrologic conditions. Such additional studies
should also include determination of possible effects of fluctuating flows on
all critical resources, including water and power.

3.

A properly scoped NEPA process must be completed before any interim minimum
release proposals or proposed modifications to the long-term operating
criteria for Glen Canyon are implemented. Moreover, the implementation of
Interim minimum flows would bias the collection of data on any alternative
considered in a future NEPA document.

25

vs um

.%.11aLcs

Department of Energy

%.1uvernmenI

memorandum
DATE

western Area Power Administralion
Crr 0

April 26, 1988

WILY TO
ATM Of:

A0207, S. Earley

MAJECt

Priorities of Project Purposes in the Operation of Glen Canyon Dam
and Powerplant

/007

Lloyd Greiner, L0000, Salt Lake City, UT
The Bureau of Reclamation proposes to change the operation of Glen Canyon dam
and powerplant to establish minimum flows of 5,000 cfs every day from
October 30 through April 15 and on weekends from April 15 through October 30,
and minimum flows of 3,000 cfs from April 15 through October 30, to further
Improve already outstanding recreational activities, such as the blue-ribbon
trout fishery and white-water rafting. You have asked for my legal opinion
concerning this proposal which will significantly reduce the amount of firm
power and energy that can be produced by the powerplant, decrease the value
of the power resource, increase the costs to power consumers in the region,
and, after repayment, reduce the profit returned to the Treasury. As a part
of the legal opinion, you have inquired about the priorities to be given the
various authorized purposes of the Colorado River Storage Project (CRSP) of
which Glen Canyon dam and powerplant are features. You have also asked about
the accuracy of a statement in the Glen Canyon Environmental Studies Draft
Technical Report (GCES) that suggests that power is to be treated on a par
equal to such other purposes as recreation and conservation. Finally, you
have asked that I address the accuracy of certain remarks in the legal
analysis of the GCES prepared by the National Academy of Sciences. My
conclusion is that the proposal of the Bureau's Salt Lake City Region fails
to comply with the directives of the CRSP, the law of the Colorado River, and
NEPA.
Background
On December 14, 1982, Mr. Clifford I. Barrett, Regional Director of the Upper
Colorado River Regional Office of the Bureau of Reclamation (Bureau), sent a
letter notifying other Federal agencies of his decision to initiate studies
to determine the environmental effects of the present and historic operation
of Glen Canyon Dam on the resources of the Grand Canyon. The result, in
August 1987, was publication of the GCES. The tudies concentrated on the
effect of dam operations on the humpback chub, other native fish, rainbow
trout, camping beaches, riparian vegetation and wildlife, white-water boating
and trout fishing. The studies were commenced in 1983' during a year in
which water was spilled due to flood conditions. The water flows into the
reservoir during the study continued to be high and, thus, the studies are
deficient regarding impacts of operations during low-water years. The
studies well not intended nor designed to lead directly to changes in dam
operations.' Nevertheless, the Bureau proposes to change the operation of
the dam.
The apparent but unstated purposes of the proposed minimum flows are to A
benefit trout and native fishes, trout fishermen and white-water rafters.'
This proposed change in operations has not been preceded by any study of the

26

effect of such changes on the primary purposes of the CRSP. The proposal has
not been subjected to any documentation or studies consistent with the
National Environmental Policy Act of 1978 (NEPA), 42 U.S.C. §§ 4321-4347.
Legal Analysis of
Priorities of CRSP Purposes
The legislative history of the CRSP Act reveals that the Act was designed to
make use of about 2,500,000 of the 7,500,000 acre-feet of Colorado River
water apportioned for use in the Upper Colorado River Basin states by and
consistent with the Colorado River Compact of 1922 and the Upper Colorado
River Basin Compact of 1949 (Compacts). H.R. Doc. No. 364, 83d Cong., 2d
Sess. 148 (1954). The water uses and power generation authorized by the CRSP
Act were considered important to the development and economic growth of the
area. H.R. Rpt. No. 1087, 84th Cong., 2d Sess., reprinted in 1956 U.S. Code
Cong. & Admin. News 2346, at 2350-51 (1956).
Without the power features, the project would not have been feasible. Of the
$760 million appropriated for project construction, power revenues were to
repay $422.7 million of construction costs allocated to power, $320 million
in interest on the power investment, $246.2 million of construction costs
allocated to irrigation and leave a surplus of $86 million in the U.S.
Treasury at the end of 50 years. By contrast, municipal water revenues were
only to recover $45.5 million of costs allocated to that purpose, plus
interest; irrigation revenues were only to recover about $36.6 million of
the $331.6 million of costs allocated to irrigation; and the $8.6 million of
project costs allocated to flood control, fish and wildlife and recreation
were and are nonreimbursable. Id., at 2355-2356; see also, 43 U.S.C. § 620g.
Thus, the importance of the three primary purposes of the CRSP Act - storage
of water to meet terms of the-compacts, and use of the water for agricultural
and domestic purposes, and for the generation of power - is clear.c It is a
theme repeated throughout the legislative history of the CRSP Act.
The importance given these three primary purposes is reflected in the CRSP
Act; they appear repeatedly in various sections - Sections 1, 2, 3, 4, 5, 6,
7, 9, 13, and 14 of the CRSP Act. Other project purposes, such as
conservation, recreation, and sedimentation control are mentioned much less
frequently or not at all.
The hydroelectric power features of the project were of such interest to the
upper basin states that three of those states, in commenting on the proposed
project wrote that "the hydroelectric plants of the Colorado River storage
project should be operated in conjunction with other powerplants present and
potential in such a way as to produce the greatest practicable amount of
power and energy that can be sold at firm power and energy rates."
See
Comments of Colorado, New Mexico and Utah. H.R. Doc. No. 364, supra, at 302,
309, and 315. They were concerned that procedures for power operation be
established that would produce the greatest future benefits possible for the
upper basin states from the CRSP power. Id. Language in all the CRSP bills
then before Congress reflected this conciiii as well as the then-present power

policy of the Congress which required "that the large multiple-purpose
projects utilize the water resources to the maximum in the generation of
power without impairing the use of the project for irrigation, municipal and
industrial water, or flood control." H.R. Rpt. No. 1774, supra, at 4 and 9;
see also, e.g., Section 6 of H.R. 3383, The Colorado River StorageProject
Hearings on H.R. 70, H.R. 2836, H.R. 3383, H.R. 3384 and H.R. 4488 Before the
Subcommittee on Irrigation and Reclamation of the House Committee on Interior
and Insular Affairs, 84th Cong., 1st Sess. 3 (1955).
The pertinent language in those bills is found in Section 7 of the CRSP Act,
43 U.S.C. § 620f:
The hydroelectric powerplants and transmission lines
authorized by this chapter to be constructed, operated,
and maintained by the Secretary shall be operated in
conjunction with other Federal powerplants, present and
potential, so as to produce the greatest practicable
amount of power and energy that can be sold at firm power
and energy rates, but in the exercise of the authority
hereby granted he shall not affect or interfere with the
operation of the provisions of the Colorado River
Compact, the Upper Colorado River Basin Compact, the
Boulder Canyon Project Act [43 U.S.C.A. § 617 et seq.],
the Boulder Canyon Project Adjustment Act [43 U.S.C.A.
§ 618 et seq.], and any contract lawfully entered into
under said Compacts and Acts. Subject to the provisions
of the Colorado River Compact, neither the impounding nor
the use of water for the generation of power and energy
at the plants of the Colorado River storage project shall
preclude or impair the appropriation of water for
domestic or agricultural purposes pursuant to applicable
State law.
This language is important in two ways. First, it requires that the CRSP
powerplants6be operated so as to produce the maximum possible firm capacity
and energy.
The only limitations on this requirement are that the operation
of the powerplants must be consistent (1) with the Compacts, the Boulder
Canyon Project Act, the Boulder Canyon Project Adjustment Act and contracts
entered into under those Compacts and laws, and (2) with the appropriation of
water for domestic and agricultural purposes.
Second, it prioritizes the three primary project purposes. The first
priority must be given to compliance with provisions of the compacts, the
Boulder Canyon Project Act, Boulder Canyon Project Adjustment Act, Rio Grande
Compact of 1938 and the Treaty with the United Mexican States. See also, § 9
of the CRSP Act, 43 U.S.C. § 620h. The second priority is to the
appropriation of water for domestic or agricultural purposes. See also, § 4
of the CRSP Act, 43 U.S.C. § 620c. The third priority is to hydroelectric
power. In fact, the project must be operated so as to produce the maximum
firm capacity and energy that can be produced consistent with the above two
project purposes. 43 U.S.C. §620f.

28

Additional project purposes of conservation of the nature and wildlife on
project lands, and recreational use of the water areas created as a result of
the CRSP Act were authorized in § 8 of the Act, 43 U.S.C. § 620g. Section 8
requires that these purposes,be consistent with, i.e. subservient to, the
primary purposes of the Act.' See also, Jicarilla Apache Tribe v. United
States, 657 F.2d 1126 at 1139, 1141 (10th Cir. 1981) ;and Friends of the
Earth v. Armstrong, 485 F.2d 1 (10th Cir. 1983), cert. denied 414 U.S. 1171,
rehig. denied. 416 U.S. 952.
In Friends of the Earth, the court rejected a proposal by environmentalists
that the Glen Canyon Dam be operated so as to reduce the level of Lake Powell
below the 3,606 foot level in order to prevent waters of Lake Powell from
encroaching on Rainbow Bridge National Monument. The court found that the
conservation proposal would conflict with the Compacts and the CRSP Act. One
of the conflicts with the CRSP Act was the negative impact such a reduction
in water level would have on power because it would reduce the head or
pressure available for power with a resultant drop in the amount of firm
capacity and energy that could be generated, and on the amount of money
available to the Upper Basin Fund for repayment of power and irrigation
costs, and for the operation of project facilities as planned by Congress. It
would conflict with the "specific admonition by Congress [to the officials of
the Bureau of Reclamation] that the power generation facilities be operated
at their most productive rate (43 U.S.C. § 620f)." Id., at 10,11.
The pre-publication copy of the Review Report for the GCES by the National
Academy of Sciences (Report) describes similar problems with respect to the
Bureau's proposed change in the operations of Glen Canyon dam and powerplant
and notes that the GCES fails to support its recommended changes in
operations to benefit recreation by discussing the impact of such changes on
power production and revenue and the availability and cost of alternative
power sources. The Report, pages 102-103, points out that:
...an increase in minimum flow during the night will
produce a corresponding decrease in maximum flow during
the day and a.significant loss in revenue to the Colorado
River Storage Project (CRSP i due to reduction in shortterm sale of surplus energy during peak hours and
perhaps even the inability to meet firm power
contracts...in the world of energy marketing, the time of
day during which energy is produced is crucial for the
following reasons: (1) firm power contracts require a
large fraction of energy deliveries during peak hours and
(2) the opportunity to sell energy surplus to firm power
contracts at much higher prices occurs during daily peaks
-- not at night. The operations report does not discuss
the implication of these facts. For example, if a policy
of much higher minimum flows were to be adopted: (1) the
existing firm power CRSP contracts could likely not be
met (there would be excess capacity at night and
inability to meet firm contracts during daily peaks). (2)
Costs to CRSP customers would increase by perhaps 3 times

29

the lost revenue to CRSP because customers of WAPA would
have to meet the peak period energy shortfall with much
more expensive fossil fuel plants.
The Western Area Power Administration (Western) has studied the effect the
proposed minimum flows would have on power production and on costs to CRSP
power consumers in the region. Western's findings echo those of the courta in
Friends of the Earth and of National Academy of Sciences in their Report.
'The Western study found that the 5000/3000 cfs releases would result in
losses of 89 megawatts (MW) of firm power and 218.9 gigawatthours (GWh) of
firm energy in the winter season, and 11 MW of firm power and 34.5 GWh of
firm energy in the summer season. These losses will increase annual costs of
CRSP power users by about $5 million until 1999, at which time their annual
costs of replacing the lost firm power and energy would increase to about $22
million. The lost profits that would otherwise have been returned to the
Treasury after repayment of project costs were not quantified.
Conclusion
Section 7 of the CRSP Act requires that the CRSP powerplants, which include
Glen Canyon powerplant, must be operated at their most productive rate - to
produce the greatest practicable amount of firm capacity and energy. The
only limitations on this requirement are that priority must be given to
meeting the allocation of Colorado River waters contained in the Compacts and
to the delivery of water for irrigation and domestic use, and operations must
be consistent with the Boulder Canyon Project Act, the Boulder Canyon Project
Adjustment Act, the Rio Grande Compact of 1938 and the Treaty with the United
Mexican States. The operation of the dam and powerplant for other purposes
such as recreation and conservation must be consistent with the above
prerequisites. The past and present operation of the dam and powerplant have
been consistent with the above prerequisites.
The proposed changes are inconsistent with the above prerequisites since they
could cause significant reductions in the amounts of short and long-term firm
capacity and energy that would otherwise be produced by the CRSP powerplants.
Moreover, it was intended by Congress that after repayment of project costs,
power revenues would flow into the Treasury as an additional benefit to the
country. This benefit would also be impaired, because to the extent that
power operations are reduced, the net revenues returned to the Treasury after
repayment would be reduced. The economic benefit that Congress intended power
consumers in the Colorado River Basin states to receive from the project
power operations would likewise be reduced.
Thus the proposed change in operation of the Glen Canyon Dam to further
improve two already outstanding recreational resources would, to the extent
that it reduced the firm capacity and energy that could be produced by Glen
Canyon powerplant, conflict with the provisions of the CRSP Act and with the
intent of Congress concerning the operation of the CRSP as reflected in the
CRSP Act and its legislative history.

Susan Earley
Attorney
Office of the General Counsel
30

FOOTNOTES
1 The humpback chub is listed as an endangered species. The issue of
whether flows-should be changed in order to comply with the Endangered
Species Act has not been raised in the GCES, so it is not addressed here.
2 Lake Powell, the reservoir behind Glen Canyon Dam, had filled in 1980.
3 GCES, page vi.
4 GCES, pp. 52, 8-41, B-43. The extent to which trout fishery needs these
minimum flows is doubtful. It is considered a blue-ribbon fishery and is so
popular that the Arizona Department of Game and Fish implemented restrictive
fishing regulations in 1978, 1980, and 1986 to reduce fishing pressure.
GCES, at 19. The white-water rafting business is apparently also thriving.
The National Park Service limits the number of rafters in order to protect
the environment from overuse. GCES, at 8. Reservations for commercial trips
must be made 1 year in advance. Obtaining a permit for private trips may
require a wait of up to 5 years. GCES, at 19.
5

See, for example, the portion of the CRSP legislative history compiled
and reprinted at 1956 U.S. Code Cong. & Admin. News 2346-2425 (1956). See
also, H.R. Rep. No. 1774, 83d Cong., 2d Sess. 11 (1954):
In addition to these three principal purposes [referring
to storage of water for river regulation consistent with
the Compacts, use of the water for irrigation and
municipal and industrial purposes, and generation of
hydroelectric power] ... [emphasis added]
For another example, see the comments of the Department of the Army on the
proposed Colorado River Storage Project and participating projects, H.R. Doc.
No. 364, 83d Cong., 2d Sess. 320 (1954):
The purpose of the structures recommended in your report would be
primarily power and irrigation....
See also Salt Lake City et al. v. Western Area Power Administration, et al.,
No. C86- 1000 G, Slip Op. at 57, fn. 51 (C.D. Utah, April 14, 1988).
6 Salt Lake City, supra, at 57.
7 The Bureau's remark in the GCES that all CRSP project purposes, including
the generation of hydroelectric power, are incidental to the purposes of
satisfying water delivery requirements of the Compacts and for providing
water for irrigation and domestic use is accurate. It is also true, however,
that the CRSP powerplants must be operated so as to produce the maximum
practicable firm capacity and energy, limited only as necessary to meet the
water delivery requirements of the Compacts and for irrigation and domestic
use. The use of the project for recreation or other purposes is limited to
the extent such use is consistent with the above prerequisites.

31

The Bureau of Reclamation has in fact, apparently operated Glen Canyon Dam
and powerplant in accordance with the above requirements since the filling of
Lake Powell began. See, for example, the General Governing and Operating
Criteria During Lake Powell Filling Period (Filling Criteria), F.R. Doc. 627030, published at F.R. 6851 on July 19, 1962. Paragraph 8 of the Filling
Criteria unequivocally states that Lake Powell and Lake Mead shall be
operated so as to produce the greatest practical amount of power and energy.
The use or operation of the project for recreational purposes is not even
mentioned in the document. In 1970, the Secretary of Interior signed a
document entitled "Colorado River Reservoirs Coordinated Long-Range
Operation" (Operations Criteria). The preparation of the Operations Criteria
was mandated by §602 of the Colorado River Basin Project Act (CRBP Act),
Pub. L. 90-537, 82 Stat. 885, 900 (1968) (codified at 43 U.S.C. § 1552).
When enacting the CRBP, Congress reaffirmed the importance of §7 of the CRSP
Act by citing it in § 602(c) and requiring that §7 of the CRSP Act be
administered in accordance with the operations criteria set forth in
§ 602(a) and (b). The Operations Criteria are in all respects consistent with
the cited provisions of the CRSP Act and with the provisions of the CRSP Act.
8

This portion of the report fails to distinguish between capacity and
energy and to note that there can be short-term sales of firm capacity and
energy.
9

On pages 53 and 105, the Report, however, mistakenly asserts that "what is
at stake are lost power revenues, not a legal obligation" - that the
operation of the powerplant to maximize firm power and energy is a
discretionary matter, not a legal requirement. This remark is controverted
by the legislative history of the CRSP, Sections 1, 7, 8, and 9, and the
cases cited above, which place a legal obligation on the Secretary of
Interior to operate the CRSP powerplants so as to produce the maximum
practicable firm capacity and energy. In accord, Salt Lake City, supra, at
57. This obligation is limited only insofar as it may conflict with the
compacts and laws cited above and with the irrigation and domestic water
delivery requirements. The operation of the dams and powerplants for these
purposes takes precedence over their operation for other purposes.

32

APPENDIX
.

B

Individual Recommendations

APPENDIX B: INDIVIDUAL RECOMMENDATIONS
PART I: BUREAU OF RECLAMATION
The occurrence of flows above powerplant capacity must be reduced to the greatest
extent possible. We recommend the acceptance of the one-in-twenty program.
The existing evidence of impacts of load following operations does not support major
reductions in fluctuating flows.
Minimum flows to support fishery and recreational uses could be established as operational goals without significant loss of historical power benefits.
Establish a coordinated analysis and monitoring program to determine long-term impacts
of further criteria on the endangered species and the continued existence of beach
environments.
PART II: FISH & WILDLIFE SERVICE
Glen Canyon Dam should be operated in a manner which reduces flood flows to the
greatest extent possible. (Flood flows should not exceed one-in-twenty years.)
An interim minimum flow of 5,000 cubic feet per second, (cfs) should be provided until
additional studies are completed which identify and minimum flow requirements for
trout, humpback chub, and other native fishes.
The interagency coordinating and planning group established during the initial stages of
the GCES should be reactivated to oversee future research, review research results,
and define management goals.
Additional research should be undertaken to further define the effects of the operation
of Glen Canyon Dam on the natural resources of Glen and Grand Canyons (i.e., impact
of fluctuating flows on humpback chub and aquatic productivity and minimum flow
requirements for humpback chub and rainbow trout).
Costs associated with additional study and the development and implementation of
Section 7 (Endangered Species Act) Conservation Measures should be considered project
costs and funded from project power revenues.
Further studies should consider impacts to Lake Powell and other upstream Colorado
River Storage Projects.
Further study should include adequate provisions for constituent involvement and review.
PART III: NATIONAL PARK SERVICE
Additional research is needed to determine the effects of several aspects of Glen
Canyon Dam operations on Grand Canyon resources. Information is most limited in
three areas:

33

a. The effects of release patterns that were rare during the GCES such as
low flows and fluctuating flows.
b. The effect of operational changes initiated by the Bureau of Reclamation to
reduce flood frequency on recreation and natural resources at Glen Canyon
National Recreation Area.
c. The effect of increased powerplant capacity from 31,500 to 33,000 cubic
feet per second.
Operational changes to protect Grand Canyon resources should be initiated along with
research to determine their effects, including a refinement of flow requirements for
resources and measurement of improvement that result from preliminary changes in
operations.
a. Reduce the risk of flood releases to less than one-in-twenty years to
protect camping beaches and other alluvial sand deposits in Glen and Grand
Canyons, protect vegetation and associated wildlife, and reduce the risk of
white-water boating accidents.
b. Raise minimum releases to 5,000 to 8,000 cfs to protect trout spawning,
improve safety and quality of white-water boating, and provide upstream access
to Glen Canyon for trout anglers and day-use rafters.
c. Reduce rate and amplitude of fluctuating releases to protect and enhance
existing populations of native fish including the endangered humpback chub
(Gila cvpha), perpetuate high-quality white-water recreation, and reduce
stranding of trout and other fish.
d. Maintain high, relatively constant flows of 20,000 to 28,000 cfs from May
to September to protect and enhance reproduction of humpback chub in the
Little Colorado River and improve trip quality for white-water boaters.
Do not include the Western Area Power Administration Special Study with the other
materials used as background information for the Executive Review Committee without a
thorough review by outside experts and other agencies.
Each agency should formally define its priorities and goals affecting the management of
the Colorado River in Glen and Grand Canyons for review by other agencies and bureaus.
In particular, the newly initiated operation criteria to reduce the frequency of floods
from Glen Canyon Dam should be formalized and distributed to agencies and bureaus for
review.
Power revenues should continue to support appropriate and agreed upon research and
monitoring of the effects of Glen Canyon Dam on the downstream resources.
An interagency coordinating and planning group is needed to define annual and longterm (exceeding two years) research and management goals, review research results,
and plan future research with concurrence and involvement of participating agencies.

34

PART IV: WESTERN AREA POWER ADMINISTRATION
The impact to power production and loss of power benefits should be thoroughly assessed
prior to any decision to modify current operations other than to minimize flood flows.
(The National Academy of Sciences also concluded that this relevant information should
have been included in the technical report.)
A planning, coordinating, and joint decision-making group should be established for the
purposes of sharing information, reaching consensus upon necessary data collection or
long-term monitoring efforts, and ensuring that constituent groups are fully informed. A
representative from Western and one from the power constituents should be included in
the group.
Any monitoring program that is established to determine the existence and direction of
any environmental trends should be designed to be cost-effective and to remain focused
on the program goals and objectives.
Any short-term data collection still necessary should be clearly focused and accomplished
at a substantially lower cost than the environmental studies supporting the technical
report.
No substantive operational changes should be made until the compliance process under
the National Environmental Policy Act is completed.
Any monitoring program costs should be shared by all program beneficiaries.

35

,.

APPENDIX C
Individual Findings

APPENDIX C: INDIVIDUAL FINDINGS
Each entity of the Executive Review Committee reviewed the Glen Canyon Environmental
Studies Final Report and the comments received from the representative constituent
groups. From this review process, each bureau and agency developed specific findings
as related to its management objectives. The findings are presented individually.
PART I: BUREAU OF RECLAMATION
* Glen Canyon Dam has had an impact on the environment downstream.
* Flows greater than powerplant capacity have the greatest impact on the
downstream resources.
* Powerplant operation to follow peak demands has a significantly lesser
impact.
* Endangered species (humpback chub, Gila cvpha) populations appear to be
maintaining themselves under existing operating conditions.
* Sport fishery and recreational opportunities have increased significantly
over pre-dam conditions.
PART II: FISH & WILDLIFE SERVICE
* The Glen Canyon Environmental Studies (GCES) Final Report and other
pertinent information, including constituent input, supports the recommendation
that benefits to the natural resources of the Glen and Grand Canyon Colorado
River corridor would occur with changes in the present operating criteria for
Glen Canyon Dam. Flood flows (greater than 33,000 cubic feet per second
(cfs)) were found to be so deleterious to the maintenance of backwaters and
riparian habitats, that the GCES report recommended their frequency not
exceed one-in-twenty years. We support modification of the operating criteria
for this purpose.
* Benefits could also be derived by increasing minimum flows and reducing
fluctuation. However, study results were less definitive regarding these flow
patterns primarily due to the occurrence of high flows over much of the study
period. Flows of approximately 5,000 cfs appear necessary for angler access,
while flows of 8,000 cfs are required to prevent loss of rainbow trout
spawning. Benefits to the endangered humpback chub may be possible with
higher flows during spawning (May/June). Additional study is needed to
further determine the extent of these benefits at various flows. Further study
is also needed to more clearly determine the impacts of fluctuating flows on
the overall aquatic productivity of the system and its relationship to the
sediment/beach aspects of this river segment.
* Review of the GCES report by constituent groups and participating agencies
was impeded by limited review time, lack of technical reports, and the limited
number of reports available for review purposes.
37

PART III: NATIONAL PARK SERVICE
* Flood releases have negative effects on alluvial sand deposits, vegetation,
and recreation.
Beaches: Erosion of beaches and other sand deposits is increased
This loss is potentially irreversible
greatly at flood releases.
because sediment lost to the system during flooding is not quickly
replaced by tributary flows.
Vegetation and Wildlife: Vegetation is destroyed during flooding,
resulting in a loss of wildlife habitat. Irreversible erosion of sand
deposits will also lead to irreversible loss of vegetation.
Recreation: Flood releases increase the hazard of running rapids,
the number of boaters that choose to walk around dangerous rapids,
and the accident rates for anglers. They also reduce recreation
benefits for fishing and white-water boating. Loss of camping
beaches permanently reduces the recreation benefits of white-water
boating.
* Fluctuating releases have negative effects on recreation, trout, and native
fishes. However, fluctuating releases were rare during the GCES and their
effects need further study.
Recreation: Fluctuations reduce the quality of white-water boating
by stranding boats, increasing the difficulty of running some rapids,
decreasing the number of campsites and safe mooring places for
boats, and reducing the perceived naturalness of the river.
Trout: Fluctuations increase stranding of adult fishes and dry out
spawning beds, killing eggs and young if flows go below 8,000 cfs.
Humpback Chub: Fluctuations may dry out spawning areas for
humpback chub in the Little Colorado River and transport larvae
into the mainstem where cold temperatures can kill them. However,
more research is needed on the effects of fluctuating releases on
humpback chub.
Native Fish: Larval native fishes depend on quiet, warm backwaters
for development. As releases fluctuate, the availability and quality
of backwaters change, forcing fish to move into the mainstem river
which increases mortality.
•
Low releases (less than 8,000 cfs) have negative effects on recreation,
trout, humpback chub, and vegetation but may have positive effects on other
native fish species.

38

Recreation: Low releases increase the danger of many rapids for
white-water boaters and decrease the trip quality. Low flows also
increase accident rates for anglers.
Trout: Low releases expose trout spawning beds, increasing
mortality of eggs and young and reducing natural reproduction.
Under low releases the level of the mainstem river drops below the
level of tributary mouths, restricting access to tributaries for
spawning.
Humpback Chub: Low releases may restrict access to spawning areas
in the Little Colorado River. More research is needed on the
effects of low flows on humpback chub.
Vegetation: Seedlings, saplings, and ramets of native species have
increased mortality under low flows relative to exotic species
(tamarisk).
Low releases may increase the number of
Other Native Fish:
backwaters available to native fish larvae. More research is needed
on the effects of low flows.
PART IV: WESTERN AREA POWER ADMINISTRATION
* Confusion in the technical report arises from the use of environmental
assessment/environmental impact statement (EA/EIS) language which could lead
to a misunderstanding that the report is a National Environmental Policy Act
document, when it is not.
* To use data practically from the technical report, an appropriate baseline
must be clarified; the resource enhancement/optimization issues must be
separated from resource maintenance/mitigation issues; and the relationships
Management and policy objectives also
between events must be clarified.
must be separated from scientific objectives and findings.
* There is insufficient identification and quantification of the interrelationships between fluctuating flows and environmental resources, and among the
environmental resources themselves, to justify any change in operations.
Costs, benefits, and trade-offs between resources need to be determined, and a
detailed impact assessment be prepared before appropriate operational changes
can be identified and supported.
* The GCES final report does not contain an analysis of the effects of
potential operational changes upon power benefits which are essential for
informed decision-making. A recent assessment by Western of the consequences to power two alternative minimum releases at Glen Canyon Dam demonstrates that the financial and economic costs of such changes are significant.
The annual cost of a 5,000 cfs minimum release rate through 1999 would be in
the range of $5 million. Beyond 1999, the annual costs would be about $30
million. An 8,000 cfs minimum release rate would cost $14.7 million annually
39

through 1999 and would increase to $60 million annually thereafter. (The
current minimum release rates are 1,000 cfs in the winter and 3,000 cfs in the
summer.)
* The construction of Glen Canyon Dam moderated seasonal flow variations,
reduced river sediment loads, and lowered the temperature of the water for
some distance downstream. These changed conditions created the opportunity
for the sport fishery and white-water rafting to develop to their present high
qualities.

40

APPENDIX D
.

Individual Management
Objectives and Priorities

APPENDIX D: INDIVIDUAL MANAGEMENT OBJECTIVES AND PRIORITIES
Each bureau and agency provided the Executive Review Committee with a list of the
priorities and goals which defines its individual management responsibilities for the
Colorado River through Glen and Grand Canyons.
PART I: BUREAU OF RECLAMATION
* Stores water for beneficial consumptive use while meeting lower basin legal
entitlements.
* Provides for the control of floods.
* Complies operationally with the Endangered Species Act.
* Generates hydroelectric power and energy to the •greatest extent practicable
consistent with sound business practices.
* Recognizing the above, to the extent possible, maximizes fish and wildlife,
recreation and environmental opportunities.
These objectives were developed in consideration of the great diversity and expectations
among users, reflect appropriate consideration of all the uses of the reservoir, and are
in concert with the authorizing history and mandates.
PART II: FISH & WILDLIFE SERVICE
Protection and enhancement of endangered fish species utilizing the
*
mainstem, tributaries, and riparian habitats of the Glen Canyon and Grand
Canyon segments of the Colorado River.
* Assures that fish and wildlife resources of this segment of the Colorado
River and their associated recreational uses receive equal consideration with
other project purposes. This includes the establishment of a flow regime that
provides the best possible habitat conditions for native fish and trout
populations in concert with other resource needs, and limiting, to the maximum
extent possible, the loss of sediment important to the formation of backwaters
and riparian habitats.
* Protection of riparian and wetland habitats and their associated fish and
wildlife resources.
PART III: NATIONAL PARK SERVICE
* Protects and enhances existing populations of the endangered humpback
chub (Gila cvpha).
* Maintains Colorado River alluvial deposits (beaches) by mitigating accelerated erosion due to human-induced processes.
41

* Perpetuates and enhances the opportunity for a high quality white-water
boating experience in Grand Canyon.
* Protects and enhances populations of other native fish species.
* Perpetuates the recreational trout fishery.
PART IV: WESTERN AREA POWER ADMINISTRATION
* To satisfy the mandate of Section 7 of the Colorado River Storage Project
(CRSP) Act, to operate Glen Canyon and other authorized CRSP hydroelectric
plants "so as to produce the greatest practicable amount of power and energy
that can be sold at firm power and energy rates, consistent with the Colorado
River Compact and the Boulder Project Acts", which include:
a. Utilizing as much water as possible for power generation, and
minimizing releases that exceed the capacity of the powerplant; and
Maximizing the value (not revenue) of power produced by
b.
following load and providing the maximum practicable amounts of
power during peak use times of the day, week, and year.
* To market Glen Canyon power so "as to encourage the most widespread use
thereof at the lowest possible rates to consumers consistent with sound
business principles", under policies consistent with Section 5 of the Flood
Control Act of 1944.

