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Grand Canyon Campaign

Headlines

February 7, 2024
LR in the News
Glen Canyon Dam: In managing Colorado River dam Feds ignored climate change, conservationists tell Appeals Court

January 23, 2013
LR Press Release
Controlled Flood in Grand Canyon a Dud

August 14, 2012
Regional News
9th Circuit rules against Recovery of Endangered Species

May 25, 2012
Reference
The Glen Canyon Dam Declaration of 3/14/2000

May 18, 2012
LR in the News
Federal Regulators Reject Green River Pipeline Again

March 28, 2012
Regional News
Agencies Weigh Competing Suggestions For New Glen Canyon Dam Plan

Submit Your Comments

The form below contains suggested scoping comments for the Bureau of Reclamation's EIS on the Long Term Experimental Plan for the Future Operations of Glen Canyon Dam. Please use this form to email your comments to Regional Director Rick Gold.

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Unless authorized below, the information submitted in this form will only be sent to one recipient (Rick Gold). If you elect to send your comments to Living Rivers/Colorado Riverkeeper, under no circumstances will we share your personal information with other organizations.

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Dear Mr. Gold,

Thank you for the opportunity to submit the following scoping comments for the Environmental Impact Statement on the Long-term Operations for the future operations of Glen Canyon Dam. The river ecosystem in Grand Canyon National Park has suffered immensely over the past forty years due to the operations of Glen Canyon Dam, and it's vital that a fresh look at the problem be undertaken. I have concerns, however, that the EIS as envisioned is destined to fail in this regard unless a number of critical issues are addressed.

First, I would like to express my tremendous dismay with the Department of Interior's mishandling of the recovery efforts in Grand Canyon National Park over the past 40 years, and that the information presented so far by the Bureau of Reclamation indicates that this EIS promises more of the same.

While new plans for ongoing investigation and experimentation can be beneficial, they are useless amidst a backdrop where the commitment to implement those plans is virtually non-existent. We've already experienced this with the completion of the first EIS twelve years ago, and there's nothing outlined in the purpose and need for this EIS process to indicate things will be any different once this process concludes. For this exercise to yield any meaningful outcome, the EIS process must be reconceived incorporating the following:

1. Restructuring the focus of the EIS on the recovery.

The principal objective should not be the long-term operation of Glen Canyon Dam, but the ingredients necessary to bring about the recovery and preservation of endangered species within the Colorado River corridor of Grand Canyon National Park. While such objectives may not be mutually exclusive, this has yet to be proven, and as such, one should precede the other. The focus must first address the ingredients necessary to restore the natural process to Grand Canyon's river ecosystem, and secondly how, and at what costs, can the Glen Canyon Dam/Lake Powell reservoir system be operated in order to achieve this. The restoration ingredients must include:

The return of river flows consistent with the Colorado River's natural discharge into Grand Canyon.

The re-establishment of a water temperature regime consistent with seasonal temperature variations of the Colorado River in Grand Canyon.

The re-establishment of sediment inputs into Grand Canyon consistent with the amount that would be received in a dam-free environment.

The elimination of non-native species, which have taken hold in the artificial riverine environment created by Glen Canyon Dam operations.

2. Evaluate the Decommissioning of Glen Canyon Dam.

The no-dam alternative must be evaluated as one means of achieving the restoration of the natural process necessary for the recovery and preservation of endangered species in Grand Canyon's river corridor. The no-dam alternative provides a valuable base line from which to evaluate other operational alternatives. Additionally, in light of the climate and human induced changes affecting flows into Lake Powell, and thus the viability of the dam to meet perceived water supply and hydroelectric benefits, BoR has additional incentive to examine a decommissioning or no-dam alternative consistent with the Council on Environmental Quality guidelines.

3. Replace the Working Groups of the Adaptive Management Program.

Despite being given specific instructions twelve years ago as outlined in the 1995 EIS on Glen Canyon Dam operations, the Glen Canyon Dam Adaptive Management Program (AMP) has failed to deliver in almost every aspect, causing Grand Canyon's river ecosystem to endure further damage. Many of AMP's failings were spelled out in the United State's Geological Survey's SCORE Report of October 2005. It was precisely these failings that have compelled BoR to undertake this new EIS process as part of its settlement agreement with environmental groups last year. Absent any structural changes to the AMP, any recommendations coming out of this EIS process will be of little value, as there are no mechanisms to ensure they won't be ignored as were those from the EIS twelve years ago.

Dominated by water supply and hydroelectric power interests, it's not surprising that the AMP has been intransigent toward addressing the true needs for endangered species recovery in Grand Canyon. Scientific, not political and commercial interests, should be the sole advisors to the Secretary ofInterior on how Grand Canyon's river ecosystem should be studied, monitored and managed consistent with the recovery objectives.

Therefore, the AMP should be replaced by an open source and independent body of research and advisory scientists, where the monitoring and research data are consistently and thoroughly peer-reviewed prior to formulating any recommendations to the Secretary of Interior.

We're closing in on 50 years of ecological destruction in Grand Canyon National Park due to the operations of Glen Canyon Dam. For much of this time the public has been asking that this be remedied. We continue to lose valuable time and species as the BoR procrastinates and resists the public's mandate to put the resource first. While there are plenty of substitutes to achieve the benefits Glen Canyon Dam may provide, there will never be another Grand Canyon. It's time for the BoR to stop thwarting the public's interest to protect it.

Sincerely,

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Last Update: January 29, 2007




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