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VICTORY! Supreme Court: Grand Canyon Uranium-Mining Ban Stands

Grand Canyon Trust
North Rim. Photo by Blake McCord

Dear James,

Ready for some good news? The Grand Canyon uranium ban stands!

After a protracted legal battle to defend the temporary ban on new uranium claims around the Grand Canyon from attacks by the mining industry, the highest court in the land has finally put the matter to rest. On Monday, the Supreme Court denied an industry challenge to a lower court’s decision upholding the ban. This puts an end to the legal battle to reopen about 1 million acres of public land around the Grand Canyon to new uranium mining. We’re deeply grateful for the government’s savvy and forceful efforts to defeat the mining industry’s lawsuit, from the trial court to the U.S. Supreme Court.

The culmination of years of hard work, this victory is shared — with the Havasupai Tribe who make their home at the bottom of the Grand Canyon, with hunting and angling groups, local governments, allies in Congress, and other partners. And we wouldn’t be here without the hundreds of thousands of concerned citizens like you who have raised their voices to protect the Grand Canyon. Thank you.

While this decision is a very big step in the right direction, our work isn’t over yet. The current administration could still decide to lift the ban. It has listed uranium as a “critical mineral” and the Department of Commerce is in the midst of developing a strategy to streamline access to critical mineral deposits, including uranium. The Department of Commerce is also investigating, at the request of two uranium companies, whether to recommend uranium import quotas. Both of these things have significant potential to add political pressure to lift the ban.

Who owns uranium claims around the Grand Canyon? There are more than 800 active mining claims around the Grand Canyon.

The mining industry promises to continue to advocate against the ban and some politicians openly call for the ban to be rescinded.

A U.S. Forest Service recommendation to review and revise the ban is still floating in the ether.

In a meeting last month, Deputy Secretary of the Interior David Bernhardt told the Grand Canyon Trust that the agency currently has “no reason” to reconsider the ban. We’re very happy to hear this, of course, but we remain alert to the ever-shifting circumstances that could move this administration to give in to political pressure and open the door to attempts to weaken or lift the ban.

Thank you for your support over the last months and years, and for sticking with us for the long haul, working together to Keep the Canyon Grand.

Sincerely,

Amber Reimondo
Energy Program Director

P.S. While this is a critical win, we’re celebrating with vigilance. Pressure from the mining industry continues. Now is the time to double down on protections for the Grand Canyon. Donate to the Trust today.

Photo courtesy of Blake McCord.

Grand Canyon Trust
2601 N. Fort Valley Rd

Flagstaff, AZ, 86001
Phone: (928) 774-7488
grandcanyontrust.org

@GrandCanynTrust @GrandCanyonNPS @NatlParkService #PaddlesportsLaw #GCRG #GrandCanyonRiverGuides #WhitewaterPark #WhitewaterLaw #RecLaw #RecreationLaw #OutdoorLaw #OutdoorRecreationLaw #OutdoorIndustry #ORLawTextbook

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Urgent Action Needed By 9/2 to Save the Confluence of the Little Colorado and the Colorado River in the Grand Canyon

CALLING ALL CANYON & RIVER ADVOCATES — The unthinkable has happened. Legislation has been submitted within the

Grand Canyon River Guides Association

Grand Canyon River Guides Association

Navajo Nation for the Grand Canyon Escalade proposal (421 acres of development above the sacred confluence of the Little Colorado and Colorado Rivers, with a gondola/tramway that could bring 10,000 people down to river level PER DAY). If approved, this massive development would FOREVER CHANGE GRAND CANYON!

EVERYONE should submit comments and speak out against this terrible proposal before the deadline which is 5:00 PM this Friday, Sept 2nd!! Please spread the word far and wide through email and social media! We need YOUR help!

1. READ THIS HORRIBLE LEGISLATIVE PROPOSAL AT http://www.navajonationcouncil.org/Legislations/2016/AUG/0293-16.pdf

2. SIGN THE PETITION AGAINST THIS PROPOSAL! The petition link can be found at www.savetheconfluence.com (and please encourage others to support and follow the STC Facebook page, sign up for email alerts, etc.)

3. COMMENT DIRECTLY TO THE NAVAJO NATION! You can email directly to comments or you can mail comments to: Executive Director Office of Legislative Services P.O. Box 3390 Window Rock, AZ 86515 (928) 871-7590. Comments may be made in the form of chapter resolutions, letters, position papers, etc. Please include your name, position title, address for written comments; a valid e-mail address is required. Anonymous comments will not be included in the Legislation packet.