42

APPENDIX E: CONSTITUENT GROUP COMMENTS
PART I: BUREAU OF RECLAMATION CONSTITUENCY
INDEX
COMMENT LETTERS
GLEN CANYON ENVIRONMENTAL STUDIES
SEPTEMBER 1987 DRAFT REPORT
Entity

Letter Date

Date Received

Colorado River Board of California

10-30-87

11-01-87

New Mexico Interstate Stream
Commission

11-09-87

11-13-87

Wyoming State Engineers Office

11-17-87

11-19-87

Upper Colorado River Commission

11-20-87

11-20-87

State of Utah Natural Resources

11-09-87

11-10-87

Representative John J. Rhodes, III

11-06-87

11-12-87

U.S. Geological Survey

12-30-87

1-05-88

Western Area Power Administration
(Reviewed August Draft Report)

9-09-87

9-11-87

National Park Service
12-02-87
12-02-87
Western Region
12-03-87
12-03-87
(Draft comments in two telecopier messages, finals not transmitted)
Plateau Group of Sierra Club

11-12-87

11-30-87

SUMMARY
COMMENTS RECEIVED FROM BOR CONSTITUENTS ON
GLEN CANYON ENVIRONMENTAL STUDIES
SEPTEMBER 1987 DRAFT REPORT
Dennis B. Underwood, Executive Director, Colorado River Board of California, Los
Angeles, CA Date of Letter: Oct. 30, 1987
Requests copy of Glen Canyon Environmental Studies Draft Report and suggests
it be sent to Colorado River Commission of Nevada and Arizona Department of
Water Resources.
Philip B. Mutz, Interstate Stream Engineer, New Mexico Interstate Stream Commission,
Santa Fe, NM Date of Letter: Nov. 9, 1987
Glen Canyon Environmental Studies Draft Report should be reviewed and
revised by Bureau of Reclamation personnel familiar with the documents
concerning the "Law of the River", the operation of Glen Canyon Dam and
Lake Powell, and development of the annual operating plan for the Colorado
River System reservoirs.
Frequency of flood releases is one in every 25 years, not one in every four
years.
Report should mention River Management Work Group which arrives at current
annual operation plan for the Colorado River System reservoirs which
minimizes change of releases exceeding 31,500 cfs.
Report shows that operation of Glen Canyon Dam has not had serious adverse
effects on the overall river environment below the dam.
Report does not evaluate in dollars the benefits of the primary purpose of
Glen Canyon Dam.
There is little to be gained by continuing the studies or starting new studies
of the effects of the operation of Glen Canyon Dam.
John W. Shields, Water Resources Engineer, Wyoming State Engineer's Office, Cheyenne,
WY 82002
ERC Report and Options Report should be subject to review and comment by
the seven Basin States prior to being forwarded to the Secretary of the
Interior.
There should be thorough review of the Operations Report with respect to the
"Law of the River" and Annual Operating Plan.
Several comments regarding language, facts, and interpretation of dam
operations.
44

John W. Shields (continued)
Report should be rewritten to acknowledge the efforts of the Colorado River
Management Work Group and their present and future efforts to avoid
bypassing water at Glen Canyon Darn.
Little can be gained by continuing the Glen Canyon Environmental Studies or
initiating other studies.
Gerald R. Zimmerman, Executive Director, Upper Colorado River Commission, Salt Lake
City, UT Date of Letter: Nov. 20, 1987
Glen Canyon Environmental Studies Draft Report contains numerous inaccuracies concerning the "Law of the River", has failed to recognize the
present environmental and other multi-purpose benefits that are due to the
operation of Glen Canyon Dam, does not take into account the Federal/State
Colorado River Management Work Group efforts to implement new approaches
for developing annual operating plans for Colorado River reservoirs, and does
not present evidence that operation of Glen Canyon Dam should be changed.
Upper Colorado River Commission and the seven Colorado River Basin States
should review and comment on the Executive Review Committee draft report
prior to its being transmitted to the Secretary of the Interior.
D. Larry Anderson, Director, State of Utah Natural Resources, Water Resources, Salt
Lake City, UT Date of Letter: Nov. 9, 1987
The Operating Criteria have given appropriate consideration to all factors
(water conservation, power production, water quality control, recreation,
enhancement of fish and wildlife, and other environmental factors) in an effort
to balance the benefits of the Colorado River Reservoirs to all users.
Study failed to address the impacts (costs) of enhancing environmental benefits
of water conservation and hydropower generation.
Study completed during a period of record setting floods and fails to take into
consideration new approaches to river operation that reduce adverse impacts
on the environmental features below the darn.
Secretary of Interior should not propose any changes in the operation of Glen
Canyon Dam based on this report, but should continue to work with the
Colorado River Basin States to develop a jointly acceptable plan to all those
involved in the operation of the river.
Congressman John J. Rhodes, III, House of Representatives, Washington, D.C. Date of
Letter: Nov. 6, 1987
Extend the review and comment period at least 30 days.

45

James F. Devine, Assistant Director for Engineering Geology, U.S. Geological Survey,
Reston, VA Date of Letter: Dec. 30, 1987
Data are not complete or accurate enough to define how large and/or how
frequent floods can be before a net loss of sand from the canyon occurs.
Evidence does not support conclusions that frequent flood releases (above
31,500 cfs) will cause significant and irreversible degradation of the environment by eroding substantial portions of the sand deposits, and frequency of
one flood in 20 years producing a net long-term loss of camping beaches and
substrate.
Marlene A. Moody, Deputy Area Manager, Department of Energy, Western Area Power
Administration, Salt Lake City, UT Date of Letter: Sept. 9, 1987 (Comments on
August 1987 Draft Report)
Disagrees with the baseline selected and the approach to the study.
Study should outline present operations as part of existing baseline, then
examine changes that could be made to this baseline condition to enhance
recreation resources.
Construction of Glen Canyon Dam produced trout fishery and allowed development of white-water rafting and day float trips.
Twelve pages of specific remarks included.
Stanley T. Albright, Regional Director, Western Region, National Park Service, Date of
Draft Telecopier Message: Dec. 2, 1987
The Glen Canyon Environmental Studies did not acquire sufficient information
to demonstrate the full range of effects of dam operations on humpback chub.
Steps to reduce flood risk to beaches should be put in place immediately and
studies should be initiated to study the relationship between fluctuating flows
(considering rate and amplitude) and beach erosion processes.
Several operational changes are necessary to reduce/mitigate impacts to whitewater boating, including: (1) increase minimum releases to 5,000 to 8,000 cubic
feet per second, (2) reduce flood frequency, (3) reduce rate/magnitude of
fluctuating flows, and (4) maintain high flows during peak recreational use
season.
Further information is necessary regarding life history of native fishes to
protect and enhance populations of endemic fish.
Several operational changes are necessary to perpetuate the recreational trophy
trout fishery, including: (1) provide minimum release to preclude dewatering of
redds (5,000 to 8,000 cfs minimums), (2) provide adequate releases to ensure
46

Stanley T. Albright (continued)
upstream access to the dam from Lees Ferry, and (3) reduction of fluctuation
rate/magnitude to reduce trout stranding.
Maximum powerplant discharge should not be allowed to exceed 28,000 cfs
pending further study.
Support continuation of interagency study/planning process and funding by
power revenues.
Stanley T. Albright, Regional Director, Western Region, National Park Service, Date of
Draft Telecopier Message: Dec. 3, 1987.
Technical studies should be completed so that they can be reviewed.
Operational changes may help humpback chub.
GCES sediment studies do not define relationship between sediment storage in
mainstem pools and rate of beach erosion.
Report raises serious questions to the Finding of No Significant Impact on the
uprate and rewind program.
Twelve pages of technical comments.
Dan Dagget, Conservation Chair, Plateau Group of the Sierra Club, Flagstaff, AZ Date
of Letter: Nov. 12, 1987
Glen Canyon Environmental Studies Draft report had inadequate distribution
and short review time.
Impacts of operations obvious and the remedy is to dismantle the dam.
Full National Environmental Policy Act procedures should be initiated. Why
has it not been done?

47

STATE 01 CAIRORNIA

I NE RESOURCES AGENCY

NEW MEXICO INTERSTATE STREAM COMMISSION

GEORGE DEUKMEJIAN. Gererno,

COLORADO RIVER BOARD OF CALIFORNIA
1 07 SOUTH BROADWAY ROOM 8103
L OS ANGE If S. CAM ORN1A 90017

COMMISSION MEMBERS

17131 620 4480

October 30. 1987

4ta

Mr. Dave Wegner
Glen Canyon Environmental Studies Manager
Attention: UC - 410
P.O. Box 11568
Salt Lake City, Utah 84147

ALBERT E LITTON, Chairman, Albuquerque
S E REYNOLDS, Secretary. Santa Fe
J. PHELPS WHITE III. Roswell
GE OR(( BRANTLEY, Carlsbad
TRACY SEIDMAN, Wagon Mound
RICHARD C JOHNSON. Slyer Coty
SAMMIE SINGH. La Mesa
PETER A CASADOS, El Gurque
JACK D COOK, Farmington

BATAAN MEMORIAL BUILDING
STATE CAPITOL
SANTA FE, NEW MEXICO 87503

NOVEMBER 9,

ERH7 't") G AL)
VP)

Dear Mr. Wegner:
The Colorado River Board of California, California's state agency
charged with protecting California's rights and interests in the water and
power resources of the Colorado River system, is vitally concerned with the
operation of the river's reservoir system and actively participates in the
formulation of the annual operating plan for the coordinated operation of
the reservoir system.

.t

CO

f understand that agencies involved in resource management in the Grand
Canyon and others have recently completed a joint study on the operation of
Glen Canyon Dam and that a draft report an the study entitled "Glen Canyon
Environmental Studies", dated September 1987, has been made available for
review and comment. Because of our vital inIecest and involvement in the
operation ..9L...
iver's reservoir system. LigiqufaiaiRiZille'reielyfng-u
t,Copy of the_tip.Ot
,.. rev if. Inasmuch as the state agebZiTrIB Iti utfter
Lower Colorado River Basin states involved Colorado River operations would
su g _Ihirreiii•
. be similarly_intccesIed.
rialkThe
e
furnished lb
the Callacada_Rivik-CommiAA
f evadi arid izona -pepartment et watEr

• -

Atesourcau

Thank you for your cooperation on this matter.
Sincerely,
c.ioNv-At,
Dennis B. Underwood
Executive Director
LL:

Jr. Alan P. Kleinman
Director
Arizona Department of Water Resources.
Jack L. Stonehocker
oirector
Coloraeo River Commission of Nevada

3 987

MR. CLIFFORD I. BARRETT
REGIONAL DIRECTOR
BUREAU of Reclamation

Upper Colorado Regional Office
P. 0. BOX 11568
Salt Lake City, Utah 84147
Dear Cliff:
THIS letter is in response to your October 7, 1987, letter,
which transmitted for review and comment a draft copy of the Glen
Canyon Environmental Studies (GCES) Integration Report.

The report should be reviewed and revised by Bureau of
Reclamation personnel familiar with the documents concerning the
"Law of the River," the operation of Glen Canyon Dam and Lake
Powell and the development of the annual operating plan for the
COLORADO RIVER System reservoirs. The report contains a number
of inaccurate statements and errors regarding the Law of the
River and the operation of Lake Powell and does not acknowledge
development OF THE ANNUAL OPERATING PLANS.
AN EXAMPLE OF .ERROR, Or MISREPRESENTATION OF DATA, IS THE
'STATEMENT IN THE SUMMARY OF THE REPORT THAT "UNDER CURRENT
operating conditions, flood releaser will occur in about ONE OF

EVERY FOUR YEARS." FOR PURPOSES OF THIS REPORT, flood releases
ARE DEFINED AS ALL RELEASES in EXCESS OF 31,500 CUBIC FEET PER
SECOND. IN RESPONSE TO QUESTIONS AT THE PRESENTATION OF THE
REPORT AT THE UPPER Colorado River Commission meeting on October
22, 1987, it developed that the high flow years of 1983-86 were

used to arrive at this frequency of occurrence of flood releases,
but that, using a representative period of record, the frequency
of such a discharge is greater than once in every 25 years.
Because much of the report is devoted to the effects on the river
environment of flood releases, this one item alone is of
considerable importance.

OF WYOMING

Mr. Clitford I. Barrett
Novemher 9, 1987
Page Two

'OORDONW FASSa

Nate engineet
HERSCHLER BUILDING

The report does not take into account the product of the
River Management Work Group in arriving at the current annual
operating plan for the Colorado River System reservoirs, which,
among other facets, minimizes the chance of releases from Glen
canyon exceeding its power plant capacity, 31,500 cfs. It can be
anticipated that future annual operating plans will also minimize
the need for releases in excess of power plant capacity.
The report shows that the operation of Glen Canyon Dam has
not had serious adverse effects on the overall river environment
below the dam. The report further shows that a change in the
operation to benefit one aspect of the environment could
adversely affect another. Moreover, changes in the current
operation could adversely affect both power production and water
conservation which would materially reduce the large benefits
realized from the current operation.
The report goes into considerable detail to evaluate in
dollars the benefits of fishing and rafting, aquatic biology and
,
t her environmental aspects, but does not evaluate the benefits
of the primary purposes of Glen Canyon Dam.
The report evidences a great deal of work by a number of
dedicated individuals over a period of four years. It appears
that there is little to be gained by continuing these studies or
starting new studies of the effects of the operation of Glen
Canyon Dam. The data and analysis of the report can be used
together with the annual operating plans to demonstrate that no
ch.nge in the current opeiation of the structure is indicated.

pf A

Thank you

for the opportunity to review and comment on the

I

Sinccerly,

P. 1:1ltz
lnteiistate StunTs Enginfr
;1.1 :11,t1 : IX-

MIKE SULLIVAN
GOvilmos

a es/Ace

November 17, 1987

SWIM:R.11H

I-2

1

CHEYENNE, WYOMING 82002

Dave Wegner
Glen Canyon Environmental Studies Manager
Attention: UC-140
Bureau of Reclamation
Upper Colorado Regional Office
P. O. Box 11568
Salt Lake City, Utah 84147
Dear Mr. Wegner:
In accordance with Regional Director Clifford Barrett's October 7,
1987 letter transmitting a copy of the draft Glen Canyon Environmental
Studies (GCES) Integration Report and the discussion on the draft report
which occurred at the Upper Colorado River Commission's October 22,
1987, meeting in Denver, Colorado, this letter will serve to provide the
State of Wyoming's comments and observations concerning the draft GCES
Integration Report. We first wish to Lake this opportunity to thank you
and the four Subteam Leaders for your time and efforts in informing the
Upper Colorado River Commission about the GCES and answering questions
relating to this work.
We found all of the presentations did a
creditable job in summarizing very detailed studies.
We provide the
following
comments concerning the Integration Report for your
consideration and do appreciate the opportunity to review the GCES
Integration Report and provide these comments.
As an initial overall comment on the disposition of the report and
what is understood to be planned for the near-term future as the results
of the GCES, it has come to our attention that the Executive Committee,
consisting of one representative of the five principal agencies who have
conducted these studies and prepared the subject report, intends to
prepare two additional reports for forwarding along with this one, to
the Secretary of the Interior.
It has been learned that 'Si Executive
Committee Report and an Options Report are to be prepared.
Given the
comp] exit i es of t he administ rat ion of t
CO] orado River in
accordance
with t he multi-elemented "Law of the River," the large stake of the
seven Basin States in t he common river resource and in recognition of
the cooperative if
between the seven Basin States and the Bureau of
Reclamation which occur (as one example, we note the activities of the
Stale/Federal Colorado River Management Work Group) as the Annual
Operating Plan for the Colorado River Reservoir is developed and the
operations are monitored and revised, if necessary, the State of Wyoming
believes that the Executive Committee Report and the Options Report
should he provided to the States for review and comment before they arc
forwarded to the Secretary of Interior. We do not recall being informed
of the fact that these two reports are being prepared for submittal to
the Secretary at the October 22nd Upper Colorado River Commission
meeting.
Again, we wish to state that we think the opportunity to
review and provide input to these two reports, before they are presented
to the Secretary of Interior should be given to the Colorado River Basin
States. We would appreciate a timely response to our request.

111

pave Wegner
rage 2
November 17, 1987

Dave Wegner
Page 3
November 17, 1987

Our review of the report indicates to us that a thorough review of
t he report and appropriate revision should be conducted by the Bureau of
Reclamation with respect to discussion of the "Law of the River" and the
elements of and customary preparation of the Annual Operating Plan,
before this report is delivered to the Secretary of Interior. There are
maly inconsistencies and misstatements made in this report with regard
t o the AOP's and the "Law of the River." We will attempt to point
The report should be more
t hese out in our comments provided below.
For
f actually correct and complete in its citings and references.
instance, contrary to what is stated at page 33 of the report, the
Colorado River Storage Project Act (CkSP Act) does not identify as one
of its objectives the "satisfying l ofj water delivery requirements to
the Lower Basin ..." Further, on page 34, discussion occurs of "Section
6C2 (a) of the CRSP Act," when the discussion should be about Section
The CRBPA was
002 (a) of the Colorado River Basin Project Act of 1968.
passed 12 years after the CRSP Act. There is, of course, no Section 602
(a) in the CRSP Act. We also note that no mention whatsoever is made in
the report to the State/Federal Colorado River Management Work Group
which played a principal role in the development of the Water Year 1988
These are but three examples of the problems we
Annual Operating Plan.
The
note with the factual basis upon which the report is grounded.
report should be thoroughly reviewed again and revised to correct its
many problems.

Thus, within this entire report, the reader has no way to know, unless
there is specific clarification and explanation made, which is noted to
be rather infrequent, as to whether the intention by the words "floods"
and "flood releases" is to a flow level that was exceeded about 16
percent of the time or to a rare historical event.

Throughout the report, the term "flood release" has been used to
define discharges greater than the designated maximum powerplant release
The report is consistent in
of 31,500 cubic feet per second (cfs).
using this term when speaking to releases greater than the designated
maximum powerplant release capacity, except in several instances to be
We understand from the discussion at the Upper
noted herein below.
Colorado River Commission meeting that the reason this term was used
rather than the more explicit term of powerplant bypasses is due to the
fact that the local people in the area around the Glen and Grand Canyons
use the term "floods" and "flood releases" to generically describe
Further, it was
releases from Glen Canyon Dam in excess of 31,500 cfs.
noted that when the river outlet works, with capacity of about 15,000
are used, they are generally used to the extent of most of their
( aparity so that releases then occurring (due to both the power plant and
t he river outlet works) are in the range of 40,000 to 46,5(X) cfs.
We would certainly prefer to see the term "powerplant bypasses"
lowd rather than "flood releases," because we feel it is more accurate,
,
in our view, is not an emotive term having the same
ill s(riptive and,
negative connotation that the word "flood" automatically has associated
This is a subtle but nonetheless very real point as one reads
with it.
It also takes away any possibility of
Itie text in its entirety.
generically distinguishing powerplant bypass releases from true historic
flood flows in the past, thus lumping into the same group extremely
rare, very high flow rates with flows that occurred rather commonly.
for the
For instance, with respect to the pre-dam period (1922-1962,
purposes of this study), the text at page D-15 notes that "Imjean daily
flows in excess of 80,000 cubic feet per second (cfs) were not uncommon
and were occasionally as high as 100,000 cfs . . . Average daily flows
greater than 30,000 cfs occurred about 18 percent of the time ..."

For instance, the "Summary and Principal Conclusions" section of
the report refers to the flood releases of 1983 in its fourth paragraph
(wherein the Glen Canyon release on June 29, 1983 was about 92,000 cfs
and inflow to Lake Powell peaked at 116,000 cfs on June 28, 1983) and in
its fifth paragraph immediately below speaks to the effect of "frequent
flood releases" on the environment due to the erosion of sand deposits.
It would seem to us that the word "flood" just gets worn out in this
report and comes to have only a very blurred meaning.
Given the
thorough scientific foundation upon which this integration report rests,
it seems less than proper and very undesirable to have important
distinctions like the difference between 90,000 cfs and 31,500 cfs
releases lost in this report so that the word usage (perhaps even
characterized as slang) of people living near the Canyons area can be
accommodated in this report.
We would be pleased to discuss this
comment at more length and elaborate on our thinking if you so desire.
As concerns "flood releases," we note that the statement is made
several times in this report that "under current operations, flood
releases will occur in about one of every four years." Further, but
intensive, reading of the report plus some clarification provided at the
October 22nd Upper Colorado River Commission meeting, indicates that
this statement is extremely misleading. While the report does recognize
that the GCES "occurred at a critical juncture in the 'life history' of
Glen Canyon Dam, when significant releases above powerplant were
occurring with regularity for the first time," we believe that a very
poor decision was made in characterizing the "current operations" as
being based on Water Years 1983 through 1986 and deriving a "flood
release" return period of 1 in 4 years based on those four years of
data.
As even a perfunctory evaluation based on the full period of
record will demonstrate, the actual return period for releases greater
than powerplant capacity is more like once each 25 years.
Because much of the report is devoted to the effects of these
"flood releases" on the river environment, the importance of this one
repeated mischaracterization cannot be overemphasized. The report
should be rewritten to deal with the fact that Water Years 1983 through
1986 are the highest four years of recorded Colorado River flows since
the Colorado River Compact of 1922 was signed.
We further point out
that the three 4-year periods of highest natural flow were, in order of
magnitude, 1983-1986, 1982-1985 and 1920-1923, based on estimates of the
natural Colorado River flow from present back to 1906.
The four-year
period of 1920-1923 reflects a volume of almost 10 million acre-feet
less than 1983-1986. Other studies have documented that the probability
that the flow experienced during Water Years 1983-1986, the study
period, will again be equaled or exceeded is extremely small, such that
a return period of well in excess of 100 years can be calculated. These
facts have not been given their due consideration in the GCES approach
and their write-up in this report.
It seems clear that revision of the
report with regard to these areas is definitely warranted.
The 1 in 4
year return period just isn't so.

Dave Wegner
Page 4
November 17, 1987

Dave Wegner
Page 5
November 17, 1987

With regard to the discussion of the functions of Lake Powell at
the bottom of page 9, and specifically the mention of the Mexican Treaty
(second line from the bottom of page 9), we comment that the Upper

but, as we state immediately above, the term "Division" would be
directly in accordance with the terms and definitions provided in the
Colorado River Compact and hence would be more appropriate in the first
three places in this paragraph.

Division States do not concur with the Bureau of Reclamation's
statements as to the obligations of the Upper Division States to deliver
It is the position of
water to satisfy the Mexican Treaty requirement.
t he Upper Division States that with the delivery of 75 million acre-feet
of water in each period of ten consecutive years at Lee Ferry, the water

supply is sufficient to meet the apportionments to the Lower Basin
provided for in Article 111(a) and 111(b) of the Colorado River Compact

The position of the Upper
and the entire Mexican Treaty obligation.
Division States should be noted in the text of the report at this point,
or alternatively, the sentence should be rewritten to avoid specific
mention of the Treaty by reference to the "Law of the River" or in some
The word "dam" should be capitalized in the
other general manner.

second line from the bottom of page 9 also.

At page 31, the fourth line of the third paragraph should state
that the combined discharge capacity of the eight turbines is
This is evidently a
approximately "33,100" cfs, not "31,500" cfs.
As noted at page 0-25, the powerplant can release
typographical error.
a maximum of 33.200 cfs at a water storage elevation of 3,700 ft and
31.100 cfs at an elevation of 3,693 ft or below. An operational cap has
been placed on the releases as is explained in the text on pages 31 and
0-25.
In the fourth paragraph of page 31, it is indicated in the seventh
line that the combined powerplant and river outlet release can reach
48,500 cfs, however the figures given above add to only 48,100 cfs.

We note that the discussion of the objectives of the CRSP Act at
of page 33 with respect to the Act listing the satisfying of
water delivery requirements under the Colorado River Compact as one of
Section 1 of the
t he identified objectives of the Act is incorrect.
CRSP Act, 70 Stat. 105, sets forth the purposes of the Act and does not
sentence
of
page
33 as item (2) as
list what is identified in the first
This paragraph should he rewritten.
A
one of the Act's purposes.
romment along these same lines concerns the first sentence at the top of
po 34, wherein the text states that "Section 602(a)" is in the CkSP
The text has confused the CRSP Act
This is of course not true.
Ait.
And the Colorado River Basin Project Art of September 30, 1968, Public
! w 90-537.
The point is again made that a hard review of the sections
t he top

iI the report dealing with the statutes would seem to be in order.
Ii VII) t he importance of the compacts, laws and decrees governing the
C•ilorildo River and the delicate balance which these "rules" maintain, it
in particularly important that these be accurately described and
r epresented in a report of this type.

For the sake of accuracy, it is suggested that the word "Division"
he substituted for "Basin" in the second paragraph on page 33 in the
In the second
first three instances in which the word "Basin" appears.
t o last line of that paragraph, the usage of "Basin" is appropriate,

With regard to the paragraph on page 34 which addresses the
objectives of avoiding [anticipated] spills as found in Article 11 (3)
(c) of the "Criteria for Long-Range Operation of Colorado River
Reservoirs" (the Operating Criteria), we note that the term "spills" is
We comment that
defined in Article IV (a) of the Operating Criteria.
the language in the paragraph is not a good paraphrasing of Article IV
(c), in that this paragraph speaks only to powerplant bypasses as
opposed to water releases which "cannot be utilized for project
purposes, including, but not limited to, the generation of power and
energy." The discussion in the third paragraph on page 34 has
The fact
oversimplified the objective of avoiding anticipated spills.
that the decision as to water releases is tied to the 602(a) storage
determination by the Secretary within the context of the annual
operating plan process is not acknowledged in this paragraph. The words
"at any time" and "later" appearing in this paragraph strike us as not
recognizing the fact that the Operating Criteria specifically provides
several objectives which must all be considered and weighed in making
release decisions, nor do they recognize the language of Article Ii (4)
relating to the retention of storage in Lake Powell to avoid bypass of
water for subsequent release as soon as practicable to equalize Lake
Powell and Lake Mead storage. We would suggest redrafting this
paragraph to point out the several factors which are integral to meeting
the objective of avoiding anticipated spills, and believe that in so
doing this will correctly advise the reader that releases cannot be
increased "at any time" but, rather, that the decision to increase
releases is conditional upon other objectives, such as that the water
can be reasonably applied to Article III(e) uses, etc., being met as
well.
On page 35,. the third paragraph states that "Glen Canyon Dam has
not been used significantly for river regulation ..." What is meant by
This sentence is not consistent with the discussion on
this statement?
page 34 as to the contributions of Lake Powell towards meeting the 8.23
million acre-foot minimum objective release, nor is it consistent with
the text found at the top of page 33 which summarizes the purposes of
the CRSP Act.
It appears to us that the elevation figure of 3,648 feet found in
the first full paragraph at the top of page 36 is a typographical error.
The reservoir elevation at which 22.6 million acre-feet of water
(useable storage) is in storage is understood to be 3,684.605 feet. The
elevation figure of 3,648 feet is the permanent spillway crest and
corresponds to about 17,530,000 acre-feet of live storage or 19,530,000
acre-feet of total storage.
Our next comment is offered on page 0-8.
In the seventh line of
the second paragraph on page 0-8, the word "Lees" should correctly be

"Lee."
The Compact point is Lee Ferry while the closest gaging station
to the point is Lees Ferry, which is about seven miles above Lee Ferry.

Dave Wegner
Page 6
November 17, 1987

In Table 8-2, found on page 8-12, the column "Energy" has the unit
of kilowatts immediately below the column title.
It is noted that
kilowatts is a measure of power as opposed to energy and that the
correct unit should be kilowatt-hours.
On page 8-17 is found Table D-3.
The first column of the table
attempts to show the period of time during which the Operating Criteria
and the Filling Criteria have been in place on the river.
This first
column is not correct. The Operating Criteria was not promulgated until
June 4, 1970.
The Filling Criteria were approved on April 2, 1962 and
were terminated prior to the date shown in the first column of this

On page 8-19, mention is made in the first paragraph (which begins
on the previous page) of the agreement as to the annual January 1st
storage target in Lake Powell.
We would comment that this agreement •be
referred to as a general agreement rather than an informal one.
We
should note that the agreement is set out in writing in a May 13, 1983
letter from Cliff Barrett to the Executive Director of the Upper
Colorado River Commission.
A typographical error is noted as to the spelling of the word
"ascending" in the first line of the fourth paragraph on page 8-27.
Concerning the definition of "flood" on page 4 of the Glossary, we
have previously commented at length on the use of this wording
throughout the report.
We feel that the definition provided hereat
points out additional reasoning as to why release in excess of
powerplant capacity should be called Just that.
On page 7 of the Glossary, the definition provided for "Lower
Basin" actually describes the "Lower Division"; or "States of the Lower
Division" as defined in Article 11 of the Colorado River Compact.
The definition of "surplus water release" provided on page 12 of
t he Glossary is extremely poor and should be revised.
Consideration of
t he meaning of the term within the various documents comprising the "Law
of the River," and the fact that the word has different meaning
depending on which document is being studied, dictates that a "tighter"
definition be provided herein.
The definition provided should
definitely state that the definition being provided is only to mean and
he used within the context of this report.
This is an important point
because of the sensitivities and importance of the term within the
Colorado River Basin.
The definition of "Upper Basin" found on page 13 of the Glossary in
actuality is more correctly that for the "Upper Division" as defined in
Article 11 of the Colorado River Compact.
That article provides a
definition for "Upper Basin" and "Lower Basin" which could appropriately
he used in this report.
We again call to your attention that the report does not take into
account the work of the State/Federal Colorado River Management Work
Group which has implemented a process for developing annual operating
plans for the Colorado River reservoirs. By its very charter - that is,

Dave Wegner
Page 7
November 17, 1987

a primary purpose for which the Work Group was initiated -- the Work
Group is working to minimize the risk of powerplant bypasses.
It will
be recalled that in documents sent out by the Secretary of Interior
explaining the Water Year 1988 Annual Operating Plan that was agreed to
by Reclamation and representatives of the seven Colorado River Basin
States, the AOP analysis stated that the probability that releases will
exceed the Glen Canyon powerplant capacity is in excess of 1 in 25
years, or less than a four percent chance. A four percent chance is, of
course, well within the range that the draft report suggests would be an
acceptable "flood" frequency and is, of course, much smaller than the
twenty-five percent chance which this report misstates with its 1 in 4
year figure.
We think a very strong argument can be made that the current
process for developing annual operating plans, involving the Colorado
River Management Work Group, will continue in future years to minimize
the risk of powerplant bypasses - or "flood releases" as they have been
termed in this draft report.
The report should be rewritten to
acknowledge the efforts, both this year and the anticipated continuance
of the Work Group, to prevent powerplant bypasses.
We believe that
there is no need to continue these or pursue additional studies or to
attempt to suggest operational changes at Glen Canyon Dam.
According to the report, one of the prime motivating factors for
initiating these studies was the public concern expressed about
fluctuation of the releases from Glen Canyon Dam.
We note the report
states that this public concern was raised in connection with, or was
focused by, the Uprate and Rewind Program, per page 11 of the report.
At page 74, the draft report states as a conclusion on this issue that
the impacts of increasing the powerplant capacity to 33,100 cfs "cannot
be assessed at this time." We are somewhat concerned that a more
definitive conclusion cannot be drawn on one of the main questions posed
in these studies, which have occurred over a 5-year period and have
involved many studies, many researchers and many dollars. It would seem
that further studies are not warranted to try to answer a question about
a 5 percent change in powerplant capacity if it could not be answered
given the very large expenditures of time and money that have occurred
to date.
The above constitute our specific comments on the report.
We have
not found any items in Appendices A, B and C which merit repeating
previously-made comments on here, although we have read over those
sections of the report as well.
With respect to comments on the report
in general, we offer the following thoughts for your consideration.
The report seems to be indicating that the operating plan for Water
Year 1988, as recently agreed upon by the Seven Basin States and the
Bureau of Reclamation, provides the best mix of acceptable uses and
releases to best protect the "critical Canyon resources."
We note
that the implication stated in the report is that the risk of
anticipated spills must be kept very low in order to protect and
maintain the Canyon's resources, particularly with respect to sediment
transport and disposition. The Water Year 1988 Annual Operating Plan has
set forth a means of operating the reservoir system which provides a

Dave Wegner
Page 8
November 17, 1987

NOV 2 0 1987

*MAU

117:77'm

probability determined to be in excess of 1 in 25 that a spill might
occur. The present operating plan thus meets the principal
recommendation embodied in the study's results, and hence should be
We see little to be gained by continuing
supported in future years.
We believe that this
these GCES studies or initiating others.
conclusion should be clearly made known as this document is revised and
f orwarded to the Department of Interior.
Thank you for the opportunity to review and comment on the Glen
Canyon Environmental Studies Draft Report. We wish to note that we have
been involved with, and hence concur with, the comment letter provided
to you by the staff of the Upper Colorado River Commission, as signed by
Gerald R. Zimmerman. That letter, like this one, raises many
substantive points and issues which need to be properly addressed in
We look forward to an early response from Reclamation
this report.
concerning the Executive Committee Report and Options Report and what
Please
the States' role may be in the preparation with those reports.
do not hesitate to contact me if I may answer any questions or provide
clarification of the points made herein.
With best regards,

JOHN W. SHIELDS
Water Resources Engineer
JWS/11w
cc: Gerald R. Zimmerman
Executive Director
Upper Colorado River Commission
355 South Fourth St.
Salt Lake City, Utah 84111
J. William McDonald
Director
Colorado Water Conservation Board
721 State Centennial Building
1 313 Sherman St.
Denver, Colorado 80203
Stephen E. Reynolds
State Engineer and Secretary,
New Mexico Interstate Stream Commission
Bataan Memorial Building
Santa Fe, New Mexico 87503
D. Larry Anderson
Director
Division of Water Resources
1 636 West North Temple
Salt Lake City, Utah 84116

UPPER COLORADO RIVER COMMIS I
.3

T South Fourth Eau Strect

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Sal, Lakt Coy. Utah 84t 1 1

November 20, 1987

•

I"Mal

1111

Mr. Clifford I. Barrett
Regional Director
Upper Colorado Region
U. S. Bureau of Reclamation
P. 0. Box 11568
Salt Lake City, Utah 84147

/41
/ fc

got

Dear Cliff:
The Upper Colorado River Commission has reviewed the Bureau of
Reclamation's "Glen Canyon Environmental Studies Draft Report" (draft
report) dated September 1987. Because of the short time period
allowed to provide comments and because the technical reports that
provide the supportive data and information are not available for
review, the Commission's comments will be general in nature and
confined to the "Summary and Principal Conclusions" and the "Draft
Report" sections of the draft report. The lack of detailed specific
comments on the draft report should not be construed as agreement
with the technical information or conclusions presented in the draft
report.
The Upper Colorado River Commission finds that the Glen Canyon
Environmental Studies draft report:
(I) contains numerous inaccuracies concerning the "Law
of the River" as well as other errors;
(2)
has looked at the operation of Glen Canyon Dam
as it may impact selected environmental resources but has
failed to recognize the present environmental and other
multi-purpose benefits that have been and are being received
from the current operation of Glen Canyon Dam;
(3)
does not take into
Federal/State Colorado River
implement new approaches for
plans for the Colorado River

account efforts by the
Management Work Group to
developing annual operating
reservoirs; and

(4)
does not present evidence that the operation of
Glen Canyon Dam should be changed.

Mr. Clifford I. Barrett
November 20, 1987
Page Two

Mr. Clifford I. Barrett
November 20, 1987
Page Three

The draft report should be thoroughly reviewed in-house by
Bureau of Reclamation personnel who are familiar with the "Law of
the River" and the operations of the Colorado River. Through such
a review misused and misquoted references to the "Law of the River"
and other glaring errors should be found and corrected.

The Commission understands that an Executive Review Committee
is reviewing the draft report, comments received on the draft report,
the report prepared by the National Academy of Sciences, and other
material related to the Glen Canyon Environmental Studies. Based on
its review, the Executive Review Committee will prepare reports and
recommendations for transmittal to the Secretary of the Interior.
The Upper Colorado River Commission appreciates the opportunity to
comment on the Glen Canyon Environmental Studies Draft Report and
trusts that its comments will be considered by the Executive Review
Committee. Also, the Commission requests that it and the seven
Colorado River Basin States be provided copies of the Executive
Review Committee's reports and recommendations in draft form before
they are transmitted to the Secretary of the Interior.

The draft report does not recognize that due to the construction
and operation of Glen Canyon Dam the white water boating season has
been extended, a trout fishery has been established, a more diverse
ecology has been established in Glen and Grand Canyons, the risk of
extremely low or large discharges has been virtually eliminated, and
the populations of plant and animal species in the canyons have
increased and new species have taken up residence in the study area.
Statements in the draft report that "flood" releases are
expected to occur once every four years under current operations
(a twenty-five percent chance of occurrence) are incorrect. Under
the Water Year 1988 Annual Operating Plan that was agreed to by
representatives of the seven Colorado River Basin States and released
by the Secretary of the Department of the Interior on October 1,
1987, the probability that releases from Glen Canyon Dam will exceed
the power plant capacity is less than one in twenty-five years, or a
four percent chance of exceedence. A four percent annual chance of
bypassing the Glen Canyon power plant is considerably less than the
twenty-five percent annual chance of occurrence referred to in the
draft report and is well within the range that the draft report
suggests would be an acceptable "flood" frequency.
Modifying the operation at Glen Canyon Dam to enhance selected
recreational or environmental resources could adversely affect the
continued existence of the endangered humpback chub and may be nonbeneficial to other critical recreational and environmental resources
in Glen and Grand Canyons. Modifying the operation of Glen Canyon
Rim definitely would have adverse effects on the primary benefits for
which the Dam was authorized and constructed.
The current annual operating plan for the Colorado River reservoirs developed by the Federal/State Colorado River Management Work
Group adequately balances the primary and incidental benefits of
Glen Canyon Dam. Given the existing process for preparing annual
operating plans and based on the comments contained herein and the
results of the draft study, it is not necessary for the Secretary of
t he Interior to conduct any further studies or environmental assessments to evaluate additional management options or to study the
impacts of alternative reservoir operating scenarios at Glen Canyon
Dam as suggested in the draft report.

Very truly yours,

Gerald R. Zimmerman
Executive Director
cc: Mr. Dave Wegner
Glen Canyon Environmental Studies Manager

Gies CONOR

OF UTAH

4

SlATE
NATURAL RESOURCES
Water Resources

1111.,1)
44

ERVitoafiniutal SWAIN

Norman H Bangerter, Governor
Dee C Hansen. Executive Ditector
D tarry Anderson, Division Director

1Ct• West North lumple • Suite 310 • Solt Lake City Ul 8411o•3156 801-5335401

ner
Mr.
Dave 9,Weg1987
November
Pa ge 2

November 9, 1987
Mr. Dave Wegner
Glen Canyon Environmental Studies Mana ger
Pos.. Office Box 11568
Salt Lake City, Utah 84147

01.4x)

onstructea.
. F

(.1/

Dave:

We appreciate
the time and effort expended by you and your team leaders
in presentin
g the back
rn
44..6
Your
explanations
answered
a number of
questions that puzzled us as we reviewed the September 1987 draft report.
you stated in the meeting, the study was initiated by Secretary of
InteriorAs Watt
in 1983 to: (1) Quantification of impacts of Glen Canyon Dam on
downstream
environmental
uses (ex. white water rafting, trout fishin g, Hump
Back
(hub, riparian habitat etc.), and (2) identify if operational chan
ges in
releases
from the dam can increase the benefits of the environmental uses.
You_c; as'zed I- re..rt was not a proposal for operational chan es,
it'llrfflTikidowe
it is always useful to haveg ob ec ive
information on operationa mitsSince
to
potential
benefits, the information
aeveloped in the study will be helpful in the preparation
of future
operational plans on the Colorado River.
It should be stressed, though, that the Criteria for Coordinated Lon gRan ge Operation
of Color
rvoirs commonl referred to as the
"Olqr'.!in2.1
e
staLLs tnat "The plan of operation...shall reflect appropriateArtic
consideration
rof use-,t of tne reservoirs for all purposes, including.. .water quality control,

v
10
.eve olen
the Calaraain
Thank
ver
.
you again for your presentations, and the opportunity to review e draft
study.
Thank you,

1416

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we have not had an opportunity to review any of the background
stuai,sSince
(41
separate
which formed the basis of the draft report, we
cannot comment on tnereports)
technical
adequacy of the study. The conclusion in the
GOES
draft
report
that
individual
features
can be enhanced by
modifying tne dam release pattern environmental
is
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Steven Reynolds
Jeff Fassett
Alan Kleinman
Dennis
Underwood
Jack Stonehocker
Don Christiansen
Mike Christensen

•

MINGANYONuNa
CRISP

JOHN J. RHODES III

COMMITTEE ON INTERIOR
AND INSULAR AFFAIRS

1.7 DemaiCT Astucw.

Of MIS
610 Cmr.o. Hew. 0.,K

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Wmmixcio. DC 20516
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alagbington, OE 20515

CHAIRMAN. REPUBLICAN TASK FORCE
ON INDIAN AFFAIRS

OW!oGICAI SURVEY
RES I ON, VA 22092

FEIGN' AND IHE ENVIRONMENT
NATIONAL PARKS AND
PUBLIC LANDS
MITTEF ON SMALL BUSINESS
W.0mm/MF.

NOVEMBER 6, 1987

United States Department of the Interior

SEAscommirrtts

WATER AND POWER RESOURCES

PR CUREMENT. INNOVATION AND
M114Opi, ENTERPRISE DEVELOPMENT

In Reply Refer To:
WGS-Mail Stop 423

e

A141 110051 IMPACT OF DEREGULATION

CT, AND PRIVATIZATION
.

MR. CLIFF BARRETT
REGIONAL DIRECTOR
BUREAU OF RECLAMATION
UPPER COLORADO REGIONAL OFFICE
P.O.BOX 11568
SALT LAKE CITY, UTAH 84147

•
REPEIBLICAN POLICY COMMITTEE

DEAR MR. BARRETT:

Om Gaon
Eaviroaraeall Stlidles

;

30

Memorandum
To:

Glen Canyon Environmental Studies Manager,
Salt Lake City, Utah

From:

Assistant Director for Engineering Geology

Subject:

Review of draft technical report/environmental studies for Glen
Canyon, Utah

THANK YOU FOR SENDING ME A COPY OF THE DRAFT GLEN CANYON
ENVIRONMENTAL STUDIES (GCES) INTEGRATION REPORT.

We have reviewed the report as requested in your letter included in the document
dated September 1987.

GIVEN THE EXTENSIVE VOLUME OF THE REPORT AND THE SEVERAL
YEARS CONSUMED IN ITS PREPARATION, IT SEEMS TO ME THE APPARENT
DEADLINE OF NOVEMBER 13, 1987 FOR SUBMISSION OF PUBLIC COMMENTS
IS RATHER SHORT.

We found that a large amount of scientific work was accomplished despite unanticipated extremely high flows during the study period. The study team responded
by shifting the primary focus of the investigation from the analysis of impacts due
to peaking power operations to an assessment of the effects of large floods. These
large flows made possible the collection of some very valuable information, but
limited that which could be analyzed for more typical floods.

I WOULD APPRECIATE YOUR CONSIDERATION OF EXTENDING THE
COMMENT PERIOD DEADLINE BY AT LEAST THIRTY (30) DAYS TO PROVIDE
ALL INTERESTED PARTIES ADEQUATE TIME TO REVIEW AND ASSIMILATE THE
INFORMATION IN THE DOCUMENT AND SUBMIT COGENT COMMENTS.
THANK YOU FOR YOUR CONSIDERATION.
SINCERELY,

. RHODES, III
MEMBER of CONGRESS

JJR:JH

The report reaches a valid conclusion that frequent large "flood" releases of
sediment-free water will cause significant erosion of a substantial portion of the
sand deposits in the canyon. The data are not complete or accurate enough,
however, to precisely define how large and/or how frequent the floods can be
before a net loss of sand from the canyon occurs.
The principal conclusion that frequent flood releases (greater than 31,500 ft 3/s) will
cause significant and irreversible degradation of the environment by eroding a
substantial portion of the sand deposits does not appear to be supported by the
evidence presented. Furthermore, the principal conclusion that "even a frequency
as low as one flood in 20 years will produce a net long-term loss of camping beaches
and substrate" seems highly unlikely.
With the respect to sand transport, the report correctly implies that the long-term
fate of the sand-based resources in the canyon depends largely on the difference
between the supply of sand to the canyon and the loss of sand from the system. The
current supply is almost entirely from the tributaries which is estimated to be about
3.6 MT/year (2.9 MT from the three major tributaries, and 0.7 MT/year for the 310
ungaged tributaries, pages A28-A30). This estimate is extremely tenuous, however,
as indicated on pages A28 and A30. The supply may even be changing with time
because of climate shifts or other factors (page 27). At any rate, however, the
supply is independent of release rates.

3
The sand supplied to the canyon is transported out of the canyon by the flow and
the transport rate of sand increases rapidly with increasing flow so that large
flows transport the bulk of the sand. Because truly large flows (greater than
100,000 ft 3/s) have been eliminated, the ability of the river to transport the reduced
supply of sand out of the canyon has been greatly reduced. On page A43, the
report correctly states that the rate of sand loss is affected by the magnitude,
duration, and frequency of floods but it also states that our present knowledge is
not sufficient to define the relative importance of the factors to sand loss. On page
59, the report states that they have "very little idea of how the system responds to a
given frequency of floods."
The principal conclusion that flood releases (greater than 31,500 ft 3/s no matter
how short in duration) even as infrequent as once every 20 years will cause significant and irreversible degradation of the environment by eroding a substantial
portion of the sand deposits is counter to almost all available evidence. The conclusion in effect says that a release of 31,600 ft 3/s for even 1 day every 20 years will.
transport more sand out of the system than has been supplied by the tributaries
during that time. Evidence to the contrary is summarized below:
Page A19 -

Page

A26 -

Page A31 -

Page

A32 -

Fluctuating flows with peaks below 31,500 ft 3/s for annual volumes of
8.2 million acre-feet ,transport only 12 percent more sand than a study
flow of 12,000 ft 3/s.
The STAB model indicated a net sand loss of only 6.6 MT (a 1.8 year
supply) as a result of floods in 1984 and 1985. These were flows of
nearly 50,000 ft 3/s for 3 1/2 to 4 months.
Figure A9 shows that although the huge flood of 1983 (97,200 ft 3/s,
for 2 1/2 months) eroded the bed significantly, the floods of 1984 and
1985 had little effect on the bed elevation.
"Sediment transport modeling and analysis of data from gaging
stations demonstrate that flows less than maximum power plant
releases (31,500 11 3/s) are not capable of transporting all the sand
delivered annually from tributaries unless annual volumes exceed
12 maf." The mean annual volume is 11.3 maf.

Page A42- The huge flood of 1983 did not cause consistent erosion throughout
the canyon "Some sand deposits did aggrade in 1983.' "The area of
sand exposed at low discharge increased at many sites in the reach
from River Mlle 122 to River Mile 160 between 1973 and 1984 (Schmidt
and Graf, 1987) " (page A44) "Vertical aggradation of channel
margin deposits was reported by Beus and others (1985)." (page A44)
Page

A51 -

"Estimates made with the STAB model suggest that sand storage in the
main channel pools will increase under current operations (floods of
40,000 to 50,000 ft 3/s for about 6 weeks about once every 4 years) and
average annual tributary delivery of sand. Aggradation is predicted
because the degradation associated with the short periods of flood
releases which occur once every fourth year is more than balanced by
the aggradation during the low-release years."

Page 455- The STAB model estimates suggest that flow releases of

33,100 ft 3/s

for 2 months each year will be incapable of removing the sand supplied
by the tributaries.
It is agreed the frequent large releases will cause a net loss of sand but the size,
duration, and frequency of releases which will result in a stable sand budget is
hi9hly uncertain. The limited evidence available suggest that current operating procedures would result in approximate balance, however, and that
limiting the flows to 31,500 would cause gradual aggradation. In light of the
limited evidence, the following statements should be modified:
Page 81 -

"Even infrequent floods cause loss of camping beaches and vegetation
substrate, and it appears that this loss is irreversible."

Page 82 -

It has not been clearly established that eliminating flood (Q >
releases wil reduce impacts.

Page A19 -

"Frequent flows higher than 31,500 ft 3/s will severely deplete sand"
should be modified to read "Frequent flows significantly higher than

31,500)

31,500 ft 3/s ..."

In regard to the loss of camping beaches and substrate, the argument is made
on pages 59, 60, and A43 that because the flood of 1983 occurred after a period of
20 years with no floods that floods even as infrequently as once every 20 years will
cause severe losses of sand. This argument is carried over in the Principal Conclusion
that "Current knowledge indicates that even a frequency as low as one flood in 20
years will produce a net long-term loss of camping beaches and substrate although
at a rate reduced from current operations."
We do not believe these conclusions can be substantiated since the 1983 flood was
an extreme event with a discharge three times larger than the report's definition of
a flood. The data in figure A9 indicates that even this extreme flood was capable
only of removing the sand which had accumulated during the preceding 18 years.
The Principal Conclusion should be modified to emphasize that only one "extreme"
flood can be tolerated every 20 years and not imply that a flood of 31,600 ft 3/s
every 20 years will cause irreversible losses.
There are a number of inconsistencies in the report which should be corrected. They
are as follows:
Pages?, 11,43, and 18.
The report defines a flood as any instantaneous release in excess of 31,500 ft3/s
(page 2 of the Summary and Principal Conclusions, and pages 11 and 43), but also
defines it as a release of 40,000 ft 3/s or greater for a month or more (page 418). A
consistent definition should be used throughout the report.
Page

15 -

Top of page, text is missing.

Page

59 -

The report states the 1983 flood occurred after 20 years with no
floods, yet on page 12 the report states, floods occurred in 5 of the
last 7 years (report ends in 1986), so at least two floods would have
had to occurred before 1984. This reduces the frequency from flood
in 20 years to one flood in 10 years, for example.

4

Department of Energy

Page 61 -

Refers to this chapter and a previous chapter, but the report does
not have chapters—it has sections

Page 62 -

The last sentence on page 62 should be clarified.

Page 72 -

The discussion on page 72 refers to a flow release pattern shown in
Figure VII-6 but no such information is provided in Figure VII-6.

Page Al5 -

The report discusses the location of a gaging station in Figure Al as
being near Bright Angel Creek but Figure Al does not show Bright
Angel Creek.

mA James F. Devine
Copy to District Chief, WRD, Salt Lake City, Utah

Western Area Power Administration
Salt Lake City Area Office
P.O. Box 11606
Salt Lake City, UT 84147

SEP 0 9 ;967

Mr. Clifford I. Barrett
Regional Director
United States Bureau of Reclamation
ATTN: Mr. Harold Sersland
P.O. Box 11568
Salt Lake City, UT 84147
Dear Mr. Barrett:
Enclosed are comments on the August 1987 preview copy of the Glen Canyon
Environmental Studies (GCES) Draft Technical Integration Report, as requested
In your letter dated August 15, 1987. In general, this draft report is much
improved from the earlier versions. The writing is more clear and concise,
and the document is much better focused. Presentation and organization also
appear to be improved from the earlier documents.
Western Area Power Administration (Western) offers the following comments
based on a review of the August 1987 draft of the Technical Report.
Western disagrees with the baseline selected and the approach to the study.
The study uses a hypothetical situation of ideal conditions for white-water
rafting and trout fishing as a baseline for the determination of impacts
resulting from the present operations of Glen Canyon Dam. Any situation of
less-than-optimal conditions for these recreation interests is considered an
'Impact" by the study. The study then proceeds to justify the optimization of
these recreation interests based on the "impacts" identified.
Western has a number of concerns related to this approach. In the usual
environmental impact analysis, a hypothetical optimum cannot be used as a
baseline. It is recognized that this was not and is not a National
Environmental Policy Act (NEPA) analysis. However, it is clearly more of a
recreation resource optimization plan than an environmental study. Western
feels that the document should reflect this. The study should outline present
operations as part of the existing baseline situation, then examine changes
that could be made to this baseline condition to enhance the recreation
resources.
As discussed in the report, the construction of Glen Canyon Dam produced the
cold, clear water that allowed the trout fishery to flourish. The moderated
and regulated flow regime also allowed the development of white-water rafting
and day float trips. All of these recreation resources are of extremely high

Celebrating the

U.S

Constitution Bicentennial

— 1787-1987

3
2
quality, as shown in the Technical Report. In its present format, the study
struggles to identify "impacts" attributed to the very conditions that formed
the resources in the first place. Western feels the approach aescribed above,
essentially a straightforward optimization plan, would greatly reduce the
confusion introduced by the idealized baseline and relationship of the dam to
the recreation resources.
For similar reasons, the term "impact" as used in the study is inappropriate. "Impact" is a term loaded with NEPA meaning--it is nearly impossible
to use the word disassociated from these NEPA connotations. Because of the
relationship of Glen Canyon Dam and its operations to the resources in
question, "impact" cannot properly be used to describe any effects present
operations would have on an idealized optimal recreation resource. The
approach advocated by Western would resolve this problem by the change in
perspective.
A major objective of the GCES is to quantify the existing baseline conditions
and to identify parameters that could be potentially modified to enhance the
recreation resources. It it Western's understanding that the GCES were
intended to provide enough information to the Secretary of the Interior so
that he could make a decision whether or not the possibility of modifying
present Glen Canyon operations for recreation and environmental preservation
should be pursued. The benefits that could be derived from a change in
operations have not been sufficiently quantified in the draft report to
adequately serve this purpose.
Specific remarks on the text of the draft integration report are enclosed.
We appreciate the opportunity to consider this preview copy and to provide
these comments. It is my understanding that our comments, and comments from
other involved agencies, will be compiled and distributed to the Executive
Committee members prior to general distribution of the draft integration
report.
A list of Colorado River Storage Project preference customer representatives
who should receive a copy of the draft integration report is also enclosed, as
requested.
Sincerely,

'‘.-

2 Enclosures

Marlene A. Moody
Deputy Area Manager

(

bc:
S. Earley, A0207, Golden, CO
W. Jamison, A0400, Golden, CO
G. Frey, A0420, Golden, CO
J. Hall, A6000, Golden, CO
R. Fullerton, A6100, Golden, CO
G. Greeny, A6300, Golden, CO
(ea. w/copy of enclsures)
bcc:
10000
10600
122
L2 I I
, • 300 (w/copy of enclosures and incoming letter)
L1007 RF(2), OF
16300:JMcCoy:jw:x5399:09/08/87
Final:09/09/87:dw
PMO/JAMPC00038

Page

Comments
Western was a contributor to the report, however was not credited as
such. In fact, major portions of Appendix D regarding CRSP operations
were initially generated by Western personnel.

vi

Page
1

2nd paragraph. 1st sentence. Define 'adverse" or delete.

3rd paragraph 2nd question. The phrase, '..consistent w/ Colorado River
Storage (CRSP) water delivery requirements.." would seem to require
'greatest practicable amount of power and energy . . .'. See Section 7
of CRSP Act.
The second question to be answered by the studies is really the focus
of the effort. Western believes the first question is based on a
faulty premise; i.e., that existing operations can affect conditions
created by the same operations. In addition, the first question is
redundant; all that is needed is to establish the proper baseline
condition, then proceed to answer the second question. The Technical
Report seems to require some 'impact' to justify proposing the
possibility of altering operations. As noted in the letter, Western
believes a better approach would be to identify how much the
environmental resources could be improved, what the benefits would be,
and through what means such improvements would be accomplished. The
effects of implementing any recommended changes have been termed
outside the scope of the GOES, so a similar commitment to investigate
the effects of any proposed changes would be necessary.

This page contains a discussion of study goals including the position
that existing operations impact existing conditions. As discussed in
the letter, Western feels that existing operations cannot affect the
resources they created and the term 'impact" is inappropriate.
vii

Coments

1st summary block. Conclusion of 'substantial adverse effects' is not
consistent w/ text in 1st paragraph. Also, contradictory to later
statements that rafting is better with the dam than without the dam.
Last paragraph. 1st sentence. Define 'frequent" in reference to flood
releases.
Western believes that the discussion on this page should be more
oriented toward identifying components of the existing environment that
could be manipulated to optimize the recreational resources of
concern. The preoccupation with 'impact" is unnecessary given the
intent of the GOES. As previously pointed out, Western does not agree
with the definition of "impact" as it is used in this report. The
institution of regulated flows from Glen Canyon Dam did not impact
existing rafting or trout fishing; if it had, then the approach used in
the Technical Report would be correct. Instead, the regulated flows
created the resources and the studies merely seek to optimize them.

vii

1st paragraph. 3rd sentence. General note: Western echos this
recommendation that flood releases be avoided, if possible.

General comment: The environment assessed is site-specific to the
river-related environment of the Glen Canyon and Grand Canyon. Though
assessment of regional or national environmental impacts is well beyond
the scope of this study, to provide a proper perspective it should be
stated in the introduction that consideration of modifying operations
to reduce or eliminate fluctuating flows would have a most definite and
adverse impact on the ability to utilize the full Glen Canyon installed
capability. Such a change might result in the need by power customers
to replace the unavailable capacity with non-hydro (thermal, perhaps)
generation. Replacing a renewable resources with a non-renewable
alternative would most likely have wide-ranging environmental impacts.

viii

2nd summary block. Recreation and aquatic resources? Summary
statement is inconsistent w/ later text in 2nd paragraph, 5th sentence,
regarding deleterious effects on " . . . recreation and aquatic
resources.'

Principal among these impacts might be (1) the impact to air quality,
(2) the depletion of the non-renewable fuel (coal, gas, etc.), and (3)
the economic impact or the impact to the human environment due to the
increased cost of alternative generation, to mention just a few.

2nd paragraph. 3rd sentence. It should be noted that fluctuations
depends on river reach.
Are these recreation "benefits" needed to repay the project?
ix

Benefit noted in 1st paragraph re: ". . . short periods of fluctuations
at other times may increase food availability and trout growth," is a
benefit not reflected in the summary box on the previous page (viii).
1st summary block. General note: The text would provide another
reason to delete "adverse" in the first summary block on page vii. The
dam, not its operation have impacted the Chub.
Last paragraph. No rationale is provided to support the last sentence
on this page.

5

1st paragraph. 2nd sentence. Statement re: recognition that changes
to operations might have negative consequences for other CRSP functions
is not consistent w/ question No. 2 on the 1st page of the Introduction.
The last sentence of the first paragraph indicates that the studies are
intended "to enable decision makers to assess the significance of
Impacts." Again, Western cannot agree with this approach. The studies
should allow the decision makers to determine if the increment of
optimization for the recreation and environmental resources is
justified in light of the changes that would be required to accomplish
the optimization.

Page

Comments

5

The comment on this page that changes to operations to protect or
benefit downstream resource might have negative consequences for other
CRSP functions, should be changed to indicate that changes would most
definitely have negative consequences to higher priority functions of
tRSP, that is , water delivery and power generation.

6

Western questions the wording 'protecting downstream resources" as used
in outcome 1. As it is known that trout fishing and rafting benefited
greatly from the Glen Canyon Dam and present operations, and it is
admitted that these resources are of extremely high quality (see page
19), it is extremely doubtful that they need 'protection" from the
conditions that provided them.

8

Western suggests including statistics on the number, type, percent of
power supply of firm power customers/consumers. Western's customers
should be given equal consideration with the anglers.
The first sentence is unsupported by any facts or figures, and is
therefore conjecture. Support the statement or delete it. The last
sentence in the first paragraph is similarly unsupported; how many
more? The sentence at the top of page 9 gives the source for the
statement--more of this should be done to enhance the credibility of
the report.

9

1st line Re: Annual gross power revenues, $80 million. This figure
should be qualified to reflect the period considered. Is this an
average revenue estimate for a specific period? Also, the gross power
revenues from the post-filling period have been significantly greater.
This should be noted if proper comparison is to be made.
3rd and 4th paragraph. The reference to 'public concern' in the text
only considers the river-users, fisherman, and environmental groups.
These segments of the public have been perhaps the most vocal, to
date. However, a significant segment of the public have not been
heard--the wholesale customers and retail power user, as well as the
water interests. It is appropriate to mention that fact to provide a
more proper perspective of the "public concern".
1st paragraph. General note: This operation is consistent w/ the
large reservoir behind Glen Canyon Dam which stores
years of
annual flows and the objective of maximizing the value of this precious
renewable resource.

10

Page
10

Comments
Western would agree and strongly support the reduction and/or
elimination of flood control releases from Glen Canyon, and as such,
have supported USBR in their efforts to prepare required annual
operation plans. However, no mention has been made in the report of
the recent efforts by the USBR to evaluate and improve past operational
philosphies in an effort to minimize the risk of future flood releases.
It should be noted in the last paragraph that the filling of Lake
Powell coincided with some extremely wet hydrological years. Flood
releases may be far less common in more normal or dry years, and also
as more experience is gained in operating the dam with a full
reservoir. Western agrees that flows above plant capacity should be
avoided if at all possible.

11

Was the powerplant bypassed prior to the filling of Lake Powell, as
stated?
We understand that flows above 33,000 cfs were extremely rare, and may.
in fact, have not occurred at all.

13

Table II-1, missing flow distribution data during filling period.

14

Resource 'protection' is again referred to. See comment 6.

17

Dollar figures for benefits are presented without source or
derivation. Where did they come from, and why should they be relied
upon?

20

The pre-dam discussion needs to relate the conditions present at that
time to the recreational resources in question. How good was the
situation then?
The last sentence on the page is true if qualified by stating that over
the long term, sediment carried by the river would eventually restore
scoured beaches.

22

2nd para. 4th sentence. Representative post-dam, low-runoff year
(1982, 8.3 maf) is a release, not inflow. Unregulated inflow was
12.5 maf. Regulated inflow was 10.9 maf.
2nd paragraph. "Contrast' between High and Low Water Years in
Figure IV - is not obvious, as stated in text.

General note: As referenced elsewhere in the report, early plans for
an afterbay dam to accommodate the peaking operation at Glen Canyon and
moderate downstream flows were discarded by USBR.

3rd paragraph. 1st sentence. High-water year of 1986, unregulated
inflow 18.2 maf, regulated inflow equal to 17.8 maf. The number
16.6 maf refers to releases, rather than inflow.

3rd paragraph. 2nd sentence. What is the rarity of higher releases?

'All" used in the last paragraph is incorrect. Some suspended sediment
does, of course, get through.

Last paragraph. 1st sentence. General note: Flood releases were more
common because of (1) high flows and (2) USBR was unwilling to operate
under a pre-release program because of the Upper Colorado River Commission.

Comments

Page
27

Page

Note positive benefits of post-dam:

38

- Following the 1st item under "Hourly Schedules', insert a new item
No. 2, 'Maintain minimum release rates'. Renumber the remaining items.

(1) regulation of river flows and lengthening of the white-water
season has certainly been a factor in the increase in the number of
boat trips and increase in related recreational benefits.

39

2nd paragraph. 6th sentence. Regarding flood releases since 1980, '5
out of 7 years'. As noted, 1981 through 1986 was an extremely wet
period.

(2) number of trips would not be as high if Glen Canyon dam did not
exist.
2nd paragraph. Last sentence, regarding depletion of 8 native fish
species. Is the increase in water temperature and sediment reduction
the only reasons why ,". . . only 4 remain"? Are there other natural
causes not mentioned and worth noting?
28

4th paragraph. Last sentence. Combined releases range from 31,500 cfs
to 46,500 cfs, rather than 48,500, as stated.

Therefore, this representation is misleading.
40

Figure VI-la. For the graph of hourly steady flows, replace the label
on the x-axis with 'MIDNIGHT', 'NOON", and 'MIDNIGHT' at the
appropriate locations.

41

Figure VI-lb. Similar comment for this Figure, as for Figure V1-1a.

50

Much importance is attached to the "naturalness" of rafting trips,
usually in reference to fluctuating flows. Is cold, clear water seen
as 'unnatural' also? The recommendations are for the elimination of
floods and the reduction or elimination of fluctuations, certainly not
a natural situation.

52

The study's use of a hypothetical optimum baseline leads to a
comparison between existing conditions and the ideal. Such a
comparison needs the benefit of an additional comparison between the
ideal and pre-dam conditions to provide perspective, as previously
stated, Western believes the whole 'impact" issue to be irrelevant
anyway. Refer to the suggested approach described in our accompanying
letter.

. . over 250,000 cfs". More precisely,
Total release is stated as
from the numbers given, the total release would be 254,500 cfs.
30

1st paragraph. Last sentence. Note that 'all other project purposes"
are not equal in priority to each other.
3rd paragraph. 1st sentence, 2nd line. Insert the phrase ". . .
objective of maintaining a . . ." between the word "the' and 'minimum".
4th paragraph. 2n4 sentence. Should read, "Glen Canyon Dam is operated
with the objective of releasing a minimum of 8.23 maf to the Lower
Basin each year . . . etc."

The second paragraph references an "immediate reduction in the quality
of wilite-water boating trips." Earlier (page 19 and others) the report
indicates that the conditions for rafting are among the best in the
world. The utopian baseline selected for comparison again appears to
be inappropriate.

4th paragraph. Last sentence. Change 'must' to 'may".
31

1st paragraph. Change "CRSP Act" to 'Colorado River Basin Project Act"
when referencing "602(a) storage".
4th paragraph. The priority of the objectives described in this
paragraph are not as stated in Section I of the CRSP Act.

35

2nd paragraph. 1st sentence. Change the word 'practical" to
"practicable", to be consistent w/ the CRSP Act.

55

2nd paragraph. General note: The discussion of potential benefits of
infrequent flooding immediately follows conclusion regarding impacts.
The order should be reversed.

57

4th paragraph. If 'fluctuating flows" are defined as changes in flows
greater than 10,000 cfs per day, then can it be inferred that "steady
flows" are changes in flows less than 10,000 cfs per day? Further, can
it be assumed that changes in flows +/- 5,000 cfs per day could be
reflective of 'steady flows"?

68

Western questions the logic that says natural flow conditions have
"strong negative impacts" on natural resources. Using the approach
advocated by Western, the discussion here would center on whether or
not natural flows would help or hinder the optimization of the
resources in question, and avoiding "impact' questions which, by the
nature of the studies and the relationship of the resources, are both
incorrectly based and irrelevant.

General note: Power pays 87 percent of all CRSP costs.
36

1st paragraph. Last sentence. Insert the word "practicable" between
the word as "greatest" and "amount".
Mention "renewable" nature of hydro when discussing relative value.

38

Comments

Table V-1:
- 1st item under 'Annual Requirements". Insert the word "objective"
before the word "minimum".

Page
69

Comments
Figure VII-6. Release pattern, as referred to in the text in the 1st
paragraph, is missing.