For a 2 page summary of the proposed legislation: http://www.grandcanyontrust.org/sites/default/files/gc_Confluence_Partners_Escalade.pdf
For more information on what’s at stake: http://www.grandcanyontrust.org/stopping-grand-canyon-escalade
And also: http://savetheconfluence.com/news/proposed-grand-canyon-escalade-bill-starts-move/

The bottom line is:

· This is GRAND CANYON – one of the seven NATURAL wonders of the world. If the Navajo Nation government approves this development, the integrity of values for which Grand Canyon was created will be severely compromised and degraded FOREVER.

· The Little Colorado River corridor and its confluence with the Colorado River is culturally and spiritually significant to ALL of the affiliated tribes who hold Grand Canyon sacred.

· A fragile, delicately balanced ecosystem is at stake. Proposed development raises serious questions about water, sewage, noise, impacts to endangered species (such as the humpback chub that spawn in the Little Colorado River), dark skies and wilderness values.

Nothing less than the future of Grand Canyon is at stake. We support the tireless efforts of SAVE THE CONFLUENCE and all those who adamantly oppose this massive development. Grand Canyon River Guides’ mission statement states: “We will act whenever a canyon natural resource is threatened or the quality of the Grand Canyon experience is compromised.” STAND WITH US AND TAKE ACTION NOW!!! Canyon and river stewards unite!!

Lynn Hamilton
Executive Director
Grand Canyon River Guides


Guiding Opportunity at Grand Canyon National Park

Arizona Outback Adventures will be conducting a series of day hikes on various trails at the South Rim of Grand Canyon National Park on May 19th 2012.

We are recruiting guides to join our existing staff for three days of work on a contract basis.

Pay is $100.00-$120.00 per day dependent upon experience and qualifications

Guaranteed gratuity plus additional tips possible

All meals, park entrance and camping fees included

Applicants are required to have:

·          Current WFR certification (or higher)

·          Current CPR certification

·          Good general knowledge of Grand Canyon’s history, geology, flora and fauna

·          Experience hiking the main trails from the South Rim

·          The ability to handle a group of seven diverse hikers on your own

·          The ability to follow specific instructions and procedures

·          A day pack, comprehensive first aid kit, trowel and all appropriate clothing and footwear for changing weather conditions

·          Be physically fit

·          Have a pleasant, friendly and engaging personality

·          Have a presentable appearance

·          Be available from 5:00am 5/17 through 9:00pm 5/19

·          Experienced Grand Canyon hiking and rafting  guides preferred

To apply email tim@aoa-adventures.com with a brief outline of your experience and qualifications, list all trails that you have hiked from the Main South Rim area (Hermit to Grandview) and the approximate number of times on each trail. Attach a current photo and a single sheet with a color scan of your Driver’s License, WFR Card and CPR card (if separate) with expiration dates clearly showing.

What do you think? Leave a comment.

If you like this let your friends know or post it on FB, Twitter or LinkedIn

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Guiding Job in the Grand Canyon

Angel’s Gate Tours is looking for experienced Grand Canyon guides to lead sightseeing tours, day hikes and the occasional backpacking trip in Grand Canyon. We are specifically recruiting experienced Grand Canyon boatman and other Grand Canyon backcountry professionals. Please contact us if you meet the following requirements:

  • Minimum WFR certified, with CPR. (More advanced med certs are also acceptable).
  • Good driving record. (1 minor ticket is usually OK)
  • Must be able to pass Arizona DOT physical (this is pretty simple, basically it verifies that you can see, hear and move well enough to drive a vehicle).
  • Outstanding Grand Canyon knowledge. (You know your schist from Shi-nola, and can present complex material in an entertaining manner).
  • Hiking experience on all South Rim trails.

This is an excellent opportunity for Grand Canyon backcountry professionals that need to spend more time in town due to family, children, dog issues or other constraints. The majority of our tours and hikes depart from and return to Flagstaff daily. Please visit our website at www.SeeGrandCanyon.com and call (928) 814-2277 to schedule an interview. Angel’s Gate Tours is an EOE.

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Long Term Experimental & Management Plan Draft EIS for Glen Canyon Dam

English: Photograph of Glen Canyon Dam & Lake ...

Image via Wikipedia

 Grand Canyon River Guides, Inc.