Page
78

General note: The discussion in the second paragraph would indicate
that rafters do not place such a high value on 'naturalness" after all.
75

76

Last paragraph. Why is the option of artificially protecting camping
beaches summarily rejected with little or no investigation? This would
seem to be a reasonable direction to take, unless it can be shown not
to be viable. The costs, feasibility, and possible impacts of making
operational modifications were considered beyond the scope of the
study, but changes to operations were not eliminated from consideration
on the same grounds.

77
cs

2n4 Paragraph. Fluctuating flows do not lead to a loss of backwater
habitat. These backwaters formed in a fluctuating flow regime in the
post-dam period--there were no pre-dam backwaters. Possible flow
patterns exist that would result in the creation of more backwater
area, or may result in the preservation of backwaters existing at a
given point of time. This again points out the inappropriateness of
using an idealized baseline for comparison.
4th paragraph. Under conclusion (2), why was it decided that only the
CRSP water delivery requirements were binding? As an assumption in the
various technical analyses it made sense to use this parameter, but
this passage indicates it has some higher importance than all of the
other provisions of the CRSP act and other 'law of the River"
components.
The text to recognize that the area downstream of Glen Canyon Dam is
and always has been a dynamic environment. Grand Canyon itself was
formed by the 'degradation" of natural resources. Steady releases of
annual runoff may preserve for the short run the status quo, but it
will not be 'natural" at all.

78

Under Management Options, the study seeks to convince the Secretary of
the Interior that "impacts" to the recreation resources are justification for taking action. Western disagrees with this approach. The
question before the Secretary is whether or not improving the recreational resource is worth the costs to other river interests. The GCES
should have focused its efforts more on providing the Secretary with
options that would achieve the study's goals, and the potential costs
of these options, than trying to justify a change based on 'impacts' to

idealized optimal conditions for these resources. Essentially, all the
study has demonstrated is that hypothetical optimal conditions for
recreation resources are better than reality.
Western has no concerns with the possible management options presented
on pages 78 and 79--indeed these are logical steps to take to achieve
the stated goal of the GCES. It must be made clear that optimization
of recreational resources will not be reached without costs to other
resources, and the Secretary should understand that the increment being
'bought' is to make excellent recreation more perfect.

A-1

Not enough has been said in the integrated report about the long-term
effects of eliminating floods and moderating fluctuations with regard
to rapids and debris flows. What will happen to rafting as these
constrictions increase? Are the short-term advantages to optimize the
rafting experience worth the long-term costs? This point should have
been investigated in depth in the main report, as it could affect the
entire viability of modified flows.

A-47

Apparently, camping beaches do reach equilibrium under daily
fluctuating flows. In the main report, however, fluctuating flows are
held to be detrimental to camping beaches. More discussion is needed
to clarify this discrepancy.

B-53

The second paragraph states that riparian and rivering ecosystems are
dynamic and adapted to high levels of disturbance. This idea did not
make the transition to the integrated report the way it should have.
The report advocates the imposition of a static regime on the natural
resources below Glen Canyon as the ideal situation. Western maintains
that this is theoretical and more or less impractical. This is
particularly true in light of the lack of information on the long-term
effects if such a proposal were implemented.

C-4

Question (2) again references "protection' of the recreational
resources. Protection from what? Existing operations are not a new
feature introduced to the present situation, but are part of the
existing situation.

C-11

Western does not agree that fluctuations necessarily impair the
naturalness of the rafting experience. Why does the study not just
state the simple facts? Apparently, some rafters just do not want to
put up with the inconvenience sometimes caused by fluctuating flows.

C-15

As discussed in comment 14, Western has reservations concerning the
methods used in measuring recreational quality, assigning dollar
values, and defining "Impact" based on lost opportunity. Extreme
caution must be used in gathering and interpreting user attitude
data. Eliminating bias in a major problem with such studies. Western
Is not implying that the researchers in this area did not do a thorough
job in minimizing bias or calculating dollar values--Western is merely
saying that the report does not provide enough information for the

1st paragraph. In keeping with the study approach proposed by Western,
conclusion (1) is better phrased, 'Downstream environmental and
recreational resources would benefit from the elimination of flood
releases and minimization of fluctuating flows.'
Last paragraph. Western disagrees that "Daily fluctuations . . .
degrade the natural character of the environment . . .* any more than
artificially block-loaded flows would.

Comments

Page

Comments
reader to conclude that the study methods are valid. The report should
state the assumptions used, the methods utilized to minimize bias, and
a measure of confidence in the results.

C-35

How much of a problem are launch windows when put in the context of the
NPS restrictions on the total number of raft trips allowed annually.
Does the reluctance of outfitters to launch on weekends due to
fluctuating flows benefit the day-trip rafters who may favor weekends?

Page

Comments

D-9

Figure 0-2.

D-10

1st sentence. Change 'practical' to "practicable', to be consistent
with the CRSP Act.

0-10

5th sentence. Delete 'not available', replace w/ "not guaranteed to be

Is generation capability per unit (112,500 kW) correct?

available'.

Last sentence. Change the words 'nameplate energy' to 'nameplate
capacity'. Change the word 'overall' to 'maximum'. Delete the phrase,
". .. or limits, . . .".

Conclusion (1) states that "normal dam operations have been, to a
considerable extent, conducive to white-water recreation . . ." and
that fishing flows have been reasonable also. This fact has not been
given appropriate attention in the main body of the report.

0-11

C-62

The recommendations on this page fail to address long-term effects to
the same recreational resource, such as how rapids will be affected if
fluctuations are minimized and flood releases eliminated.

Correct Table 0-2. Heading should read 'Nameplate Capacity (kW)",
rather than 'Energy (kW)". Insert the word "Maximum' above the column
heading 'Capacity (kW)".

0-12

D-4

1st paragraph. 1st sentence. General note: The phrase '. . . lives,

2nd para., 1st sentence. Insert the parenthetic phrase "(Colorado
River Basin Project Act)" after the reference to P.L. 90-537.

C-60

D-4

0-6

0-7

industry, and recreation" seems to be an inappropriate mix of
elements. It is to be inferred that power generation and water
delivery are lesser priorities than recreation?

2nd para., last sentence. Delete the words 'Operating Criteria' and
replace with 'Criteria for Coordinated Long-Range Operation of Colorado
River Reservoirs'.

1st paragraph. 4th sentence. General note: The phrase "The economic
health, recreational opportunities, and growth potential . . ." seems
to be an inappropriate mix of factors relating to the management of the
Colorado River. No mention is made of the 'real' management
priorities.

3rd para. The word "act' should be capitalized in several places in

1st paragraph. 6th sentence. General note: Glen Canyon is not the
only facility of CRSP on the Colorado River. Glen Canyon, in
conjunction with these other facilities have impact on the "lives,
industry, etc.", not just Glen Canyon Dam.
1st paragraph. 2nd sentence. Include Gunnison River as additional
tributary to the Colorado River.

this paragraph.

4th para., 1st sentence, 6th line. Insert the words, 'river
regulation, beneficial consumption uses, power production" following
the words 'flood control'.
0-13

2nd para., last sentence. Definition of active storage as noted is
inconsistent with Figure 0-2 on page 0-9.

0-14

Text re: Phase I. Elaborate on unpredictability of pre-dam flows and
high susceptibility to flash flooding. Text should stress range of

variation--erratic.

3rd para. 2nd sentence. Change "3,330,000 kilowatts" to "3,624,000
kilowatts'. (WAPA, 1986 Annual Report)

D-I5

It is unclear whether these graphs are based upon monthly, daily or
hourly flows.

Maybe we need another paragraph on the # on consumers in the Basin, S
annual revenues, and overall economic impacts of hydropower.

0-16

Table 0-3. Are the delineations under the column heading "Operating
Regimes', reversed?

2nd para. 2nd sentence. Change 'Lees Ferry" to "Lee Ferry". Lee
Ferry is the Compact point. Lees Fery is where the gaging station is

0-17

Phase III. 2nd paragraph. 6th sentence. Del >31,500 should be rare
if USBR is able to adopt pre-rel. program.

and where the rafters begin their trips.

D-8

2nd para. Last sentence. Change "Aspinall" to "Curecanti".
Technically , the CRSP Act authorized the Curecantl Unit, which later
was renamed the Aspinall Unit.

9

4th para., 1st sentence. Change 'These" to "The".
0-18

4th paragraph. Determination of Monthly Release Volumes. 2nd

sentence. Insert the words 'power and", before the word "energy'.

10

Comments

Page

0-21

1st paragrap.. Last sentence. At the end of this sentence, insert the
phrase ". . . and best meet the mandate to market the maximum power and
energy'.

0-23

Figure 0-5. We suggest adding a vertical line to show the release
volume at 31,500 cfs in order to explain the outlying data. Also,
change the range in the caption to 500,000--1,200,000.

0-24

2nd para., 3rd sentence. Change the word 'inititated* to "initiated".

0-24

Last paragraph. After 4th sentence, insert the following sentences:
"This increased release capability through the powerplant provides
enhanced ability to avoid bypasses and/or spills. This benefit is
substantial if releases occur over a length of time".

0-28

1st paragraph. Last sentence. It is believed that 27 maf is too
high. 25 maf (?).

0-30

2nd paragraph. Insert additional item before existing item (4), as

Comments

Page
0-36

On the X-axis, delete the word 'HOURS" and insert the words 'MIDNIGHT",
'NOON", and 'MIDNIGHT' at the appropriate places.
Figure 0-8. (1) Provide horizontal line at 5 MW through graph. Add
the note above line "HYDRO LOAD'. (2) General note: re: graph.
Hydro load occurs throughout day, not just 5 hours, as indicated.

0-38

3rd paragraph. 2nd sentence. Change 1978 to 1987.

D-40

Figure D-9.

0-41

Last paragraph. Last sentence. Change 'for' to 'or".

The reduction of this figure has made parts illegible.

follows:
'
(4) how the resource was to be allocated,'
Renumber the subsequent items.

3rd para. Items (1) through (6), pg. 0-30, and items (7) and (8) on
pg. 0-32. Suggest that 2nd paragraph may be sufficient information
regarding contents of marketing criteria. Items (1) through (8) may be

L6300:JMcCoy:dw:x5399:09/08/87
Revised:09/09/87:dw
Final:09/09/87:dw
PMO:JAMPC00037

considered redundant. Consider their deletion.
0-31

Figure 0-7. Correct legend for Northern Division such to exclude
interpretation that California and Northern Nevada are in Northern
Division. Not true.

0-32

1st full para., 4th sentence. Change "Army Corp" to "Army Corps".
2nd para.. 1st sentence. Reference Figure 0-7 regarding the geographic
market area, especially if item No. 1 on page 0-30 is removed as
discussed above.

0-33

3rd para., 1st sentence. Reference Figure 0-7 here, especially if item
No. 1 on page 0-30 is removed.

0-34

4th para., 1st sentence. Change the word 'often" to "mostly".

0-35

Last paragraph.

0-36

Figure 0-8. Add to the description below the figure the following:
"(Note: This is for illustrative purposes only, and is not intended to
represent the actual load pattern of any of the CRSP customers)".

2nd sentence. General note: Item (4) does not occur.

11

12

CRSP CUSTOMER REPRESENTATIVES TO RECEIVE A COPY OF

DRAFT GLEN CANYON ENVIRONMENTAL STUDIES
September 1987
Intermountain Consumer Power Association
Ms. Carolyn S. McNeil
General Manager
8722 South 300 West
Sandy, UT 84070
Utah Municipal Power Agency
Mr. Clark Bigler
Executive Secretary
P.O. Box 818
Spanish Fork, UT 84660
Plains Electric Generation & Transmission
Mr. George M. Sheldon
Director, Power Operations
P.O. Box 6551
Albuquerque, NM 87197
Salt River Project
Mr. John F. Sullivan
Manager Power Contracts
c/o Secretary
P.O. Box 52025
Phoenix, AZ 85072-2025
Tri-State Generation and Transmission Association, Inc.
Mr. D. E. MacLeod
General Manager
12076 Grant Street
Denver, CO 80233
Platte River Power Agency
Mr. Thaine J. Michie
Director of Operations
Timberline & Horsetooth Roads
Fort Collins, CO 80525
Arizona Power Pooling Association
Mr. Michael A. Curtis, Attorney
Martinez & Curtis, PC
2712 North 7th Street
Phoenix, AZ 85006-1003

Irrigation Electrical Districts of Arizona
Mr. Robert S. Lynch, Attorney
Palm Lane Professional Building
2001 North 3rd Street, Suite 204
Phoenix, AZ 85004-1472
Colorado River Commission of Nevada
Mr. Melvin R. Ware
Senior Power Marketing Administrator
Mailroom Complex
Las Vegas, NV 89158
Colorado Springs
Mr. J. J. Horenovsky
System Operations Superintendent
P.O. Box 1103
Colorado Springs, CO 80947
Wyoming Municipal Power Agency
Mr. Larry Lamaack
Executive Officer
P.O. Box 900
Lusk, WY 82225
Colorado-Ute Electric Association
Mr. Girt Krumins

President
P.O. Box 1149
Montrose, CO 81401

L6300:JMcCoy:dw:x5399:09/09/87
Final:09/09/87:dw
PMO:JAMPC00039

MAJOR COMMENTS
SUPERINTENDENT

DRAFT
FNP:Sliodapp,(GRCA)S:765-7751:12/01/87

1.

As stated in our previous memoranda (January 20, 1987, and June 1, 1987),
it is essential that all technical studies be completed as soon as pos-

1.7619(NR)

sible.

To date, we have received only one of the over 30 studies In Its
final version. Thus, our ability to review this final draft has been
seriously impaired, since we are unable to review the technical reports

Memorandum
To:

Regional Director, Upper Colorado River Basin, Bureau of Reclamation

Pros:

Regional Director. Western Region. Notional Park Service

which were used in developing many of the conclusions in this document.
This is of particular concern as we observe new Information and changes
in the conclusions contained in this document Over the three different

Subject: Final National Park Service Comments on the September 1987
Draft Glen Canyon Environmental Studies Report

versions we have reviewed.

We wonder how the different technical studies

have been changed to reflect this.

efforts of the combined agencies. We appreciate the impact these studies will
provide in assisting us to better perform the resource protection mandote of
the National Park Service. This effort has been well received by our publics

Some of our constituents have also

raised this concern. The current version of the final report does not

We appreciate the opportunity to review the subject document. This effort
represents • solid integration of diver:me studies culminating from the extensive

even contain a full list of these studies.
2.

We are confused by the principal conclusion that operational changes are

unlikely to help humpback chub. In fact, this statement appears to be
contradicted several times in the body of the report. For example, on

as confirmed through our recent constituency involvement (see enclosure).

page 62, the text reads "high flows in May and June would back op the
CM

With incorporation of these final comments, we will have a quality effort which
we can jointly take forward to the Department. For your convenience, we have

Little Colorado River, creating a large area of relatively warm, low-velo-

divided our comments into three sections: major comments, technical comments.
and future research needs. If you have questions about any of these comments,

vival."

city flow which appears beneficial to chub reproduction and larval sur-

3.

please contact Grand Canyon National Park Superintendent, Richard W. Marks, at

While Glen Canyon Environmental Studies (GM) does present much information on important beach building proc 00000 , the fundamental shortfall of

FT3 765-7701.

the studies is that they do not define the relationship which exists between sediment storage in the mainstem pools and the rate of beach erosion.

We look forward to continuing our positive working relationship with the Bureau

Further, the models used to characterize the river sediment regime contain

as we search for the best operational scenarios for all affected parties.

errors so large, they cannot be relied upon to present an accurate repre-

DRAFT

sentation of conditions along the river corridor. Thus, significant new
research must be designed with input from the National Academy of Sciences
to address this fundamental issue before • knowledgeable decision regarding

Stanley T. Albright

the long term fats of this critical park resource can be developed.

Enclosures
cc:

4.

Superintendent, Crand Canyon
Regional Director, usrws, Albuquerque, New roxico
Director. Arizona Gams and Fish
Superintendent, Lake Mead NRA
Superintendent. Glen Canyon NIA
Chief, Water Resources Division, NP!

This report raises serious questions as to the appropriateneso of the
Finding of No Significant Impact signed on the uprate rewind program.
Eow does the Bureau intend to address this new information in terms of

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additional (EPA

DRAFT

compliance and/or studies which may be uecsesary prior

to utilisation of the new upratad capacity?
TECHNICAL
3.

commurrs

Tha diecusmion of "OUCCOIMS" (page 6). "met-operational Approaches" (page
77), and "management options" (pas. 83) are actually the taek assigned to
the Executive Livia./ Committee and thus do not appear logical for inclusion
in this document when
firma regimes.

the purpose is to define the impacts of various

Further, the limited cr...,ntnant ;ivan

..... more questions than it provides Answerm.

to

these torici may

These [hrsa sections ahould

Page 1, paragraph 1 - As correctly presented on page 33, paragraph 1, paver
generation is not a "primary mandate of the Colorado River Storage Project
Act."

Page 10, paragraph 2 - Was Glen Canyon Dam actually "designed" as a peaking
power facility?

aither be combined and nore fully treated as an appendix, 4runsuitted in
a formal document from GGES to the Emscutive Reviow Committee, or deleted
from this document.

Page 30. paragraph 4 - The 20 Whitewater rafting concession/41ra operating in
Grand Canyon National Park grossed in excess of 814 million in 1966.

Page 36. paragraph I - We do not concur that storage spats in Glen Canyon is
not • criteria governing the release of water from Glen Canyon Dam. Water
storage space, or lack thereof, is a major factor governing the water release
schedule.

Page 34, paragraph 4 - As currently Witten, the implication la that recreation
and fish/wildlife resources are of equal value in the consideration of dam
operations with power production.

Is this actually the case?

Page 48, paragraph 1 - Why doss the plus indicate a positive Impact, but a
minus indicate a "significant" negative impact? These two symbols should be
indicative of the same level of impact.

Page 49, footnote - The term "consumer surplus" should be defined earlier in
the document where it is first used.

Page 59, paragraph 4 - The process of interchange of sediment in the riverbed
with beach building sediments is currently unknown.

Page 68, paragraph 2 - The addition of three 2-weak periods of fluctuating
flow to benefit trout cannot be justified based on the data collected at this
time. This proposal should be withheld until there is an adequate database to
support inclusion of 441 meaningful period of fluctuating flow.

TOO

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DRAFT
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12 04 87

08:37

;765

GRAND CANYON NF

7E5 779'7140.001

5

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1987) were too limited to
the scope of the beach studies (Schmidt and Graf,
to
"identify
specific
campsite
beaches that are gaining.
allow the researchers
or a similar one, should be
etatement,
equilibrium."
This
losing, or are io

DRAFT
4

included in the c wt.

Page A-17, paragraph 1 - The report would be improved if the "important channel

Page A-17. paragraph 4 - "(1) Loss or gain of sand in roaches depends on many

Page A-18, paragraph 6 - "(6) Current operations will result in loss of some
statements in the
beaches in the long run." The subject statement plum other
being
paragraph represent a good discussion of severel aspects of the problem

factors and therefore varies with time." This statement, and the two statements

addressed (objective 6, page A-I3).

and flaw characteristics" were listed.

Also, the statements are well-founded by

However, they do not represent a good reply for the questiont

following it in the paragraph, do not anewer the question that they address

results of CCRS.

(see objective 1, page A-13). The three statements, however, will generally

"What will the river morphology be like up to 100 years from now based on oper-

apply for any pool-and-rapid stream that carries a relatively wide range of
discharges and a mixture of sediment sixes. Phrased differently, the statement.

ational alternatives?" A statement, or a group of statements. should be added
that says, in effect, that • complete, or detailed, description of the river

that are given would have been well-founded, based on common knowledge, intu-

morphology 100 years from now could not be developed from results obtained

itive reasoning, and results of other studies - even without CCU.

from GUS.

However,

they do not describe "reaches of the river that are losing, gaining, or are in

should) present more definitive statements, based on results of CCES, pertinent

Page A-19, paragraph 2 - "(7) Flow routing model vas recalibrated." The flow
Colorado
routing model wam calibrated for conditions that prevailed along the

equilibrium with respect to sedimentation." We believe the authors could (and
C7)

e.12,

Results from use of the model nay, however, contain significant

to reaches that are losing, gaining, or are in equilibrium. If the authors

River in 1986.

believe that more definitive statements cannot be jus.ified, then they should

errors (see page A-60, second paragraph).

present • statement that says, in effect, "Reaches of the river that are losing,
gaining, or are in equilibrium could not be determined with methods being used."

flow velocity, travel time, reservoir storage, and scour-and-fill iu pool will dimfor • given discharge change with time, the reliability of the modal

Page A-18, paragraph 3 - "(3) Net loss of sand from Grand Canyon is highly

inish (Markham, written communication, January 1987).

As the hydraulic conditions - stream-

variable." The subject statement, and the one that follows it, do not directly
sound and are supportable - based on common knowledge and results of other

Page A-19, paragraph A - "The long term fate of campsites depends on sand storage in stain channel pools." Much discussion in the report, especially that on

studies - even without GCES. However, they do not represent answers to ques-

pages A-36 and A-37, seems to support the subject statement. A different view-

tions concerned with "the present net sand outflow from Craud Canyon into Lake

point - that the long term fate of campsites does not jgreatly depend on sand

Head" (see objective 3, page A-13).

storage in main channel pools - also has considerable support. Arguments for

answer the question that they address.

The two statements are technically

Statements should be given that either

this different viewpoint are given in the following discussion.

dascibe the average annual sediment outflow (with statements of probable errors)
or aloe that say, in effect, "The net sand outflow from Grand Canyon into Lake
Mead could not be determined with methods that were used." A statement similar

The GCES did not define the relation that exists between sediment storage in

to the above appears in paragraph 2 on page A-59. Why ween't the STAB model
used to generate this information?

Poole - or lack of sediment in pools - and the rate of erosion of beaches.
were
The CCES did show, however, that the sediment deposits used as beaches

Page A-18, paragraph 4 - "(4) Camping beaches in narrow reaches and the down-

composed mainly of fine sand (Schmidt and Graf, written communication, 1986).
vbere
Deposits along the Colorado River that are primarily fine sand are found

stream parts of recirculation tone, are particularly vesceptible to erosion."
The subject statement and others in the paragraph represent a good response to
the question being 'eked (see objective 4, page 13). These ststements are
logical and they are supported by results by 8chmidt sod Graf (1986).

20,7

However,
!

.

Dll

DLI NO/leD 131144d0

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^ - =',1! •-11480:8 114.-Z1 -2 156.- 431 ,

DRAFT

SUPERINTENDENT

DRAFT
SHODAPP:(GRCA)S:765-7787:12/02/137
(WR- )

DRAFT

Memorandum

(May/June) appear beneficial to chub reproduction and larval survival. Further
investigation of other flow regimes seem warranted at other times of the year.

Regional Director, Upper Colorado Region,
Bureau of Reclamation

Recognizing data gaps were evident, the National Park Service does not feel

From:

Western Regional Director, National Park Service

fects of Dam operations upon Humpback Chub.

Subject:

Transmittal of the Preliminary National Park Service Position
Regarding Future Glen Canyon Dam Operations

2.

To:

the CCES acquired sufficient information to demonstrate the full range of ef-

Maintain the Colorado River alluvial deposits (beaches) by mitigating ac-

celerated erosion due to man-induced processes. Protection of beaches in Glen

CD

We appreciate the opportunity to provide you with our views on this subject.

Canyon National Recreation Area (GCNRA) and GRCA is essential. Unfortunately,

The Glen Canyon Environmental Studies (GCES) process has been a beneficial one

the effects of various flow regimes on beach -rosion processes is not ye - fully

for i 51 participating agencies in terms of development of a spirit of coopera-

understood. It is known that flood flows have significant adverse effects on

tion. as well as the generation of critical information concerning the inter-

beaches and the current annual flood risk of one in four is unacceptable.

nationally significant Grand Canyon resources. Based on information contained

Steps beyond improved forecasting should be put in place immediately to reduce

In the GCES report, we now believe there is an adequate data base to develop

the flood risk to at least one year in twenty. Additionally, studies of the

and implement an operational scheme which provides for a more balanced con-

relationship between fluctuating flows (considering both fate and amplitude)

sideration between power revenue generation and protection of downstream recre-

and beach erosion processes should be initiated.

ation, biotic and abiotic resources. While some data paps clearly still exist.
this should not deter us from implementing what we have learned during this 4-

3.

year, $7.0 million study.

experience in GRCA. The whitewater raft trip within Grand Canyon, involving

Perpetuate and enhance the opportunity for a high-quality whitewater boating

more than 15,000 visitors annually, is one of the pre-eminent visitor experiResource protection objectives of critical concern to the National Park Service

ences within the National Park System. Current dam operations have been shown

(NI'S) uhich must be considered in future operating scenarios include the fo)-

to Lave significant adverse impacts on this experience both from the perspective

low'l.i:

of safety and trip quality. Several operational changer are necessary to reduct/mitigate these impacts, including:

1.

:'7. ,tect and Enhance Existing Ponulations of Endangered Humpback Chub - The

Litt!c Colorado River/Colorado River confluence within Grand Canyon National

(1) increase minimum releases, (2)

reduce flood frequency, (3) reduce rate/magnitude of fluctuating flows, and
(4) maintain high flows during the peak recreational use season.

(GRCA) provides the lest appreciable refuge for the Humpback Chub in the
•r Basin and perhaps the only genetically pure population of this species
1,,,

Einimum releases should be immediately raised to 5,000 to 8,000 cfs (see number

IN the entire Colorado River basin. Construction and subsequent operation of

5 below).

Glen Canyon Dam has severely altered the habitat of this endemic fish and re-

determined without further study, releases below 5,000 cfs are not acceptable

stricted suitable spawning habitat to a small portion of its historic range.

from both a safety and trip quality perspective.

While recognizing the existing habitat deficits, the GCES would indicate that

Flood flows have been shown to have adverse affects on recreational whitewater

relatively high flows, near powerplant capacity, during the peak spawning period

safety, especially at Crystal Rapids. Further, as previously discussed, flood

While the exact minimum release for whitewater recreation cannot be

DRAFT
4

3

flows have substantial adverse impacts on beaches. These beaches are essential

required for whitewater boating. Similarly, effects of fluctuation rate/mag-

to the current whitewater rafting experience and rust be protected.

nitude on stranding of adult fish requires further investigation before a solid
recommendation can be developed. While the GCES report identifies two, 2-week

Fluctuating flows have also been demonstrated to have significant adverse ef-

periods of fluctuations to enhance trout growth, we cannot concur that adequate

fects on the recreational whitewater experience. Fluctuations that are cur-

information exists to support this recommendation at this time.

rently experienced reduce the visitor's perception of the canyon as a natural
environment, create operational difficulties in terms of running rapids and

In addition to these resource protection objectives, we believe that maximum

establishing camps, and may have safety implications in terms of flooding camp-

powerplant discharge should not be allowed to exceed 28,000 cfs pending further

sites at night. We believe some acceptable level for the rate and magnitude

study. This level represents the approximate recent historic level of discharge

of fluctuating releases in regard to impact on whitewater boating could be •

(prior to the rewind project). Further, we cannot identify any downstream re-

defined pending further study.

sources which would be enhanced by higher powerplant discharge. However, ad-

MoreoVer, a reliable schedule of fluctuations

must Le developed to keep boaters downstream informed of upcoming release pat-

ditional work on enhancement of Humpback Chub populations in the s...cinity of
the Little Colorado River could provide additional information. Currently we

terns.

concur with the conclusion that the "effects of the Uprate and Rewind Program
High, relatively constant flows of 20-28,000 cfs are desirable during the peak

on downstream resources cannot be determined at this time" and urge that this

whitewater use season from May to September. These releases significantly

program not be implemented until the effects are fully defined.

Improve trip quality and are consistent with releases necessary for Humpback
Finally, we strongly support the continuation of an interagency study/planning

Chub protection.

process as we move forward toward changes in operations and additional study.
4.

Protect and enhance populations of other endemic fish species. Protection

As in the past, power revenues should be the funding source for this activity.

of this resource has the greatest potential for conflict with other resource

However, we see a need for reorganization of the framework of this program to

values of concern to the National Park Service. Further information regarding

where the study manager reports to all cooperating agencies and all future

the life history of these native fiehes is necessary to fully understand the

,work has full concurrence with and involvement by the participating agencies.

Impact, of high recreational releases on these fish. However, protection of
Rnm71.,k Chub and beaches would Loth take priority over protection of the common

We appreciate the opportunity to provide you with our position on this matter.

ende:-.le fish species.

If you have further comments, please contact Grand Canyon Superintendent,
Richard W. Marks, at FTS 765-7701.

5.

tuate

the recreational trophy trout fishery. This objective relates

prir“fily to fishing within GCNRA and to a lesser extent, within ChCA.

to he ssrsidered include:

Factors

(I ) providing minimum releases to preclude dewatering

of redds. (2) providing adequate releases to ensure upstream access to the dam
from Lees Ferry. and (3) reduction of fluctuation rate/magnitude to reduce trout
stranding.
Minirmm releases for both fisherman access and protection of redds need further
i n,w.tigation, but appear at this time to fall In the 5.000 - 8.000 cfs minimums

DRAFT
Stanley T. Albright
cc:
Superintendent, GRCA
Superintendent, GCNRA

E-û

DRAFT

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DRAFT

the stream velocity Is relatively law. For the Colorado River. low-velocity
'ones can be found along the river banks and in the "ehadow" of objects - large
boulders. took outcrops. debris fans - protruding into the river. The river
bank can represent a protruding object, thus causing low velocities In • nearby
downstream zone. Recirculation zones occur commonly in the "shadow" of objects
protruding into the Colorado River.

Thus. low velocity zones represent sinks

for fine grain sediments.

city zone - are primarily coarser than those found in the low-velocity sons.
The high-velocity sones then primarily represent sinks for coarse sand. gravel
and boulders.

results from the sediment transport model (Randle and Pemberton, written communication. 1986).

nificant amounts in the recirculation zones indicates that the currents that
move sediment from the main channel to the recirculation zones do not have the
competence (sediment transport capacity in terms of particle dimensions) to

occurs when the flow in steady. The 12 percent higher transport when the flow
is fluctuating could be very largo, and very important, if it represents • 100

The relationship between the transport capacity of the main channel and the
rate of erosion of the beaches was not defined by G M.

limited significance and reliability pertinent to the beaches. Uncertainty
about the importance of the number is developed because:

(1)

The ratio of sand amount in beaches and in recirculation zones near beaches
to the total of 42 at is not known.

transport significant amounts of coarse sand to the beaches. This statement
is true regardleas of the main-channel discharge or the bed-level in main channel pools.

Also, data collected by CUB researchers (Pemberton, written com-

(2)

of river f:,.ozw had the competence to move fine sand in suspension even when the
discharge im relatively low, less than 5,000 cfe. Furthermore, results from

(3)

port at discharges in the powerhouse range (Burkham, writton communication,

an argument that the current along the main path of flow always has the com-

1986).

petence to move fine grain sand (see discussion on pages 13-14 of thim project).
Apparently then, if the arguments presented in this discussion are basically

, (4)

(Schmidt and Graf, written communication, 1986).

dependent on the fine sands that are stored in low-velocity zones along the

butary stream,.

Of the amount of sand along the Vain channel bad, probably a relatively
small percent is of • fine sand size, the sire that is found in the beaches

stored in pools along the main path of river flow. Instead, the fate is mainly
margin of as main path of river flow and that are derived directly from tri-

Most of the sand that remained along the channel bed after the record
post-dam discharge, about 97,000 cfs, probably is not available for trans-

studio, by Schmidt and Graf (written communication, 1986) apparently support

valid, the long term fate of campsites is not greatly dependent on the sediments

The reliability of the estimated thickness of the sand, 20 ft., is highly
questionable (see pages A-58 and A-59).

munication. October 1986) indicate that the currant flow along the main path

(5)

Most of the fins sand that is eroded from the main channel bed occurs
during high discharges and, of this amount, a large part 10 transported
through the Grand Canyon during the high flow rate.

Page A-19, paragraph 5 - "Main channel transport of sand within powerplant
capacity is only slightly higher under fluctuating flow than under steady flow
of the same volume." The two statements in the paragraph are supported by

Page A-2I, paragraph 1 - "At that gage, discharges of about 40.000 cfs corresponds to the velocity at which degradation begins when the bid is at a low
elevation.

1- 00

However, they do not describe the difference in erosion of

beaches between that which occurs when the flow is fluctuating and that which

Page A-26, paragraph 2 - The estimated value present, 42 mt. may have only

The fact that coarse sand - and larger site sediments - are not found in sig-

NJ

7

percent increase in erosion of beaches.

Sediments in deposits found along the main path of river flow - the high-velo-

•-•••.]

;4 5

005

BOO ON

cC hOl•NtO aNtd9
co,!

82:91
1L6-7/-r

L9'0 21
›A?1,4r1 ,
1n

,

(See Burkhas...)"

This reference is not correct. On page 46.

•EPO• TELECOPIEF 49; 3-12-77; 5:0EPM

12

03.

E.i7

16:30

; 765

GRAND CANYON HP

;

765
NO. 008

Oat

TELECOFIEF 495; 4-12-77; 9:16C.,n
1. 2/04/87

08:78

; 765

GRAND CAINfON NF

765 7797,
NO.001

;
004

DRAFT

DRAFT

9
Surkhem (written communication. 1986) states "Regardless of haw high the discharge becomes ...... the riverbed did not scour significantly below the -13.0foot level." On pegs 53, he states

"However. a discharge of more than 100.000

cfs and velocities of about 10 fps would not cause the bed to scour more than
-14 feet." The bed is at • low elevation when it is at about -13 to -14 feet.
rags A-36, paragraph 3 - "At some discharge below maximum poverplant discharge,
sand in mein channel pools begins to ba transported." This statement ia not

necessarily true. *specially for pool, that had previously been scoured to •
low level. For instance, channel bed data for the measurement section at Leas
Ferry indicate that than

was no significant movement of channel bed, either

scour or fill. during 1966-83.

(ma fact that no significant chenge in bad

level occurred during 1966-83 also sssss to indicate that fine sand eroded
from upstream deposits - in low-velocity cones - during • relatively long period
of regulated flow vas transported through the pool.) Scour in a pool occurs
when the stream competence exceeds that required to move sediments found on
the stream bed.

Fill occurs when the stream competence is not high enough to

continue to transport sediment in the flow.

Page A-43, paragraph 1 - A description of the process by which fine sand le
moved from the reattachment deposit to the separation deposit is needed. For
• given site, the separation deposit is at • higher elevation thin the reattachment deposit.

Page C-10. paragraph 1 - Change "accident rate" to "accident variables."

The authors apparently expressed their view on the need for a

better definition of the process when they stared (page A-43, paragraph 1)
that "The processes involved in sand transport from reattachment to separation
deposits Sr. not understood well enough for us to estimate the rate at wbich

thie loss would occur under given flow conditione."
Page A-50, paragraph 4 - A strong argument hae previously been presented that
suggests the level of the pool may have only limited influence on the movement
of fine grain sediment to and from the beaches.

(See pages 9, 10, and 11.)

Page C-7, paragraph 3 - River companies have contracts, not permits.
Page C-8, paragraph 5 - Plows less than 1,000 cfs are "technically feasible."

Page C-10. paragraph 3 - What percent of recreationiats perceive fluctuations
in emcees of 10,000 cf. daily?
Page C-12, paragraph 2 - What percent increase is represented by the $800,0007

Fage C-60. paragraph 4 - what are examples of the positive end negative effects
of high water?

Appendix D - Operation Report - This appendix provides a detailed diecuasion
of the Colorado River Storage Project and its history and constraints. Other
applicable, and possibly contradictory, legislative directive, such as the
Grand Canyon Enlargement Act, Endangered Species Act, and other National Park
Service legislation should also be presented. This would allow the Secretary
and others evaluating the project to understand the implication, and tradeOffs which will undoubtedly have to be made.

Page 0-29, Section III - This flood risk analysis is an integral component of
the entire effort and must be fully analysed at this time. Further statistical
analysis at a later date is not a reasonable approach for ensuring this important piece of information is available.

Page 0-43 - National Park Service water rights under the Winters Doctrine need
to be recognised.

5FO , TELECOPIEF 495; 3-12-77; 5:09FN
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.

; 765

16:32

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7ELECC,FIEF
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001

9:17AN

08:29

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NO.001

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005

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10

FUTURE RESEARCH NEEDS

; 7E5

GRAND CANYON HP

Sediment

The National Park Service recognizes that. in any research

undertaking of this

(1)

Examination of a representative range of potential dam releases which

magnitude, data gape are certain to exist at ths and of the effort. We recog-

would allow definitive evaluation of the effect of variable flow rates

nize that additional data needs exist in relation to the Glen Canyon Studies

and amplitudes on beaches.

and we support additional work. We have reviewed the idea, for additional
research contained in the report and find that many of theme ideas should be
further conmidered.

(2)

However, any future research program should be based on

Development of a model to predict long-term beach erosion at specific
sites.

This study would include an analysis of the mechanism for the

transference of mainchannel sediment to sand dapomits, eddies, and back-

the following framework.

waters.
(1)

In order to improve communication and ensure that all agencies are fully
involved in authorizing future research, an interagency study team must
be developed.

(3)

Development of a basa map of beaches/vegetation along the river.

(4)

Repetitive low level aerial photography (every several years at selected

The study manager would be responsible to this study team.

and all agency participants would have to agree in writing to research

beaches).

projects before they can be initiated. A new single cooperative agreement
should be signed with all participating agencies so that all participants

(2)

are ours to be involved for the full program.

(5)

Periodic rophotographing from selected historical oblique photopoints.

No ....... h should be initiated until the National Academy of Sciences

(6)

Replication of topographic surveys at selected beaches.

(7)

Develop a model for estimating the delivery of sand-lazed sediment from

Report is received and thoroughly reviewed.

(3)

Ungauged tributaries.

No research should be Initiated until a comprehensive research program
outline has been completed. That comprehensive reeearch program would
consider

NAS

recommendations. be reviewed by scientific experts (outside

GCES), revised as necessary, and agreed to by all participating agencies

NOTE; The above studies should be designed to collect data above Lees Perry
' as wall.

prior to initiation of Ely additional research.

BIOLOGY
(4)

All research contracts; will be solicited through a competitive bid process
or through • negotiated procurement document.

Thls competition would

(1)

Analysis of the effect of high ral aaaaa on humpback chub recruitment and
the effect of low and fluctuating flows on reproduction and roaring.

ensure the best person/organization is awarded the work and would increaae
accountability wherein substantial payment would be withheld until the

final product is received.

(2)

Feaeibility study of reintroduction of humpback chub into other Grand
Canyon stream..

The following list of research projects should be considered In the comprehensive research program outlimr:

(9)

Tu.tLe,

....17414

of the relationship harves e sative fioh utilisation of

backwaters and flows.

. 74

IELECOPIER 495; 3-12-77;
.2 03 87

16:33

:755

:0 3

765 77974

GPAND C441)4 NP

NO.009

003

DRAFT
(4)

old high water
growth rates in the new and
Monitoring of mesquite/acacia

insects in the food cbain.
(5) Develop bameline data on the role of
(6)

level on endangered peregrine and bald eagle
iltudy the effects of lake
populations of Lake Powell.

(7)

How do low and fluctuating flows affect trout foodbase, growth, mortality,
and reproduction in Glen Canyon National Recreation Area.

(S) Nov will soil fertility change in the long term, especially in regards to
flooding.
RICRIATIOR
Refinement of acceptable levels of fluctuations and minimum releases nets.airy to protect whitewater raft trip safety end quality.
(2)

Analysis of the affects of fluctuations in Glen Canyon angler safety.

(3)

Analyeis of angle use above Leos Ferry based on new fishing regulations.

(4)

Further development/verification of the Wilderness Simulation Wm Model
regarding Grand Canyon Whitevater rafters.

(5)

Development of long-term survey instruments for all recreational user
groups.

(6)

Nov do flows affect user impacts on the terrestrial environment.

OPIRATIONS
(1) Nov can operations be modeled to simulate flows et the level of detail
necessary to determine their effects on downstream resources.

16:34

;76E,
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765 7797-,
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:a 4
004

12

memos.

(1)

7E_F_OF:EF 465;
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Summary of OCRS Comments
Organisation
Arizona River Runners
- reduce magnitude of daily fluctuations.
- eliminate flood rdl .....
Which are lees then 5,000 cfs.
- reduce frequency of rdl
Arirona Raft Adventures
- reduce magnitude of daily fluctuations by operating Glen Canyon
Dam aa • base-load facility and Hoover Dam as • peaking power
facility.
Friends of the River
- establish protection of recreation use ae a priority consideration
in operation of Glen Canyon Dam.
- prepare an LIS to fully smalyre impacts of current dam operations.
- reduce frequency of fluctuating flowe and flood rdl .....
- Nps should aggressively pursue establishment of Glen Canyon Dam
as • bass-loaded facility.
- supports the alternative for "maximizing fishing and whitewater
recreation".
Outdoors Unlimited
- establish • constant flow regime, allowing only gradual flow
reductions (10% per day or it per hour).
- restore critical beaches by use of suction dredges during the
winter (low use period)
- establish • silt bypass system or dredge system to restore
Colorado River sediments to the below dam environment.
Pete Resnick
preclude flood flows until mainstem sediment replenishment schedule
is better understood.
Sierra Club (Grand Canyon Chapter)
reports lack much baseline data (i.e., where beaches are located).
300 copies of the document for public distribution is inadequate.
30 days for public comment on en issue of this complexity is
unreelistic, especially when baseline reports are unavailable.
• full 113 should be completed before any changes are implemented.
priorities of release patterns should be reconsidered, especially
in the ere. of power production vs. resource protection.

EFO, TELECOF IEP 495; 3-12-77;
12.03'??

16:34

;765
WAND C.:44'i0k4 F

765 779-,

NO.007

:0 5
005

Dan Dagget
1 961 Meteor
Flagstaff, AZ 86001

2
NI'S River Concessioners
- river recreation should be • much greater consideration in the
development of the flow release schedule.
to a great extent, delayed release of flow. ha. translated into
winter releases and daily spikes which are of little use to
river runners.
immediately increase the minimum flow to at least 5,000 cfs from
October 1 through March 31.
revise the summer (April 1 to September 30) release pattern to
that experienced from 1966 to 1976.
continue studies, especially those related to • better understanding
of beach erosion proc aaaaa .

CSN

National Parka and Conservation Association
avoid flood flows
seek dam operations which protect • prioritized hierarchy of resource
values:
humpback chub,
(1)
(2)
beaches and associated sediment deposits,
(3)
whitewater boating opportunities, especially as related to
fluctuating flows which have • significant negative impact on
the whitewater experience,
other endemic fish species, and
(4)
terrestrial vegetation and wildlife - only to the extent that
(5)
management for these resources not jeopardize those resources
previously listed.
operation of Glen Canyon Dam as a peaking power facility should be
reconsidered in light of
peaking power generation is not • primary purpose of the dam, and
(1)
(2)
significant environmental impacts which have been documented
in OCRS.
Sleight txpeditions
- flood releases and fluctuating floods should be reduced to ensure
protection and maintenance of the existing environment.
minimum flows of 8,000 cfs should be established.
flows of 8,000 to 20,000 cfe should be maintained during the recreational
use season.
more data is needed in the following specific arm prior to any operational changes:
low flows (below 10,000 cfe),
(1)
(2)
fluctuating powerplant rdl.....
(3)
impacts to humpback chub and other native fishes,
(4)
relationship between flows and beaches,
(5)
relationship between flows and safety/quality of boating.

November, 12 1987 —

Dave Wegner
Grand Canyon Study Manager
P 0 Box 11568
Salt Lake City, UT 84147

Dear Mr. Wegner:
First of all, to send me a document over an inch thick containing the
results of over thirty technical studies and ask me to read, consider,
digest and comment on it in less than two weeks is a joke I don't know
about you, but I work for a living I have other things to do than drop
everything to contribute to the shaky legitimacy of another boondoggle.
The extremely short period for which this document is being held open for
review indicates to me either that either you believe its a joke too or that
you have something to hide. That feeling is confirmed by the fact that even
though this draft report deals with a subject as important as the
environmental effects of the greatest change to come to the Grand Canyon
since the last lava flow dammed it up a few eons ago, you only sent out
300 copies With all that in mind, I'll do my best to give it the
consideration it deserves
In your cover letter you ask for answers to t wo questions
to them in order

ril respond

First. Are the impacts of operations identified by the GUS
significant?'
Hell yes' Any fool can see that, and while you've been out spending a
small fortune putting this study together those wiser souls have been
wondering why the problems are being studied instead of remedied.
Second - What should be done next?'
Dismantle the dam, of course That'll take care of its environmental
effects

a

You imply a third question, should full NEPA procedures be
initiated?
While that will just continue the paper shuffling and deficit spending
to fund another several years worth of free Grand Canyon/Colorado River
vacat ions for a bunch of bureaucrats, I'll reluctantly say yes, that is, if
you don't follow my advice from the previous paragraph
What I'd like to know is why didn't we get a NEPA document in the
first place instead of this not so cheap but nevertheless pale substitute. I
realize its a lot of fun to keep riding those waves in Lava at the taxpayer's
expense, but don't you think you ought to be honest enough to give them
something real in return. And then you ought to give us the pleasure of
really getting our teeth into it and tearing it apart for a few months
instead of teasing them us with something like this
I guess the question I have for you is, now that this charade is out of
the way, are we really going to address the issues'?

Sirprely,

Dan Dagget

Cati5(11.,tiiia0
PZ

12
"3/ 4. /4-'1

,
( /14 /

7th.-

APPENDIX E
Constituent Group Comments

APPENDIX E: CONSTITUENT GROUP COMMENTS
PART II: FISH & WILDLIFE SERVICE CONSTITUENCY
INDEX
COMMENT LETTERS
GLEN CANYON ENVIRONMENTAL STUDIES
SEPTEMBER 1987 DRAFT REPORT

Entity

Letter Date

Date Received

Sierra Club Southwest

10-28-87

11-02-87

Zane Grey Chapter
Trout Unlimited

11-13-87

11-16-87

Desert Flycasters,
Arizona Flycasters,
White Mountain Flycasters,
and Trout Unlimited

11-16-87

11-19-87

Paul Marsh, Center for
Environmental Studies,
Arizona State University

11-24-87

12-02-87

Arizona Game and Fish Department

12-01-87

12-04-87

SUMMARY
COMMENTS RECEIVED FROM FWS CONSTITUENTS ON
GLEN CANYON ENVIRONMENTAL STUDIES
SEPTEMBER 1987 DRAFT REPORT

Rob Smith, Associate Southwest Representative, Sierra Club Southwest Office, Phoenix,
AZ Date of Letter: Oct. 28, 1987
Glen Canyon Environmental Studies Final Report represents a great amount of
work and data collection and needs to receive wide distribution with adequate
response time. Comment time is too short and should be 120 days.
Made suggestion of eight environmental groups which should receive the
report. Also suggested that Indian Reservations which border the Colorado
River (Navajo, Hualapai, and Havasupai) and academic experts should receive
the report.
George P. Vlassis, President, Zane Grey Chapter, Trout Unlimited, Phoenix, AZ Date of
Letter: Nov. 13, 1987
The review period of the Glen Canyon Environmental Studies Draft Report
(September) was too short.
Federal Energy Regulatory Commission required by law to give equal consideration to fisheries impact and recreational use as it does to the benefits of
power production.
State and Federal fishery agencies and plans must be considered.
There is a need for more information and analysis for water levels (minimum,
fluctuating, and maximum), periodic replacement of gravel for spawning bars
below the dam, impact of superconducting technology on water releases,
adverse water temperatures, net economic benefit, need for current and
additional power capacity, and alternative sources of peaking power.
Report needs more emphasis on the world-class nature of the trout habitat.
Conservation and enjoyment of the Colorado River Storage Project lands needs
consideration.
A review of the fish and wildlife studies is required under 16 U.S.C.A. Section.
662(b)(2) by U.S. Fish and Wildlife Service and Arizona Game and Fish
Department.
Report should address public need for lands and water.
Further research is warranted.
80

George P. Vlassis (continued)
Report had inadequate distribution, short review time, and confusing format.
Recent low flows at the Lees Ferry reach are harming fish populations.
Dr. Gerry 0. Hall, member of Desert Flycasters, Arizona Flycasters, White Mountain
Flycasters, and Trout Unlimited, Tempe, AZ Date of Letter: Nov. 16, 1987
At flow levels below 5,000 cubic feet per second (cfs): (1) fish are isolated in
backwaters and may die from excessive water temperatures and lack of oxygen,
(2) redds are destroyed, (3) fish food source is destroyed, and (4) stocked and
larval fish become easy prey for adults.
Need to maintain a minimum flow level at 5,000 cfs.
U.S. Fish and Wildife Service needs to coordinate efforts with all government
agencies to safeguard all wildlife.
Paul C. Marsh, Associate Professor, Research, Center for Environmental Studies, Arizona
State University, Tempe, AZ
Glen Canyon Environmental Studies Draft Report lacks data upon which
quantitative assessments can be made. Thus, report cannot be critically
evaluated. Reader must review multiple technical reports.
Report stretches available data beyond reasonableness.
Operational changes at Glen Canyon Dam may help endangered humpback chub,
especially in main channel backwaters.
Additional study is warranted.
Temple A. Reynolds, Director, Arizona Game and Fish Department, Phoenix, AZ Date of
Letter: Dec. 1, 1987
Glen Canyon Environmental Studies Draft Report fails to adequately emphasize
limitations in determining the effects of fluctuating flows on aquatic resources,
due to lack of these flows during the study period.
The report overzealously extrapolates current knowledge of ecological
requirements of aquatic species in the Colorado River and tributaries.
There is an unwarranted distinction made between effects of dam construction
and dam operations.
The trout fishery downstream of Lees Ferry is disregarded.
Report cannot be critically evaluated.
81

I

.;
3201 No.

16th Street•5thte 6A

Phoenix , Arizona

85016

of demand

602.277 8079
,

SIERRA CLUB SOUTHWEST

so

OFFICEPD

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ALE
APA

1997

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AR

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87102

RECEIVED
Daf

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tit

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and Wildlife Service

7::1- ugu-rilue,

Your

Let me request the following modest additions to the mailing list in
hopes that at least the few remaining copies can see broader
distribution. This is by no means an exhaustive list, but merely some
of the more obvious organizations I know about who are regularly
involved in Grand Canyon and related issues:

ii

AfiR
LlE

U.S.

Even the few copies that were printed were not distributed to many of
the parties who ought to receive one. I got a letter a week ago from
Grand Canyon National Park saying I should have already received a
copy of the draft studies, but none has ever appeared. The Fish and
Wildlife Service notice had a distribution list attached that
suggested that each conservation organization would get only one or
two copies regardless of size, and that individuals were completely
excluded. It was incomplete at that.

Fat

D
RBA____
AU
ARW

Cop.,
CtIrdP,

Auto

W.220. 2

- National Parks and Conservation Association, Box 67, Cottonwood, AZ
86326

em.cror.

- Arizona Wilderness Coalition, 2127 E. Osborn, Phoenix, AZ 85016
- Arizona Whitewater Association, PO Box 26028, Tempe, AZ 85282

hosted on October 20 regarding the
and I'd like to express some of my
concerns while there may still be time to do something about

I attJndl the meeting your agency
j..1rn Cany:A71 Frivironm.7:ntal Sludiet,
17.1f:ol
•

.71 .

,

1 :e

,

t

, n2

- Southwest Resource Council, Box 1182, Hurricane, UT 84737
- Grand Canyon Trust, 1660 L St., NW, suite 812, Washington, DC 20036

went into thee studies is iTtprPSSive and the data
will be key to making informed and justifiable decision:: on
- naetement of Glen Canyen Dam, a major influence on the
if Grond Canyen National Fark and its re',OurC ,' S. As you
s were don- in 1..rge part to address th., highly
,
,
: .1
ei r-tential chan .t es in the aat 1 rel,ares frc7m,
hem.
in other matterr. dealing wtth the Grand Canyon,
.
e,Iderrr(:.1 and well-infc.med multitude of people of varied
care dyehly about what qe ,. on there.
r. hlt

- Amr■rican Rivers, 801 Pennsylvania Ave., SE, suite 303, Washington,
DC 20003

turbing to me to see the distribution of
limited and to have so littl , time to
with the quality of comments'you told us you seek.

1 - why

it is quite

di
t. o sever.ly

- Arizona Nature Conservancy, 300 E. University Blvd., *230, Tucson.
AZ 85705
- The Wilderness Society, 234 N. Central, Suite 430, Phoenix, AZ 85004

"NH

rr,72 1937
amiri

.

and to make sure those who can make quality comments can 0 -)

,

.

'eld only 300 copie-, were printed even though this document is
l y to be a key reference work for the debates which will involve
:t; of people before it is over. This limited printing was not
t hourar.,

J1;ifictent in number for even all of the government experts at our
7eetinJt to have a copy. I know of many others who would be interested
rd hAvo useful commonts to make. but I was informed at the meeting
that er.ly a handful of copies remain even now and that the one ( 1)
c:Jpy whIch was sent to the Sierra Club in Arizona maybe all we can
! - 7.puqh copies should be printed to more closely meet the level

,
•=1
.

'41/417„7
1 . *1/

w.-Is surprised to find no Indian tribes on the mailing list even
thou?h the Grand Canyon is an important feature for the Navajo.
Hualapai and Havasupai tribal lands. It was also noted at the meeting
that almost no academic experts were included. These exclusions
seriously detract from the breadth and quality of comment that could
be had; these parties and other similar ones should be identified and
mailed copies.
The November 13 comment deadline seems unusually hasty given that the
Bureau of Reclamation and your agency frequently allow 90 day comment
periods on much less controversial and complex issues. I also heard
the government experts at the meeting say that they had just received
their copies the day before. In this case, given the distribution
problems I've mentioned already and the desire for top-quality
comments, a comment period of 120 days seems fully warranted.
I appreciate very much the work you and the others have put into these

Lit- aft studies and I make these remarks with the hope that the
information you've compiled can be put to best possible use and made a
part of the discussion which will certainly follow on the management
of Glen Canyon Dam.

ZANE GREY CHAPTER
1545 W. Thomas Road
Phoenix, Arizona 85015 6

', '

AGGIGAGI
I

1

November 13, 1987

Thank you for taking these comments into consideration.
Sincerely,
Mr. Jim Young (Attn: Dick Morgan)
U.S. Fish E. Wildlife Service
P. O. Box 1306
Albuquerque, New Mexico 87103

Rob Smith
Ai.sociate Southwest Representative

To Whom It May Concern:
The Zane Grey Chapter of Trout Unlimited for the State
of Arizona obtained a copy of the Glen Canyon Environmental Draft
Report dated September 1987 only within the week past.

x: Senator John McCain
Senator Dennis DeConcini
Rep. Rob Stump
Rep. Mo Udall
Rep. Jay Rhodes

We have been informally advised that a written response
This has been extremely
must be made by November 13, 1987.
difficult to do since the document was almost impossible to
obtain and the sheer size of the report requires extended review.
To review the work of over a hundred researchers compiled over
what appears to be five years is not an easy task even if the
report had been available in September, the date its legend
bears.
Our initial review of the draft study suggests the
following:
1. The September 1987 draft may be part of the process
leading to the relicensing of the Glen Canyon Hydro
Project.
A.
If so, the Federal Energy Reaulatory Commission (FERC) is required by law to give the sare
consideration to the impact on fisheries and
recreational use as for the benefits of power
production.
B.
Recommendations from state and federal
fisheries agencies must be considered, as well as
any existing state or regional fisheries plans.

WECEIVED
is PIG)

FERC cannot relicense a project over the
C.
objections of fish and wildlife agencies unless
specific findings show that the objectives do not
comply with the Federal Power Act.

tisrv

MU 16
Founded in 1959
Over twenty fire years of trout and salmon conservelion
Washington. D.C. Headquarters • 501 Church Street. N.E. • Vienna, Virginia 22780 • 703 281 1100

2. The text and the conclusions of the report are
inadequate with respect to:
A. Water levels:
i)
ii)
iii)

uneven flows;
fluctuating water levels;
appropriate guidelines for minimum
and maximum flow.

B.
Possible need for periodic replacement of
spawning gravel below the dam.
C.
Impact of superconducting technology which
requires less fluctuation of water flow.
D. Adverse water temperatures.
E.
Net economic benefit and actual need for
additional or the current power capacity.
F. Alternative sources of peaking power such as
the Spring Canyon storage site at Lake Mead.
3.
Sufficient emphasis has not been given to the
unique nature of this trout habitat as being one of a
handful of world class fishing attractions on a
national and international basis.

in a format that is confusing and unfocused, thus giving rise to
what may be unfounded suspicions that fisheries, wildlife and
recreation are preordained to have minimal consideration.
Lastly, the recent diminishment in water flow at Lee's Ferry
Low
seems, by simple observation, to be extraordinarily low.
enough to give rise to expressions of concern from public users,
and federal and state field workers who are familiar with the
area that the fish population is being harmed on a current basis.
Given the totality of what is not known, even by an
organization whose primary concern is the preservation and
enhancement of the nation's fisheries, we believe, at the least,
a program of dissemination of information be initiated at once.
This letter should also be deemed a formal request for
the implementation of all state and federal fisheries, wildlife
and recreational use studies mandated by law or allowed as a
discretionary matter.
Further specific requests will be made as we become
more familiar with this matter.
We offer our cooperation and assistance in any way to
facilitate a full review and consideration of this unique natural
resource.
Very truly yours,

4. Little consideration is shown for the requirements
of 43 U.S.C.A. Sec. 620g which refers to the conservation use and enjoyment of these Colorado River Storage
Lands.
5.
No adequate reference or support for the fish and
wildlife studies required under 16 U.S.C.A. Sec.
662(b)(2) by the U.S. Fish & Wildlife Service and the
Arizona Game and Fish Commission has been made and is
hereby requested.
We understand no review of this
nature has been made since the 1950's.

Geo e P. Vlassis, President
GPV:bjl
cc Dave Wegner, GCES
Fish & Wildlife Service, Arizona
National Park Service, Arizona
Arizona Game & Fish
Kenneth Plumb, FERC

6. The totality of the myriad public needs for these
lands and waters has not been adequately addressed nor
has sufficient attention to alternatives been given.
7. The essence of this draft report seem- to suggest
only that further research must be accomplished. With
that, we agree.
The circumstances under which this report has been
pr,-- duced, (a) sparse distribution, (b) short response time, (c)
2

3

•
•

NO.

,

MBER 15, 118;

J'1

.

.1 3
L

r81

MR. JIM YOUNG
U. S. FISH.6 WILDLIFE'SERVLEE'
P. 0. BOX 1105
.1.
:
ALBURQUERQUE, NM 87103

1

RD
DID
RECRIVED

Al.
ARV!
AWE
ALE
Ape
AHR
Cole

NO.V1 9 138
own es WV

11010

04•4 SIVIECO.

for' MR. YOUNG:

SUP.7TT:
AN
110

Adion

LEES FERRY WATER FLOW CONCERN

UPOE

A47
AV
ARIZONA
STATE
UNIVERSITY
Center for Environmental Studies
Tempe. Arirona 85287-1201

MEMBER OF DESERT FLYCASTERS, ARIZONA FLYCASTERS, WHITE
IN FLVCASTER, AND TROUT UNLIMITED I WOULD LIKE TO CALL
your ATTENTION TO A SERIOUS MATTER.

PROBLEM SEEMS TO BE IN MAINTAINING A MINIMUM
THE
ORESENT
FLEW LEVEL OF AT LEAST 5,000 CUBIC FEET PER SECOND THROUGH
t he
RILEE CANYON DAM TO ENHANCE AND MAINTAIN THE WORK AND
,
-FF-:RT, THAT HAS GONE ON TO DATE. IF WATER LEVELS DROP
I,ELCW THIS FIGURE, THE FISHERY EXPERIENCES THE FOLLOWING
prot,:EMS:
1.

FISH BECOME
ISOLATED IN SIDCWATER AND BACKWATER
POOLS. IF ALLOWED TO REMAIN TOO LONG, THE FISH DIE
FROM EXCESSIVE WATER TEMPERATURE AND LACK OF
OXYGEN.

1.

THE

OMMEMS

DEC

0 2.

MOO=
MIMI=
MENEM
MIME=
MIMI=
IMMUNE

87

1.

THE FRESH WATER SCUDS ARE KILLED DUE TO THE LACK OF
ADEQUATE FLOW, RESULTING IN A MAJOR FOOL SOURCE
REDUCTION.

I.

REWLEY HATCHED AND/OR NLANTED FISH BECOME easy pray
TO ADULTS, DUE TO THE LACK OF FINDING A STABILIZED
HIBITAT THEY CAN RELY ON.

1r

lUMMOMM
VIIMMINS

MIME=

7RNESME1011

i n remnon:c: to P reoomat for review cf the craft report cn the
Lao . ..co Ew.ar:r,rentsl Studitt
( SCES,.
I have read the subject
and offs,- the followin9 comments.

•

thr draft 7- Ebert i s uninteroretable because it l acts
data ucon which ouantitative asm.:mments can ts made.
Thus.
.
Is 4■Jrced to review multiple. additional tecnn . :al resorts
, , 1
:7 t.- .■ten as Dt,rt
f ate to have a fair perspective from i.. nich to
i ot , thc ;a - aft rsurt. U4, 4brtunate1v. t ess technical reL,c:ts have
•
ch.lc,
ready a .. ailabilitv: me request 4 22 October ISF.71 fcr copies
PI.
Ferrari Ir!Bt. Haury 196b. leittried an: ilinn
1.1- rer ct :1. 1 4?:1,1.. and Weqner I•E'S WENT UNFUL4ILLEO. E- NE i rave
rseults reported by haddue et al. 1St7 actaInst whir''s-I' the Oran. renort.
C
,

■ ttr■41

r

1 .
2. mit'ino:•. it is clmar that the draft rsoort
oate ts ,srd trm l i mit: of reasonablensoit. This is
,
l y trs ,
r., ,
rd7 rnt=ntial effect: of fluctuatie ilcm: ucco
thrre.:.
s
y te, t. few data ctza:ro::: clurlh9 that
ed i n ?ti 5 d ,
& ft r- DOrt.
witt
cnneltreie:o that orrna -_ist- t
■.-.;. !tI.1:.
.
H.
I .,
t t
..

•

•

•
■

. olrrstan■iinq

.

oi

-

• weo1
drait rootort apnoir: l ucid and wsll
s:, nnet Le
e...Aluated without adsitional
mirinteroretatier.L Cr e:trapclations c4
I.

•

-

-

-

far dEc

. Tary 0. Mall

•

. tic', in the dra4t repert that . ot, t.?
Colorade
rein
e tFrt ,, i n
Thsre stio:t4alle rmorcsent
comtsntion that par ?enm-,.1
et the chsb
trend Canyon mush e•csaas

tie C.

• : - t. t ;.

1

-

•

-r..!

.•

DR. GARY O. n J
510 S. CENCERDO DR.
TENNE, AL 65Z.62

Cafe
fde
Actiog rCL -it 4

MEMMOMM211111

.

REDS (NESTING) ARE DESTROYED.

is that the BUREAU CAN MAINTAIN A MINIMUM
5, -110 CFN, UNLESS WE HAVE BEEN FACED WITH A SERIOUS
SITULTINN. WE ALSO ARE CONCERNED FOR ALL WILDLIFE
THEREFOR, WE ASK
THESE LOW RELEASE PERIODS, AS WELL.
. 0 TR./ AND CUT THROUGH THIS OREPONDERANCE OF RED TAPE
COORDINAT ,"
YOUR EFFORTS WITH THE OTHER GOVERNMENT
ES
INVOLVED IN THIS DECISION AREA, TO AFFORD THE
r1
' 'mine OF THE MINIMUM 5,100 CFS FLOW THAT IS NECESSARY
GUARD OUR CONCERNS.
TO 7
4

SENSES
ONENNE

.

THE ARIZONA GAME AND FISH DEPARTMENT AND MANY OTHER
INTERESTED ORGANIZATIONS, IN OUR STATE, HAVE LABORED
DILY:ENTLY AND EXPENDED FUNDS WITH THE OBJECTIVE BEING TO
root-re LEES FERRY TO ONE OF THE PREMIER TROUT FISHERIES IN
THE WESTERN UNITED STATES, ONCE AGAIN.

'SLAtCooll

iuJ %NMI=

(6 )2) 965-2977
revitor,1e1 Pirsetor
•
FlF and Wildlife Set-,Ice
■
L:o
Now

e

APA
AMR

rnal Ire.

If resew se aryint7
-

0111et Cf IV?

ARIZONA GAME & FISH DEPARTMENT

be ow Glen Cenyon Dam, then they muzA
re==; esDeCially aE
on thet pr ,
much yet to be l ezrned before
be serlovEl ., c:nsiclerea.

r, oi th•
,G:E1, tc artz er, a 9 Jorl st.E.rt
There 1 5
41urtoatirl,) ,low.
Cen7an cen
zt
; ,r,r1 1
•

Glen

,

z ,.■

-

icy this
oamt.

14

zrhect

orq.crtunitv

to comment on the

., ou reauire edditionel
thir zi.cmr,tzry,

.

1 4

dre4t

Glen

Cznvon

in4crmetion. or wth tc
cohtect

.. 49..S5,223

.2:222 Lf,:e

941 -3AR

December 1, 1987
Jim Young
Glen Canyon Executive Review Committee
U.S. Fish and Wildlife Service, Region 6
P.O. Box 1306
Albuquerque, NM 87103
Dear Mr. Young:
This letter and appended comments constitute the Arizona
Game and Fish Department's response to the Service's request for
review of the Glen Canyon Environmental Studies (GCES) Draft
Integration Report (DIR).
I regret that we were not able to
provide the review by the requested deadline. Unfortunately, the
Department's Planning and Evaluation Branch, which handles our
environmental action review procedure, never received a copy of
the report from your agency or any other federal agency. This
has led to some confusion and slowed the departmental review
process.

OD

The DIR obviously represents a great deal of work by the
authors, and they are to be commended for their efforts.
Compilation of more than 30 technical reports into a single,
comprehensive, readable document was indeed a formidable task.
The DIR represents a giant step forward by GCES in furthering our
knowledge of the operation of Glen Canyon Dam and its effects on
the natural resources and recreational opportunities of the
Colorado River in Glen and Grand canyons.
Our comments and criticisms of the DIR are directed mainly
at a few key issues, namely: (1) failure to adequately emphasize
GCES limitations in determining the effects of fluctuating flows
On aquatic resr,urces, an a result of limited availability of
these flown during the study; (2) overzealous extrapolations of
our current knowledge of the ecological requirements of aquatic
npecien in the Colorado River and its tributaries in Glen and
Grand canyons; (3) unwarranted distinctions between the effects
of dam construction and dam operations, and; (4) disregard for
the trout fishery downstream from Lee's Ferry, a recreational
resource of growing importance. I hope that our review is taken

• - C,•.

Apo.,

Mr. Jim Young

-2-

December 1, 1987

in the spirit with which it is intended, as constructive
criticism, and I assure you that the Department appreciates the
We look
opportunity to comment on this important document.
forward to seeing the final version and to future cooperative
efforts in the management of resources in Glen and Grand canyons.
Sine er
//

Temple A. Reyflolds
Director
TAR:dah
cc: Richard Marks, NPS
Dave Wegner, BOR

Mr. Jim Young

-3-

December 1, 1987

Appendix: Page and paragraph citations of Arizona Game and Fish
Department (AGFD) comments on the Glen Canyon Environmental Studies (GCES) Draft Integration Report (DIR)
SUMMARY AND PRINCIPAL CONCLUSIONS

FLOE_

ga_r_a

Fluctuations which occur during critical times of the
3
2
year can negatively impact trout, the endangered humpback chub,
and common native fishes.
Loss of spawning sites, stranding of
fish, desiccation of algae and invertebrate food resources, and
increased mortality of larval fish are effects of fluctuating
flows.
Increased food availability to trout through greater
drift may be a short-term benefit, but could have negative longterm effects on food resource populations (p. B-18, DIR).
Cumulative negative impacts to aquatic resources from fluctuating
flows are sufficient to place these resources on a level with
effects on recreation, and, thus, the banner over this paragraph
should be changed to: Fluctuating Releases Primarily Affect
Recreation and Aquatic Resources.
4
3
There is little, if any, evidence to support the
contention of the banner preceding this paragraph that
Operational Changes Are Unlikely To Help Humpback Chub. Indeed,
the following text suggests that modified operations might
increase chub population size in this area, an obvious benefit.
We are currently unaware of what combination of factors controls
the range of humpback chub in Glen and Grand canyons.
The DIR states that humpback chub rearing is now
restricted to the mouth of the Little Colorado River (LCR) at its
confluence with the mainstem. Present knowledge of humpback chub
in the LCR does not include the linear extent of this tributary
used for either spawning or rearing purposes.
Kaeding and
Zimmerman (1983, P. 588) noted the possibility of upstream
reproduction, and they collected Age 0 chub throughout most of
the Little Colorado below Blue Spring.
AGFD personnel have
collected spent humpback chub below Blue Spring and what appear
to be chub eggs in drift samples above the mouth of the LCR.
The next to the last sentence should be changed to
"... unsuitable habitat for spawning and rearing chub."

Mr. Jim Young

Ba_ge

-4-

December 1, 1987

-5-

December 1, 1987

r_a_ge

p_ara

It may be argued that there is only one humpback chub
5
1
population in the Colorado River between Glen Canyon Dam and Lake
Mead, but there is no strong evidence for a "...humpback chub
GCES (AGFD) tagpopulation in the Little Colorado River."
recapture data showed that humpback chub move from the mainstream
into the tributary from distances of at least 10 km (p. 9-18,
DIR, see also Kaeding and Zimmerman 1983), and numerous young-ofthe-year chub were collected from mainstream backwaters below the
LCR. It is highly probable that many humpback chub in the study
area utilize both the tributary and the mainstem for completion
of their life cycle.
GCES data were insufficient to state with certainty
that current operations (of Glen Canyon Dam) do or do not have a
Dam
deleterious impact on humpback chub in Grand Canyon.
operations during the period of the study consisted largely of
high, steady flows. Fluctuating flows were not provided during
the time of year when early life stages of humpback chub would be
We have hypothesized that high
rost susceptible (p. 14 DIR).
steady flows during May and June would be beneficial to early
No experimental teats of this
life stages of humpback chub.
hypothesis have been conducted, but based on information at hand
we recommended this modification to dam operations in our GCES
In contrast, our
report (see also pp. 62-64 of DIR).
observations suggest that fluctuating flows may negatively impact
early life stages of humpback chub both in the mouth of the LCR
This paragraph misstates our
and in mainstream backwaters.
conclusions, and we suggest strongly that it needs to be
rewritten. Note also that p. 12 of the DIR states that the Fish
and Wildlife Service concluded in 1978 that construction and
operation of Glen Canyon Dam has jeopardized the continued
existence of humpback chub. To date, this opinion has not been
rescinded.

DRAFT REPORT
Estimated angler use figures for the Lee's Ferry
9
1
reach in recent years have greatly exceeded 10,000 anglers/year.
The range of estimated anglers/year for the period 1980-1985 was

18,986-52,725.

Mr. Jim Young

Here and throughout the report, the trout fishery
While certainly not utilized to
below Lee's Ferry is ignored.
the same extent as the Ferry reach, many commercial river trips
ve anglers aboard who fish. Furthermore, many people hike to
This
tributaries
such as Bright Angel and Nankoweap creeks.
E,
gment of the sport fishery should not be ignored.

1
Are the authors sure that the public's questioning of
11
the BOR environmental assessment (FONSI) was due to a blurring of
the difference between Peaking Power and the Uprate and Rewind
Program?
II-1
14
Use of the term "flow range" in Table II-1 is
confusing. We assume that these flows are minimum, maximum, or
mean daily values and the percentages of days in which these
flows occurred.

15

1

Text missing.

3
According to AGFD records, average size (length and
21
weight) of trout caught in the Lee's Ferry area peaked in 1980.
Fishing pressure peaked in 1983 with an estimated 52,725 anglers
visiting the Ferry; user-days at 8 hours/day were 44,816.
Changes in AGFD regulations were instituted more to
reduce fish harvest than fishing pressure.
30
2
Here and elsewhere in the DIR the statement is made
that humpback chub spawning is restricted to the LCR. This may
not be entirely accurate for other investigators found ripe
females in Shinumo Creek, and we observed what appeared to be a
spawning aggregation in Havasu Creek. Furthermore, Kaeding and
Zimmerman (1983) suggested that chub may well spawn in the
mainstream, but that these waters are probably too cold for
hatching of most eggs.
35
4
GCES information shows that winter flows of 1,000 cfs
are detrimental to both the Lee's Ferry trout fishery and to
downstream trout attempting to gain access to tributaries for
spawning.
Not only are trout negatively impacted, but in the
Lee's Ferry area the safety of trout fishermen and their
equipment is jeopardized.
We feel that this minimum flow is
insufficient for AGFD to fulfill its commitment both to wildlife
and fishermen.
38
3
On pp. 33-35 of the DIR, it is stated that power
production is one of several objectives of Glen Canyon Dam that
are incidental to the primary functions of water storage and
delivery. Here it says that the dam must be operated to produce
the greatest practical amount of power.
Does power production
take precedence over other incidental objectives? If the

Mr. Jim Young
PASe

-6-

December 1, 1987

EAre

(continued) maximization of power production results
3
38
in real dollar losses to other incidental objectives, are these
losses to be compensated and, if so, how? The DIR needs to
clarify these points.
Flow sensitive aspects for humpback chub should
47
All
include mainstream backwaters as rearing habitat; access to
tributaries for spawning is also important to downstream trout.
Recreational use of the Lee's Ferry fishery is
highest during the period September to April, but fishing in this
Boating safety and angling
reach is a year-long occurrence.
quality are thus sensitive to flow impacts during the entire
year.
53
"Once chub reach a size that allows them to survive
4
in the mainstem river, dam operations have few direct impacts on
them." The term dam operations should be replaced by floods in
keeping with the context of this section. The sentence as it
stands is tautological, and it may well be that dam operations
determine the size at which chub can survive in the mainstem.
Furthermore, we see little difference between "direct" and
indirect impacts of dam operations as they affect this endangered
species.
Both types of impacts should be considered in an
analysis of this sort.
57
1
The volumetric proportion of amphipods increased
during a 3-day period in October 1984 when flows were decreased
dramatically and held low. Long-term effects of increased drift
have not been examined and may prove detrimental to food resource
populations (see comments for Summary, Page 3, Para 3).
We do not know at what size most young humpback chub
57
3
move out of the Little Colorado River or what proportion of young
Passive movement (drift) of
individuals leave the tributary.
eggs or larval chub have not been investigated sufficiently to
Certainly, we do not know that young
justify this statement.
chub wait until they reach a certain size to move into the
Furthermore, we do not know what impacts occur to
mainstream.
young chub in backwaters under conditions of fluctuating flows.
It may well be that larval chub (or eggs) experience very high
mortality if they are carried into the cold mainstream waters
This paragraph should be
during periods of fluctuating flows.
rewritten as should Figure VI-7, P. 58 and its caption.

Mr. Jim Young
Page

-7-

December 1, 1987

Ea_ra

The results of GCES must be viewed in the context of
58
3
the limited availability of fluctuating flows and the consequent
restrictions on our ability to determine their effects on aquatic
resources. The discussion of relative effects of flood releases
and fluctuating flows does not recognize this major shortcoming.
62 Banner There seems to be a conflict between this banner and
the one on p. 4 of the Summary and Principal Conclusions section.
Certainly, the discharge scenario presented here would be a
modification of current dam operations designed to maximize power
production.
4
62
The continuation sentence from
no sense. Something is missing.

P.

62 to p. 64 makes

3
64
As indicated, the scenario of preferred flows for
native fishes is based on limited information. It assumes that
maximizing backwater numbers during a three-month period with low
flows, coupled with steady flows during the remainder of the
year, optimizes conditions for these species. This seems like a
great extrapolation of our limited information on the ecological
needs of these species; particularly when one considers that they
evolved in a desert river system characterized by large annual
floods and great variation in year-to-year flows.
2
66
A sustained decrease in flow from 26,000 cfs to 5,000
cfs would result in a major loss of habitat space for both fish
and their food resources at any time of the year. Would this
have no negative effects?
3
74
The text following the banner considering the effects
of the Uprate and Rewind Program hardly follows the banner, which
contends that these effects cannot be assessed.
In fact, the
text points to increases in the amplitude and rate of change of
fluctuations, which would have negative impacts on most
resources.
77
2
This paragraph, as elsewhere, disregards the effects
of low and fluctuating flows on the downstream fishery, which is
dependent upon natural reproduction that occurs largely in
tributaries. The reach of the Colorado River in Grand Canyon is
one of the few places in the conterminous United States where
trout fishermen can experience the pleasure of fishing for "wild
trout" that are generations removed from the parent hatchery
stock.

Mr. Jim Young
p_age

-8-

December 1, 1987

Pr_a

77
3
How can modifying the intake structure of Glen
Canyon Dam and routing water from higher levels in Lake Powell be
considered a non-operational alternative? This most certainly
involves changes in operations as well as new construction.
78
2
Most marshes in Grand Canyon apparently were formed
after flow regulation was initiated in 1963 (pp. A-42, B-9, DIR).
If marshes formed naturally under dam operations (limited floods)
during this period, why would non-operational measures be
necessary to reestablish these streamside habitats?
81
1
Here, and elsewhere in the report, reference to
fluctuating flows should acknowledge that the effects of these
flows on aquatic resources could not be adequately determined by
GCES. High runoff and far above average inflow into Lake Powell
made difficult the delivery of fluctuating flows necessary for
GCES to evaluate their effects on aquatic resources. Sufficient
fluctuating flows during periods critical to native fishes were
not available to our researchers (see p. 14, DIR and comments for
page 5, paragraph 1 of this review).
82
3
Again, we do not know what the long-term effect of
fluctuating flows would be on humpback chub. This paragraph and
paragraph 5 following seem to be contradictory; the first
suggests no long-term effects for most resources, while the
latter states that approximations to steady releases will cause
least degradation to most environmental resources.
82
5
No comparative measurements of trout growth were made
under -onditions of steady and fluctuating flows. We know only
that in the short-term more food is available to trout under
fluctuating flows.
82 S-9
The contention that reducing vulnerability of humpback
chub can be realized only through non-operational alternatives is
net supported.
Again, we have proposed, and the DIR contends
repeatedly, that high, steady flows during May and June might
benefit the chub. It certainly is also probable that reductions
in fluctuating flows could benefit spawning and immature chub in
mainstream backwaters.
Backwaters largely isolated from
mainchannel water circulation warm appreciably as evidenced in
our GCES report. It may be that these areas would serve as
spawning habitat for mainstream chub under sustained, optimum
flow conditions prior to and during the reproductive period.

Mr. Jim Young
IPAG

-9-

December 1, 1987

EARGI

Humpback chub reproduce successfully in pond
8-9
82
environments at the Fish and Wildlife Service hatchery in Dexter,
New Mexico. Any discussion of warming the entire mainstem river
should include the potential to increase the distribution and
abundance of fishes that might be competitors with or predators
on humpback chub.
We recommend full support for pursuit of the
4
83
management options expressed on pp. 83-84 of the DIR. We would
emphasize that if monitoring programs had been in effect since
building of Glen Canyon Dam, many presently unanswered questions
concerning critical resources and dam operations might have been
resolved.
APPENDIX B
Does this statement adequately portray peregrine
5
8-25
importance in the Grand Canyon? It is true that they nest there
in small numbers, but these numbers are probably higher than
anywhere else in Arizona. The National Park Service has funded a
three year study to investigate this species in Grand Canyon.
8-30 Table B-2 Here it says that fluctuations are not likely to
have a direct effect on riparian birds. Elsewhere it is stated
that some of the obligate riparian species nest 2-3 feet above
water level, yet fluctuations of up to 13 vertical feet are
possible. Will these nests be inundated?
Again, fluctuating flows were limited during this
3
8-31
The first sentence here, and elsewhere in the report,
study.
does not adequately address problems that ca. 150% of average
inflow into Lake Powell caused not only AGFD researchers, but
other GCES researchers, power managers, etc.
What about downriver reproduction of trout and loss
2
8-51
of the aesthetic value of catching naturally reproduced fish?
Kaeding, L. R. and M. A. Zimmerman. 1983. Life
Reference:
history and ecology of the humpback chub in the Little Colorado
and Colorado rivers of the Grand Canyon. Transactions of the
American Fisheries Society 112:577-594.

APPENDIX E: CONSTITUENT GROUP COMMENTS
PART III: NATIONAL PARK SERVICE CONSTITUENCY
I NDEX
COMMENT LETTERS
GLEN CANYON ENVIRONMENTAL STUDIES
SEPTEMBER 1987 DRAFT REPORT
Entity

Letter Date

Date Received

Grand Canyon Chapter Sierra Club

11-13-87

11-16-87

Colorado Plateau, Friends of the River

11-10-87

11-12-87

Sleight Expeditions

11-13-87

11-17-87

11-10-87
Southwest & California Representative
National Parks & Conservation Association

11-19-87

11-12-87
Grand Canyon Commercial Outfitters:
11-13-87
Arizona Raft Adventures, Inc., Flagstaff, AZ
Arizona River Runners, Phoenix, AZ
Canyon Explorations, Inc., Flagstaff, AZ
Canyoneers, Inc., Flagstaff, AZ
Colorado River & Trail Expeditions, Salt Lake City, UT
Cross Tours & Expeditions, Inc., Orem, UT
Tour West, Inc., Orem, UT
Moki Mac River Expeditions, Inc., Salt Lake City, UT
OARS, Inc., Angel Camp, CA
Outdoors Unlimited, Lotus, CA
Diamond River Adventures, Page, AZ
Expeditions, Inc., Flagstaff, AZ
Georgie's Royal River Rats, Las Vegas, NV
Grand Canyon Dories, Inc., Menlo Park, CA
Grand Canyon Expeditions Co., Kanab, UT
Hatch River Expeditions, Inc., Vernal, UT
Sleight Expeditions, Inc., LaVerkin, UT
Western River Expeditions, Inc., Salt Lake City, UT
White Water River Expeditions, Mariposa, CA
Wilderness River Adventures, Page, AZ
Arizona River Runners, Inc.

11-10-87

11-12-87

Arizona Raft Adventures, Inc.

11-10-87

11-10-87

Outdoors Unlimited Raft Trips

11-06-87

11-10-87

Peter Reznick

11-10-87

11-13-87

The Arizona Nature Conservancy

11-30-87

Unknown

91

SUMMARY
COMMENTS RECEIVED FROM NPS CONSTITUENTS ON
GLEN CANYON ENVIRONMENTAL STUDIES
SEPTEMBER 1987 DRAFT REPORT
Joni Bosh, Chairperson, Grand Canyon Chapter, Sierra Club, Phoenix, AZ 85016 Date of
Letter: Nov. 13, 1987
Glen Canyon Environmental Studies Draft Report successfully presented vast
array of separate bits of data, but is not complete or adequate enough upon
which to base operation decisions.
Why were so few copies made available to agencies and the public?
Comment time too short, implies that the Bureau of Reclamation did not want
public comment and participation.
Strongly urge a full environmental impact statement be completed before any
changes to dam operations are instituted.
Colorado River Storage Project rules should be modified to account for
environmental effect of dam operations, and importance of environmental
protection should not come last after power production, water retention and
other uses of the river.
Robert Lippman, Colorado Plateau Representative, Friends of the River, Flagstaff, AZ
Date of Letter: Nov. 10, 1987
Recreational values, interests, and downstream environmental impacts of Glen
Canyon Dam were not being afforded the proper consideration in the early
1980's.
The Glen Canyon Environmental Studies confirmed the "obvious" substantial
adverse effect on downstream environmental and recreational resources.
The development of long range operating criteria, documentable trend to
maximize peaking releases, and enhancing power revenues in a carefully defined
power brokerage scheme are "major federal actions" necessitating National
Environmental Policy Act consideration.
Floods and fluctuating releases adversely impact existing park resources and
values.
Operating criteria were shown by the 1983-84 "flood" to be grossly out of
balance with competing uses, resources and considerations, and with general
concepts of prudent conservative operations.
Fluctuating flows observably may have had a greater impact on beach stability
than indicated by draft report.
92

Robert Lippman (continued)
National Park Service should support proposals for modified operations which
mitigate present level of impacts by dam operations.
Environmental Impact Statement on modified operations is long overdue.
Recommend that National Park Service should actively and affirmatively
encourage an accelerated Environmental Impact Statement process and Glen
Canyon Dam releases be modified to a base loaded pattern subject to water
availability and delivery commitments.
Steady flows of 25,000 to 30,000 cubic feet per second for the April through
October season should be followed as it would permit beach stabilization and
enhance most identified "critical resources".
Sleight Expeditions, P.O. Box 40, St. George, UT 84770 Date of Letter: Nov. 13, 1987
Protection of Grand Canyon environment is critical until all aspects of impact
on the Grand Canyon can be determined.
Dam releases have increased both the safety and quality of white water
recreation.
An operating scenario which protects beaches, terrestrial vegetation, wildlife,
and recreation would be preferable.
Flood releases should never occur for the protection of the Grand Canyon
environment. Low flows (below 8,000 cfs) and rapid fluctuations (3,000 to
31,000 cfs) need to be avoided.
More research needed before sound judgement can be made on: low flows,
fluctuating flows, high flow effect on endangered species, how flows relate to
beaches, and how flows relate to safety and quality of boating.
Flow scenarios too incomplete to judge which would most benefit the Grand
Canyon resource and inconclusive in deciding which would have precedence
over others in protecting the environment.
Need to study how to ensure continuation of common native fish and humpback
chub before any modification of dam operations is implemented.
All issues need to be carefully studied before any modification to dam
operations are put into effect.

93

Russell D. Butcher, Southwest & California Representative, National Parks and Conserva
tion Association, Cottonwood, AZ Date of Letter: Nov. 10, 1987
Glen Canyon Environmental Studies Draft Report confirms that the dam has
grossly altered and manipulated sedimentation, turbidity, aquatic life, riparian
habitat, terrestrial wildlife, and white-water recreation.
Suggests that Glen Canyon be operated in order to place greatest emphasis on
values and resources that have higher priority. Urges that the following list
receive priority attention:
(1) Humpback chub: this federally listed, endangered, native fish
species must be accorded special management emphasis. Its jeopardy
status must be addressed by meaningful dam operations to assure
fish's survival and enhancement in the park.
(2) Erosion of sediments from river channel and river banks must
be slowed as much as possible by restricting flood releases.
(3) Sharp daily fluctuations caused by peaking power should be
eliminated or greatly reduced so not to impair white-water recreation.
(4) Other native species of fish and habitat requirements need to
be protected and enhanced while taking into account the aforementioned priorities.
(5)
Enhancement of artificially expanded terrestrial wildlife and
related riparian habitat, but not at the expense of the priorities
listed above.
Efforts should be enacted to mitigate impairments caused by dam construction.
Develop best set of priorities for management.
Continued professional
monitoring and research is necessary to fully understand impacts and to
improve operations of the dam for the welfare of Grand Canyon National Park
and its resource values.
Funding for on-going monitoring and research program should be derived from
dam revenues.
Combined response letter from 20 Grand Canyon Concessionaires, Date of Letter: Nov.
12, 1987.
Although Glen Canyon Environmental Studies Draft Report states that flows
from Glen Canyon Dam have been beneficial to commercial and private river
running by attenuating seasonal flow extremes (high and low), it fails to
mention that water releases have prevented river running for six weeks in

94

Grand Canyon Concessionaires (continued)
August-September 1973, six weeks in May 1977, and two weeks in June 1977.
Also, there have been low water problems every year which lead to inconveniences, damaged equipment, injured passengers, and helicopter evacuations
of passengers, boats, and crew.
Surplus water has been released during winter months and by daily spikes
which are of little use to river runners and recreationists.
Interests and opportunities of white-water boaters should be major factor in
the operational management of Glen Canyon Dam.
Propose operational changes: (1) Minimum releases from the dam to be at
least 5,000 cfs and a maximum of 28,000 cfs from October 1 through March 32,
and (2) release summer runoff in the summer similar to pre-dam pattern with
minimum at 11,461 cfs and maximum of 28,000 cfs. This will yield an annual
average of 8.23 million acre-feet.
Urge continuation of environmental studies and funding for them.
Bruce Winter, Arizona River Runners, Inc., Phoenix, AZ Date of Letter: Nov. 10, 1987
Glen Canyon Environmental Studies Draft Report supports observation that
operation of the dam has an adverse effect on the Grand Canyon and river
users downstream of the dam.
Short-term and daily fluctuating flows are causing irreversible loss of sand and
beaches, thus negatively impacting recreation and other aspects of the Canyon.
Flood releases above 31,500 cfs and resultant erosion are causing extreme
damage to beaches, vegetation and wildlife habitat, and eliminating camping
sites. Flood flows also have negative impact on safety of white-water boating
and angling.
Flows below 5,000 cfs have negative impact on almost all users and should be
avoided.
Bill Wasley, Operations Manager, Arizona Raft Adventures, Flagstaff, AZ Date of
Letter: Nov. 10, 1987
Glen Canyon Environmental Studies Draft Report documents observations shared
by many who have seen the damage caused by fluctuating flows.
Hoover Dam should be operated to producing peaking power while Glen Canyon
Dam should be operated as a base-load plant for electrical needs.
Sand on the beaches and river bottom are disappearing and not being
replenished. Destruction of beaches is detrimental to the entire environment
of the Grand Canyon.
95

John Vail, Outdoors Unlimited River Trips, Lotus, CA 95651 Date of Letter: Nov. 6,
1987
Past and present operations of Glen Canyon Dam have caused two significant
changes in Grand Canyon: (1) beaches have been lost due to extreme daily
fluctuation in flow and loss of replacement silts and clays, and (2) composition
of beaches have been altered by water fluctuations and high water releases.
Proposes study to include three phases for mitigation of the loss and alteration
of beaches:
(1) Flow reductions of no more than 10% per day, not to exceed 1
percent per hour.
(2) During November through February use suction dredges to restore
critical beaches by pumping sand from adjacent river bottom.
(3) Retrofit the dam for a silt bypass to be supplied by sand/silt
slurry or sand barges.
Peter Reznick, 1460 W. Palmer Ave., Flagstaff, AZ 86001 Date of Letter: Nov. 10,
1987
Theories that sand beaches may be replenished by side canyons bringing
enough silt for resupply may be incorrect.
Andy W. Laurenzi, Field Representative/Public Lands, Arizona Nature Conservancy,
Phoenix, AZ Date of Letter: Nov. 30, 1987
Principal conclusions of the Glen Canyon Environmental Studies Draft Report
in regard to possible effects of current and modified operations on humpback
chub are misleading and not adequately demonstrated by the data presented.
Operational changes are likely to help humpback chub.
Time length of study is too short. Continued monitoring for several years of
key natural resources, both biological and physical, necessary before a
reasonable decision can be made about how dam operations affect resources.

96

SIERRA CLUB
Grand Canyon Chapter • Arizona
2127 E. Osborn

Phoenix,_E C: 85,0,1fi

r.,

Nov 16 '87

November 13, 1987

Dick Marks, Superintendent
Grand Canyon National Park
PO Box 129
Grand Canyon, AZ 86023

operations changes are either unknown or would have a significant impact.
While the theoretically best option would be to tear the dam down and let the
river run naturally, that isn't the best scenario for the river with the
dam in place. High flows will destroy the beaches and the riparian habitat,
which is one of the longest in the state even if created artificially.
Monster fluctuations will do the same. Further, it is conceivable that,
had the high waters of 1983 been released just a bit later, the vegetation
that reemerged would have been composed primarily of native species. Also,
non-operational changes should be fully investigated before any decisions
are made.
Lastly, the fact that environmental protection of an internationally
recognized park comes last after power production, water retention and
other uses of the river is disturbing and outdated. The Colorado River
Storage Project rules should be modified to account for environmental
effects of dam operations:
Thank you for this chance to comment.

Dear Mr. Marks,

Sincierely,

On behalf of the Grand Canyon Chapter of the Sierra Club, I'd like to
respond to your request for comments on the Glen Canyon Environmental
Studies Draft Report. There are, indeed, several points we think should
be carefully considered.
1/40

First, the overall impression is that this first round report pulled
together a vast array of separate bits of data, and did so successfully.
However, as a first attempt it is not complete or adequate enough to base
any operations decisions upon. For example, the report, as far as I can
v:7'1, lacks even the simple data on where beaches are located or have
been redistributed. Several of the beaches that formed after the high water
in 1983 disappeared by the end of 1984. I also am interested in seeing
the data that supports the contention that 30,000 cfs is preferred by whitew“ter enthusiasts. At flows of 28,000 cfs and above is when river running
i,:)blems and accidents start to occur at Crystal Rapids.
Second, after four years or more of work, why in the world did the agency
make only 300 copies available to other agencies and the public? I've been
aged for copies by several people (whom I referred to your agency) and loaned
my copy to one other person. It is inconceivable to me that after so many
people have expressed interest in Glen Canyon Dam that so few copies would
he available.
Third, it is hard to believe that the agency really wants to hear from
the public. Allowing well less than 30 days for comments on a document
that took more than four years to write boggles the mind. Does_the Bureau
of Reclamation not want public comment and participation, or do they not
intend to take comments seriously? How can they expect to get thoughtful
comments in such a short amount ofttime? I've had my copy for only 18 days.
I read appendix D once and need to review it more carefully, especially
the information on 602 (a) that regulates some dam operations.
Fourth, we would strongly urge that a full environmental impact statement
be completed before any changes to dam operations are instituted. As
brief as the GCES is, it is obvious that the impacts associated with
Printed on 100% Recycled Paper

Joj
Joni Bosh, Chairperson
Grand Canyon Chapter, Sierra Club

FRIENDS OF THE RIVER
1 01 LIM

— Colorado Plateau

Birth Strert • P.O. Box 1115 • Fliagstali,Ar

zon.1

10,002 • (602) 774-0130

..- Gan an 1■1:Arn-r,F
NOV

1 2 '87

November 10, 1987
77-7

Mr. Richard Marks, Superintendent
Grand Canyon National Park
P.O. Box 129
Grand Canyon, Arizona 86023

7

"7—

7.7

_

Re: Comments on Glen Canyon Environmental
Draft Report
Dear Mr. Marks:
As you know the GCES were undertaken largely as a response to
the public and technical controversy generated by the Glen Canyon
Power Plant expansion project proposal and the rewind and uprate
program (or "Peaking Power Project") in the early 1980's. At
that time, it was clearly articulated that recreational values
and interests long institutionalized by the National Park Service
at Grand Canyon National Park were not being afforded the proper
consideration justly due in the prioritizing of Glen Canyon Dam
op.-rations and uses, and that the downstream environmental
impacts were totally ignored with no efforts at mitigation.
The draft report indicates several critical factors which now
ju:-.ify the informed proposing of alternative operating criteria
at lien Canyon Dam and the institutionalizing of recreation and
downstream ecological protection as a "purpose" or priority in
the operating criteria.
First, the GCES confirmed the "obvious" observable phenomenon
that the existence and subsequent operations of Glen Canyon Dam
have "substantial adverse effect on downstream environmental and
recreational resources."
The development of long range operating criteria and the
documentable trend to maximizing peakina releases and enhancing
power revenues in a carefully defined power brokering scheme,
are, "major federal actions" occurring subsequent to the passage
of the National Environmental Policy Act, although the Dam itself
b/ w constructed prior to the ACE. Any new proposal to modify the
operations and releases would also be a "major federal action"
due to its far reaching effects.

Second, the impacts of flood and fluctuating releases
documented by the study adversely impact existing park resources
and values (i.e. the riparian ecology, beaches and terrestrial
resources, as well as recreational values and experience).
It is noted here that recent operations and flood releases
have violated one of the primary present operating criteria being
simply that "spills are to be avoided." The 1983-1984 "flood"
situation clearly illustrated how the gradual trends to promote
water storaae and enhance power revenues above all other uses,
resources and considerations have resulted in further impacts and
depredations to those ignored uses, resources and considerations,
i.e. recreation and the downstream riparian environment. The
operating criteria were shown to be grossly out of balance with
competing uses, resources and considerations, and with general
concepts of prudent conservative operations.
It is also noted that fluctuating flows observably may have
had a greater impact on beach stability then indicated by the
draft report, especially considering that fluctuating flows were
not the norm during the study period.
Third, as modified operations have been shown to
in mitigating the present level of impacts caused by
operations, and in protecting or even enhancing most
resources, it appears that the National Park Service
support proposals for such modified operations.

have value
dam
downstream
should

Such proposals, for the above noted reasons, would r eauire
the preparation of an environmental impact statement which again
is long overdue regarding the impacts of Glen Canyon Dam.
Friends of the River thus supports the articulation of a
preferred Proposal for modifyina operations to protect and
enhance downstream resources and values, via an accelerated EIS
. process. We therefore recommend that the National Park Service
propose that releases from Glen Canyon Dam be modified to a base
loaded pattern subject, of course, to the Physical constraints of
water availability and delivery commitments, and that the
National Park Service actively and affirmatively encouraae the
executive committee representina the participating agencies in
the GCES to t each consensus on such a recommendation. That
r ecommendation and consensus should be forwarded to the Secretary
of the Interior for the immediate establishing of an accelerated
EIS process addressing the proposal.

SLEIGHT EXPEDITIONS
Friends of the River would, at this time, under the
unfortunate realities of Glen Canyon Dam's presence, recommend
that releases on the order of those described in the scenario for
"fishing and white water recreation" (pages 70 through 71; Figure
VII - 5) be proposed as the preferred alternative, as high flows
( but not flood flows) have been shown to be the most preferred by
recreational interests for safety and quality of experience.
Steady flows of 25,000 to 30,000 cfs can be achieved during the
peak river running seasons, (April through October), would permit
beach stabilization, and would enhance most identified "critical
resources".
In contrast, it has been our position since the "peaking
power project" that the monthly and daily release patterns as
proposed by the Western Area Power Administration (Appendix D,
Pages D-21 to D-22) are completely unacceptable and extremely
damaging to all critical resources.

LO
LO

National Park Service support for the Grand Canyon
Environmental Studies, as well as this opportunity for
participation, are most appreciated by Friends of the River. We
trust that the opportunity to mitigate this most far reaching
resource problem at Grand Canyon National Park will similarly be
appreciated by the Park service throuah its affirmative advocacy
of the above proposal for modifying operations at Glen Canyon
Dam.
Sincerely,

Robert Lippm
Colorado P),4

VILEIGEXIDRURRA.IXTIBOMIAIMVIITAIRAIDASILORM.IIITIOR6354141
.DIX
PO Box 40. St. George. Utah 84770 (801) 673-1200

November 13, 1987
Grand Canyon National Park Service
Attn : Superintendant Richard Marks
Post Office Box 129
Grand Canyon, Arizona 86023-0129
RE: Glen Canyon Environmental Studies Draft Report
Comments :

E!'l 17 T7

77,
•

Dear Sirs.
We appreciate the opportunity to assess the findings and
conclusions of this report, and the opportunity to express our
opinions and comments.
In reviewing the report, we recognize the fact that since
the dam was created , the Grand Canyon has become a completely
new and transformed environment. We beleive that protection of
this environment is critical. This environment needs to be fully
protected until all aspects of the impact on the Grand Canyon can
be determined.

au Representative

PL/tIc
cc: Dave Wanner, U.S. Bureau of Reclamation
Upper Colorado Reaion

White-water recreation (as stated in the report) would
probably be at or near the level of activity it is now. But the
Glen Canyon Dam has certainly provided a less dramatic flow,
because of its regular seasonal flow levels, which has increased
both the safety and quality of the white water recreation.
In the Glen Canyon Environmental Studies suggested operating
scenarios: the scenario that protected the beaches, terrestrial
vegetation and wildlife also benefits the white-water. recreation.
These two different aspects can work hand in hand together
creating a quality environment of beaches, different vegetation
and wildlife habitat which all add to the white-water
enthusiast's experience and enjoyment of the Canyon.

_

List of Important Issues
Protection 6 Maintenance of the existing environment. As
stated in the report, flood releases and fluctuating releases
were found to have negative impacts on downstream resources. It
,Iso stated that flood releases occur one in every four years.
"hese flood releases cause irrepairable damage to the downstream
eaches, vegetation and wildlife. Even 1 flood release in 20
-ears is too often I The Glen Canyon Dam operation needs to be
hanged so that Flood releases may never occur for the protection
of the Grand Canyon Environment.
Also, low flows (below 8,000 cfs) and drastic fluctuations
of between 3,000 cfs and 31,000 cfs need to be avoided. The
ideal recreation level may be for flows between 8,000 cfs and
20,000 cfs. This flow should be consistent enough to protect the
Grand Canyon Environment.
More Data is Needed. It is clear from reveiwing the Draft
Report that much more research is going to be needed before sound
judgement can be made in regards to the Grand Canyon Dam
Operational Flow. Especially more data is needed on
1
2
3
4
5

Low Flows (below 10,000cfs)
Fluctuating Flows (3,000cfs to 31,000cfs)
How Flows effect endangered species.
How the Flows relate to the Beaches.
How the Flows relate to safety and quality of Boating.

All the flow scenarios are too incomplete to judge which
would most benefit the Grand Canyon Resource and are inconclusive
in deciding which scenario would have precedence over the others
in protecting the environment.
Concern Over Endangered Species. How to best ensure the
continuation of the comman native fish (which needs a quiet, warm
backwater for proper growth and survival) and the Humpback Chub
( which represents 80% of the total population) needs to be
studyed more fully before any modification of the Dam Operation
is implemented.
In Conclusion.
All issues should be carefully studied
before any modification to the operations of the Glen Canyon Dam
are put into effect. Only through continued and careful study
can a modification be chosen that will benefit the majority of
the resources. Again, we appreciate the opportunity to express
our concerns over the issues and look forward to discussing these
concerns with the different agencies, so that they can provide an
operating scenario that can fully protect the natural resources
in the Grand Canyon.
Sincerely,
Sleight Expeditions

NATIONAL PARKS
1701

& CONSERVATION ASSOCIATION

Eighteenth Streit, NM.. Washington, D.C. 20009
(202) 265-2717

RUSSELL D. DUTCHER
Roronal Illipmentsrtis■

.—

SOUTHWEST a caupDawA
Bob, 67
Cottonwood. AZ 86326
(602) 634-5758

VLI.)
:110:12 1

November 10, 1987
GLEN CANYON ENVIRONMENTAL
STUDIES DRAFT TECHNICAL
WORT, September 1987
,
"

Mr. Richard W. Marks
Superintendent
Grand Canyon National Park
P.O. Box 129
Grand Canyon, AZ 86023
Dear Dick:

,EF,
,
-

—

National Parks and Conservation Association, a nonprofit
membership organization founded 68 years ago to promote the
protection, enhancement, and public understanding of the National
Park System, appreciates this opportunity to offer preliminary
comments on the September 1987 "Glen Canyon [Dam] Environmental
Studies Draft Technical Report."
We first want to say how impressed we are with the thoroughly
professional quality of this document. The many persons involved
with its preparation deserve to be commended.
As for the document's conclusions as to the state of affairs
downstream from Glen Canyon Dam, they unfortunately and certainly
assur.4,tioi,s :.-1,7.- 6c at t!..-2 time the dam war built and put into
operation that a project of this magnitude would inevitably drastically change what had always been a naturally functioning ecosystem-which Grand Canyon National Park was established to protect. For
the dam has grossly altered and manipulated sedimentation, turbidity,
aquatic life, riparian hauitat, terrestrial wildlife, and whitewater recreation.

Because the complex interrelationships have been so dramatically
changed, it is, as the document so well points out, no easy matter
to find ways of operating the dam so as to enhance the array of disrupted natural ecological processes and needs, and to enhance, as
well, the visitor's use and enjoyment of the river.
For instance, to minimize the process of "flushing" sediments

2-Glen Canyon dam impacts draft report

on through the Grand Canyon and into Lake Mead (sediments that
in post-dam years are coming into the Canyon at but a small fraction of pre-dam sediment load), the dam should be operated to
avoid flood flows. Yet, floods are needed to keep the quantity of
boulders at rapids from steadily accumulating and building themselves into massive barriers that are hazardous to and disruptive
of white-water boating. (Actually some of the buildup of boulders
could only be kept from occurring by much greater pre-dam spring
runoff floods than have resulted from dam flood-flow releases.
But at least the dam's flood-flow releases can help to some extent.)
What must be sought, in our view, is a method of operating
Glen Canyon Dam that will place the greatest emphasis upon those
values and resources that have the higher priority. We urge the
following listing of relative priorities, not that any should be
mutually exclusive of any others, but that this listing should
suggest relative emphases:
(1) The Humpback Chub, as a federally listed endangered
native fish species must, under the law, be accorded special management emphasis. Construction and operation of Glen Canyon Dam has
so drastically altered the habitat tolerances of the chub that its
range in Grand Canyon National Park is now but a precarious small
fraction of its pre-dam range. Its jeopardy status must be addressed by meaningful dam operations that will not only assure the fish's
survival in the park, but will offer the chance for enhancement of
the species there.
(2) The steady erosion of sediments from the river channel
and along the riverbanks in the national park must be slowed as much
as possible, to forestall for as long into the future as can be possible the flushing of this relatively finite resource on through
the Grand Canyon and into Lake Mead. This steady erosion is the inevitable reality, since Glen Canyon Dam and its reservoir are now capturing the bulk of sediments that formerly were carried by the freeflowing river into Grand Canyon. With this once-enormous sediment
load no longer constantly replenishing the sediments then being carried on through Grand Canyon, the only remaining sources come from
such tributaries as the Paris and Little Colorado rivers, and from
side drainages in the Canyon. All of these, however, comprise but
a tiny fraction of the fine-grained sediments that once were available
to continually rebuild the beaches and sandbars.
beaches and sandbars are, of course, essential to white-water
boating, most especially to non-motorized river trips through Grand
Canyon. As the bulk of the beach and sandbar sediments are gradually
flushed farther and farther downstream without the pre-dam replenishing process, the size and quantity of such places that are valued for
rivertrip camping sites will inexorably diminish.. .until camping becomes unbearably congested and until too few camping sites remain for
the running of non-motorized river trips (remaining camping areas, at

3-Glen Canyon dam impacts draft report

least in some stretches, becoming too far apart for a non-motorized
day's journey). We urge that there be no more flood releases.
(3) The sharp daily flow fluctuations should either be
eliminated or greatly reduced, since they often greatly disrupt
white-water boating trips. When Glen Canyon Dam was constructed
and put into operation, it was intended as a base-load power generation facility. However, it has since been used to supply daily
peaking-power needs, thereby creating the sharp fluctuations in
the quantity of water released from the dam. We urge that peakingpower electrical needs be provided by other facilities; or at the
least, that those needs be spread out across a number of major facilities. It should also be pointed out that the Repayment schedule
for Glen Canyon Dam was predicated exclusively upon base-load power
generation. Peaking power is, thus, not part of the repayment arrangement; it is "gravy." We urge that Grand Canyon National Park
and its white-water recreation should not be sacrificed or impaired
to meet this aspect of power generation. White-water recreation
deserves a very high priority in terms of just how Glen Canyon Dam
is operated.
(4) Other native species of fish and their habitat requirements need to be protected and enhanced as much as possible, taking
into account the urgent priority needs, 1, 2, and 3, above.
(5) As for the terrestrial wildlife and related riparian
habitat, since this is already a significantly altered situation,
we suggest that enhancement of this artificially expanded abundance
not be manipulated/managed at the expense of the priorities listed
above.
It is a monumental tragedy, in our view, that Glen Canyon Dam
was ever built--both because of the loss of magnificent Glen Canyon-,a place of exquisite natural beauty that is now destroyed, and because of the array of impacts upon the Colorado River downstream from
the dam. The challenge now is not to try to "mimic" how things originally were (the changes have been too drastic to ever accomplish
that), but instead to try to mitigate the impairments causeu by the
dam by establishing the best set of priorities possible.
A vital part of such mitigation management is for continued
professional monitoring and research so that complexities of the dam's
impacts can be more fully understood and so operational techniques
of the dam can be gradually improved for the welfare of Grand Canyon
National Park and its resource values.
Funding for an on-going monitoring and research program should
naturally be derived from the dam's operating revenues. Since it is
the dam that has radically disrupted and altered the river's ecosysten
and recreation, it is the consumers of the dam's power who should pay
for the long-term costs of monitoring, research, and, where necessary,

4-Glen Canyon dam impacts draft report

too, any costs of implementing protective management programs designed to protect and enhance our only Grand Canyon.
We greatly appreciated the October 28th briefing session in
Flagstaff, and we look forward to participating in further phases
of this process.
As we never did directly receive a copy of the draft report,
I'd greatly appreciate my name being added to the mailing list.
WithRDB/prb
cc: T. Destry Jarvis,
NPCA Vice President

,t

Ru
D. Butcher
Southwest -& -California Representative
Box 67, Cottonwood, AZ 86326

November 12, 1987

Mr. Richard W. Marks,
Superintendent, Grand Canyon National Park
P.O. Box 129
Grand Canyon, Arizona
Dear Superintendent Marks:
Subsequent to a public meeting in Flagstaff on October 28, and discussions at
their annual river concessioners' meeting on October 29-30, the Grand Canyon
river concessioners agreed to issue a combined response to the Draft Glen Canyon
Environmental Studies Report. This letter is our combined response.
It is stated in the Report, and elsewhere, that control of Grand Canyon river
flows by Glen Canyon Dam has has been beneficial to commercial and private river
running because it has attenuated seasonal flow extremes, high and low.
That, however, is only part of the effect, part of the time. It fails to mention
that Glen Canyon water release management prevented river running for about six
weeks in August and September of 1973, for lack of boatable releases, that it
did the same thing for about six weeks in May and half of June 1977, and that
there are a number of low water problems just about every year, ranging from
inconveniences, to damaged equipment and injured passengers, to the necessity
for helicopter evacuation of passengers, crews and boats from the canyon.
The Study's observation that past water relase scenarios have not always met the
best interests of the boating community is something of an understatement, and
it has become more so in the last 11 years.
In 1966 (generator installation had just been completed) the highest water
released through Glen Canyon Dam was 20,900 cubic feet per second.Now, through
rewinds and uprates, and utilizing the lull stroke of the turbine gates, as much
as 37,296 cfs can be released downstream.
That additional water, however, has since 1976, gone into daily spikes, and into
releases in the dead of winter, when they are of almost no use to river
runners, or other recreationists. To a very great degree, water release patterns
since 1976 have "prolonged" the river season by "prolonging it" into months for
which there is no public or private demand because of severe temperatures and
weathers.
We believe the interests and opportunities of whitewater boaters should be a
major factor in the operational management of Glen Canyon Dam, and we speak for
ourselves, and about 15,000 people who want a safe enjoyable Colorado
River/Grand Canyon experience each summer.
The Grand Canyon river trip is one of our nation's premiere outdoor recreational
experiences. It is the nucleus of a very significant regional economy,

generating about $14,000,000.00 in passenger fares and related expenditures each
year, employing several hundred professional guides, and generating significant
sales, income, and excise taxes, and franchise fees.
That experience, and those values, can only survive if they are factored into
water release management policies at Glen Canyon Dam. Toward that objective, we
recommend the following operational changes:
I. Immediately establish the minimum release from the dam to be at least 5,000
cis at any and all times, around the clock and throughout the week, from October
through March 31.
2. Revise toward release of summer runoff in the summer, similar to the pre-dam
pattern of the river, and similar to the release practice at the dam from 1966
to 1976.

Sincerely,

The chart below provides an equation for accomplishing the above revisions:

April
May
June
July
August
Sept emhe r

685,833
685,833
685,833
685,833
685,1333
685,1133

ihe alms, l uure

acre-feet,
acre-feet,
acre-feet,
acre-feet,
acre-feet,
acre-feet,

@
@
@
@
@
@

11,461
11,461
11,461
11,461
11,461
11,461

cfs
cfs
cfs
cis
Os
cfk

minimum,
minimum,
minimum,
minimum,
minimum,
minimum,

ARIZONA RAFT ADVENTURES, INC.
Flagstaff, Arizona

DIAMOND RIVER ADVENTURES
Page, Arizona

ARIZONA RIVEk RUNNERS
Phoenix, Arizona

EXPEDITIONS, INC.
Flagstaff, Arizona

CANYON EXPLORATIONS, INC.
Flagstaff, Arizona

GEORGIE'S ROYAL RIVER RATS
Las Vegas, Nevada

totaling
4,115,000 acre-feet
firm

CANYONEERS, INC.
Flagstaff, Arizona

GRAND CANYON DORIES, INC.
Menlo Park, California

6,230,000 acre-feet

COLORADO RIVER. 1, TRAIL EXPEDITIONS
Salt- Lake City, Utah

GRAND CANYON EXPEDITIONS CO.
Kanab, Utah

CROSS TI URh 6 EXPEDITIONS, INC.
Orem, Utah

MATCH RIVER EXPEDITIONS, INC.
Vernal, Utah

totaling
4,115,000 acre-feet
+ or -

minimum 5,000 cfs; maximum 28,000 cfs

28,000
28,000
211,000
28,000
28,000
28,000

cfs
cis
cfs
cfs
cfs
cfs

maximum
maximum
maximum
maximum
maximum
maximum

are u6ed because:

is tic amount that must (it• released as an annual average.
in winter.
on. -half of that annual average would he released in summer and one-half
Out—twelfth ( 685,833 af) of t he annual requirement would he released each summer month.
Releasing 6%5,833 af in A month requires a constant flow of at least 11,461 cfs,
which is sufficiently high for safe, if not enjoyable river running.
The difference between the low of 11,461 and the high of 26,000 would provide for
fluctuations necessary to reasonable peaking power generation.
releases
Hivher inflows, or greater storage needs could be provided by more sustained
acre-feet
upward of 28,000. ( Constant release of 28,000 cfs would provide 1,680,000
of downstream release or upstream storage capacity per month.
Winter limits of 5,000 cfs minimum / 28,000 cfe maximum would allow the Bureau of
Reclamation to reasonable peaking power demands, which would resultingly provide
sufficient averages for the few winter river trips that take place, and it would
provide adequate protection for trout spawning and rearing.

6,:•10,000 at

In addition to adoption of the foregoing water release equation, we also urge continuation
of the studies and the funding for them. After the studies had begun, a three year period
of unusually high inflows and releases took place that eliminated the very conditions that
were to be studied as far as Grand Canyon beaches were concerned. The availability of
these beaches is essential to continuation of these incomparable river trips and the
economic and financial activities they produce. It is vital to determine the water
release patterns under which they can survive.
We appreciate and urge your attention to these concerns and alternatives.

3. Significantly reduce the magnitude and rate of fluctuating releases.

October
November
December
January
February
March

The 28,000 cfs figure would provide a good whitewater boating experience while slightly
shaving the peaking power "spikes" that are removing Grand Canyon's camping beaches.
Bureau of Reclamation data has shown that flows higher than 28,000 would be foregone
only 2-1/2% of the time.

IOUR WEST, INC.
Oren, Utah

MOK1 MAC RIVER EXPEDITIONS, INC.
Salt Lake City, Utah

SLEIGHT EXPEDITIONS, INC.
LaVerkin, Utah
WESTERN RIVER EXPEDITIONS, INC.
Salt Lake City, Utah

OARS, INC.
Angels Camp, California

WHITE WATER RIVER EXPEDITIONS
Mariposa, California

OUTDOORS UNLIMITED
Lotus, California

WILDERNESS RIVER ADVENTURES
Page, Arizona

-4
_L.ov

November 10, 1987

_ C.7
NOV

Richard Marks
Superintendent
Grand Canyon National Park
P.O. Box 129
Grand Canyon, Arizona 86023

1mr41
3.

2

Finally the low flows (below 5,000CFS) again have
a negative impact on almost all the users of the
river below the dam and should be avoided.

It clearly seems time for the Bureau of Reclamation to
consider the negative effects that the operations of the
Glen Canyon Dam are having on our national treasure the
Grand Canyon and the users of the river below the dam.

Dear Mr. Marks,
Sincerely,

We have read and reviewed the "Glen Canyon Environ
Studies Draft Report, September 1987", initiated by the
Department of the Interior.

BA"La__

Bruce Winter

We feel there is now concrete evidence to support what
we as a Grand Canyon rafting company have been experiencing
tor many years. The operation of the dam is having an
adverse effect on the Grand Canyon and most of the river
users downstream from the dam. We feel, the report points
out many realistic operational changes that can be made
to eliminate or at least minimize the adverse effects.

1,s,
, 1
•4 1

4

F.,
CD
,.P.

I \,
,

cc:

We strongly support a review of the dams operations
to consider and adopt these changes. The following points
1
we fee_ are some of the most important ones that need to
‘
be addressed.
I '
1. The greatly fluctuating flows(especially the
short term and daily fluctuations) are causing ,
an irreversible loss of sand and beaches
throughout the Grand Canyon. This is having a
negative impact on the recreational rafting and
..-.
many other aspects of the canyon.
f
2.
Flood releases (releases over 31,500 CFS)
are causing extreme damage to the beaches
,.. .
through erosion. This also damages vegetatin
wildlife habitat and eliminates camping,gigh
fcr the whitewater trips. These flows have
a very negative impact on the safety of 4„:
whitewater boating and fishing below th7' d

Anz.ltIVER AUNNERS incorporated
P0 BOX 47788

PHOENIX, ARIZONA 85068-7788

4(
-4<

(602) 867-4866

Senator Dennis De Concini, AZ.
Senator John Mc Cain, AZ
Clifford Barrett, Regional Dir., Bureau of Reclamation

OUTDOORS UNLIMITED RIVER TRIPS

Arizona Raft Adventures, Inc.

PO Box 854 • Lotus. CA 95651• (916)626-7668

4050 E. HUNTINGTON DR., FLAGSTAFF, AZ 86004 (602) 526-8200

November

o, 1 987

-

NOV 10 '87

Richard Marks, Superintendent
Grand Canyon National Park
,
P. 0. Box 1 2'
86023
Grand Canyon, eq

November 10, 1987

Dear Dick:
Richard Marks
Superintendent
Grand Canyon National Park
Grand Canyon, A7 86023

The following are my initial comments on the CIR RTJ-..REOOR
Glen Canyon Environmental Studies.

'
1
1241
1-?:
:2
7

e

Dear Dick,

l

,fni l•Tettrrencht
. ri,--Getober
I would like to respond to the meeting held in Flagsta
28, 1987 regarding the Glen Canyon Environmental Studies draTt —rePo'it: This
response comes from an individual representing a river running concession in
tin. Grand Canyon, as well as a citizen of the United States. My concern is the
amount ot sand that is being lost along the Colorado River through the Grand
Canyon due to the fluctuating flows from Glen Canyon Dam.
I was impressed with the GCES report explaining the effects of Glen Canyon Dam
on the Colorado River. Individuals who have been around the Grand Canyon for
years have seen the damage caused by fluctuating flows, and now that it is
documented, I hope something can be done to preserve what is left.
It is my understanding that Hoover Dam could handle the fluctuating flows, and
Glen Canyon Dam could operate as a base load operation for the electrical needs.
I understand this switch is not implemented because of political reasons. As
a base load operation, Glen Canyon Dam could be set up to provide both the
needed electricity and to help protect the fragile river environment.
Whether irreversible damage has been done to the Canyon or not, the point is
N■.,t
is being done to the Canyon, effecting not onlv our business as
river running concession, but also the preservation of the Grand Canyon tor
Ii litre generations.

Mv i - rn” ern is that the beaches and sands at the bottom of the Grand Canyon are
.li.,appc,ring and not being replenished. Today this effects primarily the hum:,
IRR;RR t of the Canyon. It it continues as it has, the riparian habitat_ in the
Grand Canyon will also feel the impact. The destruction of the beaches is
detrimental to the entire environment of the Grand Canyon. Thank you for your
time
Sincerely,

B111 Wasley
Operations Manager
Arizona Raft Adventures

T—T.

Past and present operations of Glen Canyon Dam have caused
two significant changes to occur in the bottom of the Grand
Canyon. First, beaches have been lost due to extreme daily
fluctuations in flow and loss of replacement silts captured
upstream behind Glen Canyon Dam. Second, the composition of the
beaches themselves has been altered by water fluctuations and
high water releases.
I n the past beach composition ranged in gradation from
passing 04 grandular fines down to 5 and one micron sized clays
with a heavy concentration of passing M270 to 5 micron (silts, in
between. These silts and clays are more easily suspended in
water than the coarser materials and rapid flow reductions cause
their migration through the saturated beach substrate and on down
the river. The result of this loss of fines is a coarse
particle beach composition that, without the fines to bind it
together in a cohesive mass, becomes unstable and highly
susceptible to damage from river currents, foot traffic and high
winds.
#4 good analogy would be the composition of a concrete
mixture, wherein engineers specify blends of material sizes to
maximize strength with cement (like clay) acting as the binder
between particles big and small.
I would like to propose that the study include three phases

o+ mitigation for the loss and alteration of beaches.

First -- Normalize releases into a constant flow regime, allowing
oradual reductions in flow. This would give suspended
sediments time to settle into eddys and also allow existing
beaches to drain under low head conditions simulating natural
circumstance. I suggest flow reductions of no more than 1 0% per
day, not to exceed I % per hour.
Only

Second -- During the winter low-use period (November through
February) Bureau of Reclamation should use suction dredges to
restore in a limited way the most critical beaches by pumping
what fines it can from the adjacent river bottom for deposition
on the shore. The Park Service would determine these critical
site locations.

CRANDCANYON•TUOLUMW.MERCED.ROGUE•KLAMATH

Reznick
1460 W. Palmer Ave.
Flagstaff, Az. 86001
602 774-780t
Peter

Long Term -- If possible to retrofit, a silt bypass such as
those designed and used by the Chinese on many of their major
dams should be i nstalled on Glen Canyon Dam to begin the
restoration of sediments to the riverbed. I n addition, the use
of a large dredge upstream of the dam to supply silt for
downstream should be considered for long-term mitigation. Said
dredge would either send silt in a slurry to a collection area or
deposit it onto barges for transporation to a collection area near
the dam for deposition into the river at the most opportune time.

SincerZ:s,
A--

n Vail

11/10/87
Attn. Dicl Marks
Glen Canyon Environmental Studies
Public lmput Program
United States Park Service
Grand Canyon, Arizona 86023
Dear Mr. Marks,
I am writing, as you suggested at the meeting i n Flagstaff, to
press my feelings on the Glen Canyon Environmental Studies
report.
I was a part of the studies by guiding many of the trips, and I
I learned
f eel that Dave Wegner has done a fine kob throughoutat the Flagstaff meeting that the sandy beaches are in danger of
serious further erosion thus reducing what camps are left in
Grand Canyon. The bureau of Reclaimation seems to think that the
studies prove that side canyons can bring in enough silt to
replenish the beaches a n a 20 year period. I would hate for them
to be proven wrong by peaking the flows too much or too quickly
and seeing insufficient replenishment of sand. It seems to me
that 14 their theories are incorrect, then we could lose these
beaches f orever.
,
Thank you for hearing my vie-w‘..
Sincerely,

kL.2nILI

The
Maim

The Arizona Nature Conservancy

coliseniti■hy
•

300 East University
( 602)622-3861

Boulevard. Suite

230.

Tucson. Arizona 85705

November 30, 1987
Mr. Richard Marks
Super intendant
Grand Canyon National Park
P.O. Box 129
Grand Canyon, AZ
86023
Dear Mr. Marks,
The Arizona Nature Conservancy appreciates the opportunity to
submit our comments in response to the Glen Canyon Environmental
As a national, non-profit
Studies Draft Technical Report.
conservation organization dedicated to the preservation of
biological diversity, we are especially concerned with land
management activities and their potential impacts on rare plants,
We include a specific concern
animals and plant communities.
related directly to the Gila chub, an endangered species and a
more general concern related to several aspects of the study.
The principal conclusions related to possible effects of
1.
current and modified operations on the Humpback Chub are
misleading and not adequately demonstrated by the data presented.
"Flucuations during the
The document states in the summary that
summer months reduce habitat for native fishes". On page B-31
the document indicates that Juvenile chub used backwaters during
three seasons but because flows were steady during most of the
study period it was not possible to determine what effect flow
Because flow fluctuations were
flucu.alons had on the chub.
shown to impact other native fish, it appears reasonable to
have
the potential to impact
assume that flow flucuations
Juvenile chub.
Is
difficult t o
Without adequate study, It
discern how you arrived at the conclusion that flow flucuations
do not appear to have a deleterious effect on the chub.
A spuond conclusion related to the chub indicates that modified
flows are not likely to benefit the chub due to its reliance on

the LCR confluence for spawning. Once again no data appears to
be available that can provide some understanding of the
i mportance of mainstem backwaters to the chub during the Juvenile
and adult portions of their life cycle when they are known to
inhabit the mainstem of the Colorado River.
I n addition, studies performed by C.O. Hinckley during the summer
of
1 987 (reported at the Desert Fishes Council meeting in
November 1987) suggest reproductive chub congregate at the mouth
of the LCR in the shallows near the confluence. Dewatering of
these shallows by flucuating
flows could have a serious

deleterious effect on chub reproduction and larval survival.
concommlttently, the document indicates that Humpback chub "would
probably fare well with a more 'natural' release pattern because
flood flows increase the area of reproductive and rearing habitat
at the mouth of the Lower Colorado River". Based upon this
statement it is difficult to understand how you arrived at the
summary conclusion that
"operational changes are unlikely to
help humpback chub".
2. It is clear, in almost all aspects of these studies, that
most of the natural resources in the Canyon have normal
disturbance patterns and recovery cycles.
These cycles span a
period of from one to many years, as for example, in the case of
long-lived riparian trees that may need up to fifty years to
mature. The three year span of these studies, Is not adequate to
provide a solid understanding of the dynamics of the riparian
biological community, particularly since all of those years were
characterized by high flows.
Continued monitoring for several
years of key natural resources, both biological and physical,
will be necessary before a reasonable decision can be made about
how dam operations affect those resources.
We appreciate the opportunity to provide comments on an important
study effecting one of North America's truly special treasures of
our natural heritage.
Please continue to keep us informed on
this project. Thank you for your time and consideration.
Sincerei
:coa4„.
■ (
dý , urenzS
Field Rt resentative/Rublic Lands

APPENDIX E: CONSTITUENT GROUP COMMENTS
PART IV: WESTERN AREA POWER ADMINISTRATION CONSTITUENCY
INDEX
COMMENT LETTERS
GLEN CANYON ENVIRONMENTAL STUDIES
SEPTEMBER 1987 DRAFT REPORT
Entity

Letter Date

Date Received

Wyoming Municipal Power Agency

10-23-87

10-26-87

Tri-State Generation & Transmission, Inc.

11-06-87

11-12-87

Salt River Project

11-10-87

11-12-87

Colorado River Energy Distributors Assoc.

11-11-87

11-12-87

Platte River Power Authority

11-12-87

11-12-87

Irrigation & Electrical Districts
Association of Arizona

11-12-87

11-13-87

Bountiful City Light & Power

11-12-87

11-13-87

Intermountain Consumer Power Association

11-12-87

11-16-87

Arizona Power Pooling Association

11-24-87

11-27-87

Arizona Municipal Power Users Association

11-24-87

11-30-87

109

SUMMARY
COMMENTS RECEIVED FROM WESTERN CONSTITUENTS ON
GLEN CANYON ENVIRONMENTAL STUDIES
SEPTEMBER 1987 DRAFT REPORT
Larry LaMaack, Executive Director, Wyoming Municipal Power Authority, Lusk, WY
Date of Letter: Oct. 23, 1987
Member of CREDA. Support CREDA comments.
Stress that reader be able to understand the adverse impacts to power
customers as a result of restriction in daily releases.
Wyoming Municipal Power Agency (and others) have built base-load thermal
generators to compliment existing operation of CRSP powerplants.
Changes to daily operation would most certainly result in uneconomic
adjustments in WMPA operations, add coal or gas-fired generation, and cause
increased emissions of pollutants. Such impacts are appropriate topics for this
report.
Concerned over the use of dollars as a relative measuring index for recreation,
but not for other areas (such as power generation). Recommend including
relative dollar impacts to all areas, or eliminate.
Request to remain on list of interested and affected parties for further
information.
Daniel E. MacLeod, General Manager, Tri-State Generation and Transmission Association,
Denver, CO Date of Letter: Nov. 6, 1987
Important from the preference power customer standpoint that the economic,
operational, and planning impacts to the power community be appropriately
documented in the report.
Concerned for the impacts of "late" consideration of operational impacts.
Suggest appropriate documentation of power impacts to provide decision-makers
the necessary data to set priorities.
Impacts to purchasers of Federal power not limited to immediate area around
Glen Canyon. There may be substantial impacts even in an insignificant
change of operations.
Expect NEPA compliance process required if decision is made to change
operations. Tri-State would participate at that time.

110

John F. Sullivan, Manager, Power Contracts, Salt River Project, Phoenix, AZ Date of
Letter: Nov. 10, 1987
Member of CREDA. Fully subscribe to CREDA comments.
Concerned that there is no discussion of impacts to power as a result of
modifications to releases. Such operational patterns would eliminate SRP's
ability to use SLCA/IP allocation for peaking.
Estimate present value of replacement cost for peaking power to be $29
million.
Additional generation required would be from fossil fuel generation.
Recommend including explanatory note to support recent USBR claim that flood
flows will be significantly less frequent than one year out of four, as stated in
the report.
Appreciate being kept informed of progress of the GCES and additional
opportunities to comment.
John R. Allum, Chairman, Colorado River Energy Distributors Association Date of
Letter: Nov. 11, 1987
Interested in any studies or decisions which could change quantity or price of
power available from the project.
Reference constraints that must be followed: (1) CRSP Act, Section 7, re:
"greatest practicable amounts of power and energy...", and (2) Operating
Criteria.
Include reference to CRSP Act and Operating Criteria in disclaimer on back of
cover.
Inappropriate to include dollar impacts for recreation, but not for other
sections.
Recommend removing dollar references or include references in all
sections.
Interested in the decision-making process for priorities for native fisheries vs.
recreational fisheries, and recreational use by anglers vs. boaters. Operations
and marketing should also be represented in decision-making.
Concerned about cumulative impacts of GCES and other related studies in the
Upper Colorado. Concern for possible change to operations of hydro facilities
(peaking to base load operation) which could require addition of generation,
using nonrenewable resources.
Very interested in being kept informed of studies being performed, and being
allowed to participate whenever possible.

John R. Allum (continued)
Urge WAPA to take an active role in representing the power viewpoint,
expressed as early and as often, as possible.
Thaine J. Michie, General Manager, Platte River Power Authority, Fort Collins, CO
Date of Leter: Nov. 12, 1987
Member of CREDA. Fully support CREDA comments.
Either delete dollar impacts to recreation section, or include dollar impacts in
all sections.
Concerned for cumulative impacts of various environmental studies.
Critical that power community be represented and actively participate in this
type of study. Important to stay within the "spirit and intent" of the law.
Reference to CRSP Act.
Encourage WAPA to take active role in representing power viewpoint.
Robert S. Lynch, Asst. Secretary/Treasurer, Irrigation & Electrical Districts Association
of Arizona, Phoenix, AZ Date of Letter: Nov. 12, 1987
Membership includes 10 Southern Division Customers.
Also a member of CREDA. Supports CREDA comments.
Recommend report contain an outline of areas not studied that would need to
be studied if further consideration were given to operational changes at Glen
Canyon.
Summary of omitted areas: (1) impacts on power generation, contractual
compliance, and power purchasers, (2) cost/benefit analyses of alternatives, (3)
water right constraints on operation changes, (4) impacts on downstream and
upstream river operations re: other studies, (5) potential conflicting impacts
among endangered species for recovery alternatives, and (6) operational
constraints resulting from modifications, such as Glen Canyon Uprates.
Current text in summary pages leaves several "false impressions." False
impressions are: (1) this study can be the basis of a decision to make
operational changes and the Secretary should know the scope of the feasibility
studies and NEPA compliance activities that would need to be undertaken, (2)
discussions have been rigorously reviewed, (3) alternatives considered are legal
with respect to Law of the River, (4) text in summary (pg 4) might mislead
reader to believe that such alternatives are without legal objection, and (5)
statement on top of pg 33 is legally misleading.
Support CREDA request to include reference on back cover to Operating
Criteria.
112

Robert S. Lynch (continued)
Support SRP request to include post-study data re: frequency of flood releases.
Concerned over the possible cumulative impacts of this GCES and other such
studies.
Request to be kept informed of progress of GCES, notified when these
documents and the Executive Review Committee Report are forwarded to the
Commissioner of Reclamation and to the Secretary and provided a copy of the
Executive Review Committee Report.
Clifford C. Michaelis, Director, Bountiful City Light and Power, Bountiful, UT Date of
Letter: Nov. 12, 1987
Support comments by CREDA.
Bountiful very concerned that studies could lead to changes in operations
which would reduce power resources available to WAPA's customers.
Two constraints: (1) CRSP Act. Reference to Section 7; and (2) Operating
Criteria.
Interested in being kept aware, and of being allowed to participate whenever
possible.
Edward C. Rampton, Manager of Federal Water and Power Issues, Intermountain Consumer
Power Association, Sandy, UT Date of Letter: Nov. 12, 1987
Member of CREDA. Supports CREDA's comments.
Concerned with the apparent direction and attitude to reply on power revenues
as a source of funding for uses not contemplated or authorized under
applicable laws. Reference to CRSP Act, Section 7 language re: greatest
practicable power and energy. Activities jeopardizing power revenues should be
examined to assure recovery from other sources.
Encourage WAPA to continue its active role in representing its power
customers, and allow opportunity for customer input.
Arthur J. Faul, President, Arizona Power Pooling Association, Benson, AZ Date of
Letter: Nov. 24, 1987
Identical comments as Arizona Municipal Power Users' Association.
•

Support CREDA comments, dollar impacts, cumulative effects of studies, and
power community participation.

113

Michael A. Curtis, Executive Secretary, Arizona Municipal Power Users' Association,
Phoenix, AZ Date of Letter: Nov. 24, 1987
Member of CREDA. Support CREDA comments.
It is inappropriate to include dollar impacts for recreation, and not for any
other section (including power).
Cumulative impact of the various environmental studies is a concern. It is
important that these impacts be viewed on a total basin basis.
It is important that the power community participate and be actively involved
in any and all studies.
Urge WAPA to take "necessary action" in order to present the power viewpoint.

114

WYOMING MUNICIPAL

POWER AGENCY

P.O. BOX 900 — WEST HWY. 20
LUSK, WYOMING 82225
(307) 334-2170

Ms. Marlene Moody
October 23, 1987
Page Two

the merit of changing release patterns. To achieve maximum clarity in
the assessment of relative impact to changing release regimes, dollars
should either be included in all elements under study or eliminated
from all sections. From our perspective, this is especially
significant when discussing any impact to power generation.

October 23, 1987
The Agency is grateful for the opportunity to become familiar with and
comment on the GCES report. We wish to remain on your list of
interested and affected parties for further information as the report
takes final form. Should you have any questions concerning our
comments please do not hesitate to contact me.

Ms. Marlene Moody
Western Area Power Administration
438 East 2nd South, Suite No. 2
Salt Lake City, Utah
84111

Sincerely,
Dear Ms. Moody:
WYOMING MUNICIPAL POWER AGENCY

Lit

As a constituent of the Western Area Power Administration with
interests in the operation of the Colorado River system, the Wyoming
Municipal Power Agency is pleased to be able to offer its comments on
the draft copy of the Glen Canyon Environmental Studies Integration
Report. The Agency is also a member of the Colorado River Energy
Distributors Association (CREDA) and as such, endorses those comments
made by CREDA on the report. While it is clear from reading the study
that it is primarily technical in nature and was not necessarily
designed to focus on potential adverse impacts to those who benefit
from existing operations of Glen Canyon Dam, it is that aspect of
existing releases which is of concern to the Agency.

LARR
ALIAACK, P.E.
EXE "TIVE DIRECTOR
LEL:kt

Of primary importance to us, is that those who read the report gain a
clear understanding that any restriction in the daily release pattern
from Glen Canyon would have an adverse impact on the character of the
power delivered to the Agency from the CRSP system. The power
received from the federal system is now delivered In a manner which
follows the swings in our load and therefore is most valuable when
integrated with our existing base-load thermal generators. The Agency
and other preference customers of the CRSP have built thermal
generation which takes into account the variable nature of the power
deliveries from the project and blends together with it to produce the
lowest cost of power to our customers. To restrict the release
regimes on a daily basis would almost certainly require the Agency to
make uneconomic adjustments in its operation of those plants, add
additional coal or gas fired generation and cause increased emissions
of pollutants into the atmosphere from accelerated use of fossil
fuels. It seems to us that such adverse environmental and economic
results from restrictions in daily releases are an appropriate topic
for the report.
The Agency is also concerned that confusion may result from the use of
dollars as a relative measuring index for recreation, but not for any
other area of investigation. We do not argue that it is an
inappropriate index, only that there are clearly monetary implications
to almost every other aspect of dam operation addressed in the report
and that no such comparable index has been assigned to them to gauge
ROAM) Or DIRECTORS
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TRI-STATE GLATER4770N AND TRANSMISSION ASSOCIATION, INC
12076 GRANT STREET P.O. BOX 33695 DENVER, COLORADO 80233

13031 452 - 6111

S.4LT RIVER PROJECT
NOVEMBER

6, 1987

poromuuxmon

AA20..
1i072 )O2

NOVEMBER 10, 1987

SUBJECT: GLEN CANYON ENVIRONMENTAL

STUDIES

DEAR MS. MOODY:

DEAR MARLENE:

THE GLEN CANYON ENVIRONMENTAL

STUDIES NEARING COMPLETION POINT OUT THE NEED
SAME VERY CAREFUL ANALYSIS BY POLICY LEVEL ADMINISTRATORS IN THE
DEPARTMENT OF INTERIOR.
FOR

20 TO THE PREFERENCE POWER CONSTITUENCY IN SALT LAKE
I NDICATED DELICATE BALANCING OF INTERESTS OF BOATERS, FISHERMEN, FISH
AND WILDLIFE AGENCIES, POWER CUSTOMERS AND OTHER BENEFICIARIES WILL BE
REQUIRED. IT IS IMPORTANT FROM THE PREFERENCE POWER CUSTOMER STANDPOINT
THAT THE ECONOMIC, OPERATIONAL AND PLANNING IMPACTS TO THE POWER COMMUNITY

THE REPORT ON OCTOBER
CITY

CR)

BE APPROPRIATELY DOCUMENTED IN THE REPORT. THE LATE CONSIDERATIONS OF
OPERATIONAL IMPACTS LEADS TO THE INFERENCE THAT APPROPRIATE WEIGHT MAY NOT
HAVE BEEN GIVEN TO THIS ELEMENT OF THE STUDY AS WELL AS TO ECONOMIC
IMPACTS. APPROPRIATE DOCUMENTATION OF POWER IMPACTS WILL provide policy-

MAKERS THE NECESSARY DATA TO SET PRIORITIES.
THE IMPACTS TO THE ELECTRIC UTILITY THAT PURCHASES FEDERAL POWER REACHES
FAR BEYOND THE IMMEDIATE AREA OF GLEN CANYON AND CAN BE SUBSTANTIAL EVEN
WITH WRIST MAY APPEAR TO BE AN INSIGNIFICANT CHANGE OF operations.

1,4E HAVE TO ASSUME THAT POLICY DECISIONS, TF RESULTING IN OPERATION CHANGES,
WOULD TRIGGER A NEPA COMPLIANCE PROCESS, AND WE WOULD EXPECT TO HAVE
PARTICIPATION AT THAT TIME.

POLICYMAKERS TO GIVE POWER IMPACTS, APPROPRIATELY DOCUMENTED,
ITS PROPER LEVEL OF WEIGHT IN SETTING PRIORITIES.

WE EXPECT THE

CO
-

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DANIEL E. macLecd
GENERAL MANAGER

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AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER

PR.

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I.Rle

IS, r.•
144 Crcr TT

MS. MARLENE MOODY
WESTERN AREA POWER ADMINISTRATION
438 EAST 200 SOUTH, SUITE NO. 2
SALT LAKE CITY, UTAH_ 84111

Pgir w Irk ,
klail IR.

438 E. 200 S., SUITE 8 2
84111

SALT LAKE CITY, UTAH

, NOV 1 2 1987

WESTERN AREA POWER ADMINISTRATION

11■14 *VARY

MS. MARLENE MOODY

SLCAO
OFFICIALFO ECOPY

Wmou.woo

r

t.

.••••• •

r.. . 11111111
e•

WE APPRECIATE THE OPPORTUNITY TO REVIEW THE GLEN CANYON
ENVIRONMENTAL STUDIES DRAFT REPORT DATED SEPTEMBER, 1987, AND
TO ATTEND THE OVERVIEW OF THE STUDIES AT THE CONSTITUENCY
MEETING WITH THE BUREAU OF RECLAMATION ON OCTOBER 20, 1987, IN
SALT LAKE CITY. SALT RIVER PROJECT IS A MEMBER OF THE COLORADO
RIVER ENERGY DISTRIBUTORS ASSOCIATION ( CREDA) AND HAS PARTICIPATED
WITH OTHER CREDA MEMBERS IN DEVELOPING COMMENTS TO THE DRAFT
REPORT. WE THEREFORE FULLY SUBSCRIBE TO THOSE COMMENTS SENT TO
YOU BY CREDA, AS WELL AS OFFERING THE FOLLOWING COMMENTS ON
OUR OWN.
WHILE THE DRAFT REPORT MAKES NO SPECIFIC RECOMMENDATIONS FOR
OPERATIONAL CHANGES, IT DOES DISCUSS THE POSSIBLE BENEFITS,
PARTICULARLY TO RECREATIONAL USERS, OF AN ALTERATION OF THE
generation PATTERN AT GLEN CANYON DAM TO PROVIDE CONSTANT RIVER
FLOWS. THE REPORT DOES NOT DISCUSS THE corresponding IMPACTS TO
POWER GENERATION FROM SUCH A CHANGE. SUCH OPERATION WOULD
ELIMINATE SALT RIVER PROJECT'S ABILITY TO USE A PORTION OF ITS
SALT LAKE CITY AREA INTEGRATED PROJECTS ALLOCATION FOR PEAKING
PURPOSES. WE ESTIMATE THAT OVER THE 15 YEAR TERM OF OUR POST-89
ELECTRIC SERVICE CONTRACT ( 1989-2004), THE PRESENT VALUE OF THE
, COST TO REPLACE THE ENERGY LOST ON PEAK BECAUSE OF constant FLOWS
BELOW GLEN Canyon DAM WOULD BE $29 MILLION IN 1987 DOLLARS. THE
ADDITIONAL GENERATION WOULD BE FROM FOSSIL FUELED THERMAL
GENERATING UNITS, WHICH WOULD ALSO CREATE ADDITIONAL
ENVIRONMENTAL IMPACTS WHEREVER THE ACTUAL GENERATION OCCURRED.
THE DRAFT REPORT ESTIMATES THAT FLOOD FLOWS WILL OCCUR ONE YEAR
OUT OF FOUR, A FREQUENCY WHICH WILL BE DETRIMENTAL TO THE CANYON
ENVIRONMENT. IN THE BUREAU OF RECLAMATION'S PRESENTATION TO THE
UPPER COLORADO RIVER COMMISSION THERE WAS A DISCUSSION WHICH
INDICATED THAT DATA COLLECTED SINCE THE COMPLETION OF THE STUDY
INDICATE THAT FLOOD FLOWS WILL BE SIGNIFICANTLY LESS FREQUENT.
WHILE IT MAY not BE VALID TO INCLUDE THAT INFORMATION IN THE

et

, CREDA

Draft Report, it should be included either by way of footnote
or within explanatory material which accompanies the Report.
Again, we appreciate the opportunity to review the Draft Report
and attend the informational meeting with the Bureau of
Reclamation. Such open and informal exchange of information is
becoming a hallmark of the Salt Lake City Area Office's
relationship with the power community. We would appreciate
being kept informed of the progress of the Glen Canyon
Environmental Studies, particularly if there will be
additional opportunities to review and comment on the material.
If you have any questions on our comments, please contact me at
(602) 236-5812 or Charles Reinhold at (602) 236-5840.
Sincerely,

hn F. Sullivan
nager, Power Contracts
JFS/CR
cc: Leroy Michael, Jr.
Darrell Smith
CREDA Steering Committee
CREDA Marketing Committee

COLORADO RIVER ENERGY DISTRIBUTORS ASSOCIATION

November 11, 1987

Ms. Marlene Moody
Western Area Power Administration
438 East 200 South, Suite f2
Salt Lake City, Utah 84111
Dear Ms. Moody:
Thank you for sending us a copy of the Glen Canyon environmenta
study report dated September 1987 and the opportunity to get
additional information in the public information session held on
October 20, 1987, in Salt Lake. As you are aware, the Colorado
River Energy Distributors Association ("CREDA') is a non-profit
corporation made up of the entities who purchase power from the
Colorado River Storage Project ("CRSP") and represent over 858 of
the power marketed from the project. As the primary source of
revenue for CRSP, we are very interested in any studies or decisions which could change the quantity or price of power available
from the project.
We understand that the Glen Canyon environmental study was
requested by the Secretary of Interior to (i) try to quantify the
impacts of the project from a technical standpoint, and (ii) to
determine if changes in operation, with appropriate constraints,
could minimize these impacts. We would like to emphasize that
two of the major constraints of this study are the CRSP Act which
specifically states that 'the project shall be operated . . . so
is to produce the greatest practical, amounts of power and energy
that can be sold at firm power and energy rates" and the
Operating Criteria which has been established by the seven states
to optimize the water operation. Obviously these two constraints
must be followed.
Other concerns and suggestions we have include:
(1)

The disclaimer on the back side of the cover should
include reference to the Operating Criteria as well as
the CRSP Act.

(2)

We feel quite strongly that it is inappropriate to
include dollar impacts for recreation but not include
dollar impacts for the other sections. We would
strongly urge you to either remove the dollar references from the recreation section or include dollar
impacts in all other sections.

Ms. Marlene Moody
November 11, 1987
Page Two
(3)

(4)

(6)

- We are very interested in the decision-makin g process
involved with determining what the priorities are for
native fisheries versus recreational fisheries and
recreational use by an g lers versus boaters. We feel
that it is important that the operations and marketin g
areas be represented in this decision-makin g process.
We are also very concerned about the cumulative impact
of these studies. We are aware of environmental studies which are being done on the Flaming Gorge Project,
Black Canyon which could impact the Aspinall units, and
these Glen Canyon studies. Our concern- is that individually the changes in operation may not be too significant but, when they are all considered together, they
can have a very significant impact on the water and
power benefits of the river and violate the original
intent of the CRSP Act. For example, CRSP customer
facilities have been constructed in a manner which .
relies upon using the hydro power features in CRSP
primarily for peakin g and load followin g generation.
Supplemental sources have been added as base load
units. If constraints on the river mandate constant
releases with no flexibility, then these hydro units
are essentially base load units and peakin g and load
followin g resources will have to be added which will
more than likely use non-renewable resources.
We are aware that it is important to continue to study
the river operation and try to optimize it as much as
possible. We are therefore very interested in bein g
aware of the studies which are bein g done as early in
the process as possible and being allowed to participate whenever possible:

We appreciate your participation in these Glen Canyon studies and
would urge you to take a very active role in representing the
power viewpoint. We understand that there may be future opportunities to comment on the Glen Canyon studies, especially if
NEPA compliance is required. However, we feel that it is important to get the power viewpoint expressed in the process as early
and as often as possible. If we can be of further assistance,
please give us a call.
Sincerely,
PLATTE RIVER POWER AUTHORITY

ohn R. Allum, Chairman
REDA Marketing Committee
/ krar

at

PLATTE RIVER POWER AUTHORITY
TIMBERLINE

HORSETOOTH ROADS .FORT COLLINS. COLORADO 60525 .1305 226-4000

OFEC!AL FILF COPY 1
NOV
MkOWW=r1
SLC.......

1

November 12, 1987

Of
Puw.
■
IPA O I

•: '•

21•1•111•
Ms. Marlene Moody
Western Area Power Administration
438 East, 200 South, Suite 42
Salt Lake City, Utah 84111
Dear Ms Moody:
We received a copy of the Glen Canyon Environmental Study Report
dated September 1987, and attended the public information session
held on October 20, 1987, in Salt Lake. As we understand it,
this report was a summary of information which was requested by
the Secretary of Interior to try to q uantify the impacts on
several technical areas, and to determine if operational changes
were appropriate. At the meeting on October 20, comments from
the power community were requested and this letter is in response
to that request.
Platte River is a member of the Colorado River Energy
Distributors Association (CREDA) and is in full support of their
comments dated November 11, 1987. In particular, we would emphasis the following concerns:
(1)

The report should be as unbiased and fair as possible
and, therefore, it is inapp{opriate to include dollar
impacts for recreation and not for other sections
including power. Since dollars are always a sensitive
topic, I strongly urge you to make sure that the dollar
impacts are either deleted from the recreation section,
or included in all other sections.

(2)

We are very concerned about the cumulative impact of the
various environmental studies. What seems like a minor
impact in one area, could become very significant when
viewed with all of the other changes that are being proposed. It is important that these impacts be viewed on
a total basin basis.

Ms. Marlene Moody
Western Area Power Administration
November 12, 1987
Page Two

IRRIGATION & ELECTRICAL DISTRICTS
ASSOCIATION OF ARIZONA
GI GALE PEASE
PRESIDENT
RD JUSTICE
VI CE • PRE SIDE NT

(3)

We feel that it is critical that the power community be
represented and actively participate in this type of
environmental study. We understand that it is important to optimize the multiple uses of the river,
however, it is vitally important to stay within the
spirit and intent of the law. Since the CRSP act is one
of the primary governing laws, and this law has specific
language concerning the use of the river for power
generation, it is important that the power community be
involved in any and all studies.

Thank you for the opportunity to make comments on this report and
we woulc encourage you to take a very active role in representing
the pow,r viewpoint with the other federal agencies. If we can
be of further help, please let us know.

WA DJNN
VICE-CJ-MiRMAN

(602) 254 5908

CLYDE GOULD
SECRETARY-TREASURER
PK/BERT S LYNCH
ASSISTANT SECRETARY-TREASURE R

FEDERAL EXPRESS

November 12,

19 1

SLCAO
OFFnAL FILE COPY
NOV 1 3 1987

1am4mm.,, ...
mom
`

ILJr, o,

Ms. Marlene Moody
Western Area Power Administration
438 E. 2nd Street South, Suite #2
Salt Lake City, Utah 84111

.
t7 Le
*

I)]

w:'..UL

Re: Glen Canyon Environmental Studies

Sincerely,

Dear Marlene:

PLATTE RIVER POWER AUTHORIYT

As you know, the Irrigation and Electrical Districts Association
of Arizona includes within its membership ten (10) of the
Southern Division allottees for power and energy from the
Colorado River Storage Project. IEDA is also a member of the
Colorado River Energy Distributors Association ( CREDA) and we
have participated with other CREDA members in developing comments
on the draft report integrating the various Glen Canyon
Environmental Studies. Obviously, we support the comments
submitted by CREDA on this subject. We will attempt to make our
comments on the draft study and the study process cumulative
rather than repetitive.

Thaine J. Michie
General Manager

■.0

Hi RAYMOND
CHAIRMAN OF THE BOARD

SUITE 204
2001 NORTH THIRD STREET
PHOENIX. ARIZONA 85004-1472

/Jm

First and foremost, we think that the summary pages of the draft
report together with the text of the Executive Review Committee
Report must contain an outline of areas not'studied that would
need to be studied If any further consideration were being given
to operational changes at Glen Canyon Dam. These areas that have
not been studied were outlined for us at the constituent meeting
with the study team on October 20, 1987 in Salt Lake City. The
omitted areas include:
1.

Impacts on power generation, contractual compliance, and
power purchasers;

2.

Cost/benerit analyses of alternatives;

3.

Water right constraints on operational changes due to the
"law of the river";

4.

Impacts on downstream and upstream river operations
resulting from decisions made in this process as well as
other ongoing studies on the river;

OUR 25TH YEAR OF SERVICE TO ARIZONA AGRICULTURE

cam
:al
All

Ms. Marlene Moody
Novemper 12, 1987
Page 2
5.

Potential conflicting impacts among endangered species for
recovery alternatives (looked at briefly in a biological
sub-report but not analyzed In any depth); and

6.

Water operation constraints resulting from further
development or modification of water projects on the river
including but not limited to Glen Canyon uprates and their
cumulative impact within the context of the operating
criteria.

We think that the study and the Executive Review Committee Report
must note these areas that would require detailed inquiry in any
feasibility analysis as well as the environmental impact analysis
that would have to accompany such further studies. The Secretary
of the Interior should have at his disposal in the summary
documents and summary pages of the study document a clear and
concise outline of these omitted areas in order to be sole to
properly gauge the impact of any decision on the Department and
It. resources.
This is especially true since the current
language in the summary pages of the draft report leaves several
false impressions.
The first false impression is that this study can be the basis of
a decision to make operational changes at Glen Canyon Dam. While
the language in the first paragrapn of the summary says that the
study is not designed to lead that way "directly", it is clearly
the intent of the study to suggest to the Secretary that he could
consider studying operational changes and use this report as a
oasis for such consideration. He needs to know the scope of the
feasibility studies and NEPA compliance activities that would
have to be undertaken in addition to the documents he has in
front of him should he consider further study of operational
changes.
The second false impression is that the discussions in this study
have peen reviewea in some rigorous legal analysis and the
alternatives suggested fall within the legal constraints for
operation of the Colorado River Storage Project. While there is
an excellent discussion in the operational appendix of the
development of CRS?, it is clear that no documentation has been
supp.ied even remotely purporting to be a legal analysis of any
range of alternatives as it relates to the "law of the river".
Yet the language on the fourth page of the summary could easily
lead one to believe that the modified operations discussed in the
document have been given sucn analysis and are without legal
objection. This false impression about the depth of inquiry on
legal issues is carried forward by the discussion at the top of
page 33. While it is true that the major purposes of the CRSP
dams are as stated, there is a direct command within the Act to
operate Glen Canyon Dam to produce the greatest practical amount

Ms. Marlene Moody
November 12, 1987
Page 3
of power that could be sold at firm power and energy rates. That
is not a goal totally incidental to the water goals of the
facility and the statement at the top of page 33 is, in our view,
It is true that the operational mandate is
legally misleading.
referenced on page 38 and In Appendix D at page 11, but these
references do not overcome the false impression given by the
offending language.
While we are on page 33, we wish to second the CREDA suggestion
that the caveat about interpretation on the back of the cover of
the draft study be expanded to include the operating criteria.
The criteria are discussed on pages 33 and 34 but clearly this is
a discussion for purposes of the study and not an administrative
interpretation of those criteria. The need to point this out is
highlighted by the language in the middle of page 34 in which the
underlined language at the beginning of the second paragraph does
not agree with the language In the text of the paragraph. Nor
would either discussion of the relationship between Lake Mead and
Lake Powell necessarily satisfy water lawyers In either the Upper
or Lower Basins, based on discussions I have had with them.
We would also like to join with the Salt River Project in
suggesting that the post - study data on frequency of flood
releases be included in the Executive Review Committee Report.
We would close with the comment that this is but one of at least
three (3) studies currently ongoing on operation of dams on the
Colorado River. The cumulative impacts of all these studies are
of great concern to us as well as other power users on the
system. Any further study in this process would obviously have
to study the cumulative impacts of all of these efforts.
We appreciate the opportunity to coMment on these studies and the
draft integration report. We would join with CREDA and others in
asking that we be kept apprised of the process, notified when
these documents and the Executive Review Committee Report are
forwarded to the Commissioner of Reclamation and to the
Secretary, and provided with a copy of the Executive Review
Committee Report.

Robert S. Lynch
Asst. Secretary/Treasurer
RSL.psr
cc: CREDA Board of Directors
CREDA Marketing Committee
:DA Members

IC A
BOUNTIFUL CITY LIGHT AND POWER

INTERMOUNTAIN
CONSUMER POWER
ASSOCIATION
am to xoa SANDY ll7■011•070
TELIP,ONI 0011 MS 293.3

DAM (IO*

12 1987

1

Because the outcome on
being conducted on the Colorado River.
these studies could lead to changes in the power operations

which would reduce power resources available to Western
customers, Bountiful is very concerned with this study.

We understand the Glen Canyon Environmental Study was requested
by the Secretary of Interior to try and quantify the impacts of

the projects and determine if changes in operations with the
appropriate restraints, could minimize these impacts.

would like to state
that two major constraints of this study are 1) the CRSP Act,
which specifically states that "the projects shall be operated so
as to produce the greatest practical amount of power and energy
that can be sold at firm power and energy rates", and 2) it needs
We appreciate this opportunity to comment and

to follow the operating criteria which has been established by
We make
the seven (7) states to optimize the water operations.
reference to the November 11, 1987 CREDA letter to Miss Marlene
Moocy, and agree with the concerns included in this letter.

Again, we appreciate your role in these Glen Canyon studies and
the opportunity you have given us to comment. We understand that
there will he future opportunities to comment on these Glen
Chnyon studies when NEPA Compliance is begun. We are very
Interested in being aware of the studies which are being done as
early in the process as possible and being allowed to participate
whenever possible.
„

/
Clifford C. Michaelis,
Director
CCM:paw
cc: Ted kampton, ICPA
198

South 200 Wee • Bountiful, Utah 84010 • Phone ei,■1.295 9190

C4 C011

..

......
......

mft..

I

_

Dear Marlene:

I appreciated your report which you gave at the ICPA Meeting in
October 1987 on the Environmental and Fish Mitigation Studies

Sincere)

trb btre

/IMF

Mr. Lloyd Greiner
Western Area Power Administration
438 East 200 South, Suite #2
Salt Lake City, Utah 84111

0.00

.C7p

t.JTE I

Ms. Marlene A. Moody
Western Area Power Administration
438 East 200 South, Suite 2
Salt Lake City, Utah 84111

........

000w
kaM

40

12, 1987

Dear Lloyd:

NOV 1 61987

CLIFFORD C MICHAELIS

November
November

SLCAO
OFFICIALFILECOFT

We appreciate the opportunity afforded to the CRSP customers to
review and comment concerning the Glen Canyon Environmental Studies
Draft Report. As a purchaser of Colorado River Storage Project power,
ICPA is vitally interested in all activities surrounding future
operations of the project. ICPA submits the following comments for
and in behalf of its membership for your consideration.
ICPA is a member of the Colorado River Energy Distributors
Association (CREDA) and has participated in CREDA's review of the Glen
Canyon study document. ICPA fully concurs and supports CREDA's
comments pertaining to this matter.

In addition to the concerns addressed by
emphasize the following:

CREDA, ICPA

wishes to

The Colorado River below Glen Canyon Dam is enjoyed by thousands
of individuals who would not have had the opportunity unless the dam
had been constructed. Power generation has been designated to be the
significant source• of repayment of the facility. ICPA is concerned
with the apparent direction and attitude to rely on power revenues as
a source of funding for uses not conteMplated or authorized under laws
pertaining to the development of the Colorado River. The operation of
Glen Canyon DaR should be such as to produce the ;reatest practical
amounts of power and energy that can be 'sold as firm power revenues
for the repayment of the project. Any other uses or activities
jeopardizing power revenues should be examined to determine if lost
revenues could be recovered from other sources.
It is our experience that in studies and evaluations of the
Colorado River, there has been some reluctance to include the
involvement of power users. We are pleased the power users are being
consulted and represented through Western Area Power Administration in
the completion of the Glen Canyon Environmental Studies. We wish to
encourage Western to continue its active role in representing its
power customer and allow every opportunity for customer inputs.

ARIZONA POWER POOLING ASSOCIATION

Marlene Moody
November 12, 1987
Page 2

P. 0. BOX 670
We again thank you for the opportunity to submit these comments
and look forward to our future participation in this process.

BENSON, ARIZONA 85602 • (602) 586-3631

Sincerely yours,

Edward C. Ram on
Manager of Federal Water and
Power Issues

ECR/yta

ARTHUR J. FALL Pascoe
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November 24, 1987

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Ms. Marlene Moody
Western Area Power Administration
438 East 200 South
Suite *2
Salt Lake City, Utah 84147

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Re: Glen Canyon Environmental Study
Dear Ms. Moody:
The Arizona Power Pooling Association ( APPA), as a
member of the Colorado River Energy Distributors Association
( CREDA), is in full support of the comments dated November 11,
1987 which were submitted by CREDA regarding the Glen Canyon
Environmental Study.
APPA would like to emphasiie the following concerns:

1.
Since dollars are always a sensitive issue, we feel
the report should be fair to all sections. Therefore, APPA feels
it inappropriate to include dollars impacts for recreation, and
not for other sections (including power). If it is absolutely
necessary for the dollar impacts to remain in the report, ther.
such impacts should be Included for all other• sections.
2.
The cumulative impact of the various environmental
studies is of concern to APPA. What appears to be a minor impact
in one area could very well become a significant impact when
viewed with all of the other changes that are being proposed.
APPA feels it important that these impacts be viewed on a "total
basin" basis.
3.
Since the CRSP Act is one of the primary governing
laws and this law has specific language concerning the use of the
river for power generation, APPA feels it important the power

_
oolco m. POWER USte
s . 48,

op*

USERS'

POWER

Ms. Marlene Moody
November 24. 1987
Page 2

271/

community be involved in any and all studies. The power community
should be adequately represented and actively participate in this
type of environmental study so as to optimize the multiple uses of
the river.

NORTH SEVENTH

ST. • PHOENIX. ARIZONA

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ELICUT7•111
01•••••••71

APPA thanks you for this opportunity to submit comments
c n the report, and urges you to take the necessary action in order
to present the power viewpoint to other federal agencies.

November 24, 1987

Should you have any questions regarding these comments
or be in need of further information, please do not hesitate to
contact the undersigned.

Ms. narlene Moody
Western Area Power Administration
438 East 200 South
Suite 12
Salt Lake City, Utah 84147

Very truly yours,
ARIZONA POWER POOLING ASSOCIATION

S1008.1007

SLCAO
OFFICIALFILECOPY
NOV 30 1987

Re: Glen Canyon Environmental Study
Dear Ms. Moody:

By

Arthur J. Faul, President

The Arizona Municipal Power Users' Association (AMPUA),
as a member of the Colorado River Energy Distributors Association
(CREDA), is in full support of the comments dated November 11,
1987 which were submitted by CREDA regarding the Glen Canyon
Environmental Study.
AMPUA would like to emphasize the following concerns:
1.
Since dollars are always a sensitive issue, we feel
the report should be fair to all sections. Therefore, AMPUA feels
it inappropriate to include dollars impacts for recreation, and
not for other sections (including power). If it is absolutely
necessary for the dollar impacts to remain in the report, then
such impacts should be includ:A for all other sections.
2.
The cumulative impact of the various environmental
studies is of concern to AMPUA. What appears to be a minor impact
in one area could very well become a significant impact when
viewed with all of the other changes that are being proposed.
AMPUA feels it important that these impacts be viewed on a "total
basin" basis.
3.
Since the CRSP Act is one of the primary governing
laws and this law has specific language concerning the use of the
river for power generation, AMPUA feels it important the power
community be involved in any and all studies. The power community
should be adequately represented and actively participate in this

Ms. Marlene Moody
November 24, 1987
Page 2

type of environmental study so as to optimize the multiple uses of
the river.
AMPUA thanks you for this opportunity to submit comments
on the report, and urges you to take the necessary action in order
to present the power viewpoint to other federal agencies.
Should you have any questions regarding these comments
or be in need of further information, please do not hesitate to
contact the undersigned.
Very truly yours,

Ass.. A 10

ARIZONA MUNICIPAL POWER USERS'
By

N.)

cc: Management Committee

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