 Scoping comments on the development of a

Long Term Experimental & Management Plan Draft EIS for Glen Canyon Dam

Submitted January 17, 2012

1  Introduction

Grand Canyon River Guides, Inc. (GCRG) was founded in 1988 to provide a collective voice to protect Grand Canyon and the Colorado River experience.  Our non-profit 501(c)(3) educational and environmental organization is made up of over 1,600 river guides and fellow travelers who care deeply about Grand Canyon and the Colorado River.  Most of our officers and board members are (or have been) professional river guides in Grand Canyon.  The same is true of our 800+ guide members.  Having spent much of our lives immersed in the Grand Canyon river experience, our collective perspectives are uniquely well informed.

The Grand Canyon experience has a remarkable effect on our lives and the lives of those we share the canyon with, and inspires us to preserve its legacy for future generations.  Our mission is to:

Protect the Grand Canyon

Provide the best possible river experience

Set the highest standards for the guiding profession

Celebrate the unique spirit of the river community

Since its inception, GCRG has been heavily involved with dam management issues beginning with the initial Glen Canyon Dam EIS process in the early 1990s.  Our members played an instrumental role in the passage of the Grand Canyon Protection Act of 1992 – “As Arizona Senator John McCain said in Flagstaff a short time before the signing, a lot of the credit goes to the guides who realized that things were not right and kept the issue alive.” (Boatman’s Quarterly Review, Volume 5 #4, Fall 1992).   Our subsequent involvement as the recreational river running stakeholder within the Glen Canyon Dam Adaptive Management Program (GCDAMP) has provided GCRG representatives with an opportunity to unify and direct the concerns of the river community on scientific and policy issues affecting operations of Glen Canyon Dam.

We are therefore very appreciative of the opportunity to provide scoping comments for the development of an Environmental Impact Statement (EIS) for the Long Term Experimental and Management Plan (LTEMP).  We realize what an incredibly complex and challenging process this will be, but we are encouraged that the Bureau of Reclamation and the National Park Service will work together as cooperating agencies in charge of this endeavor.  And we expect that you will conduct thorough and respectful consultation with the eleven affiliated tribes of the Grand Canyon as well.

Our members understand that a river expedition through Grand Canyon is a highly sought after and deeply treasured outdoor experience.  As river guides, we have direct contact with the 20,000 people who seek out this world class recreational river running experience each year. We understand that without proper protection, we could lose one of the most valued, irreplaceable areas, not only of the United States, but of the world. Taking a broader view, the National Park System is part of our national heritage, and it is our profound responsibility to protect and preserve it on behalf of all Americans, including future generations.

Consequently, as river stewards, Grand Canyon River Guides would like to share our vision for dam management and the experimentation efforts on the Colorado River which should serve as context for the development of the LTEMP and LTEMP alternatives.  The elements of our vision are as follows:

English: A picture of the Marble Canyon sectio...

Image via Wikipedia

  • A long term, scientifically-grounded, and sustainable “ecosystem management” approach for the river corridor that carefully preserves park resources and values in accordance with the National Park Service Organic Act, the Endangered Species Act, the Grand Canyon Protection Act, the 2006 NPS Management Policies, the Redwoods Amendment, and other federal legislation.
  • Re-establishing the range of natural variability for all ecosystem patterns and processes in keeping with the conservation mandate from the 2006 NPS Management Policies which requires that “The Service will reestablish natural functions and processes in parks unless otherwise directed by Congress.” (NPS Management Policies, Section 4.1.5).  This is also in keeping with one of the nine principles of the GCDAMP: “Dam operations and management actions will be tried that attempt to return ecosystem patterns and processes to their range of natural variability. When this is not appropriate, experiments will be conducted to test other approaches.” (Strategic Plan, Glen Canyon Dam Adaptive Management Program, August 17, 2001)
  • Protection of the fragile and non-renewable cultural resources and Traditional Cultural Properties along the river corridor in accordance with the National Historic Preservation Act of 1966 and related laws.
  • A renewed commitment to respect and incorporate values and traditional cultural knowledge from the eleven affiliated tribes of the Grand Canyon.  Those spiritual and cultural connections, concerns, and objectives must be woven into the LTEMP and incorporated more effectively and holistically into the GCDAMP.
  • A river corridor ecosystem that matches the natural conditions as closely as possible, including a biotic community dominated in most instances by native species.
  • A river corridor landscape that matches natural “pre-dam” conditions as closely as possible, including extensive beaches and abundant driftwood.
  • Numerous campable sandbars distributed throughout the canyon within a scour zone between the 8,000 – 35,000 cfs levels, built and maintained by Habitat Maintenance Flows and Beach Habitat Building Flows (BHBF) timed to maximize/optimize sediment distribution throughout the river corridor, and conducted under sediment-enriched conditions.
  • River flows that continue to be within a range that ensures navigability and boating safety (8,000 cfs minimum).
  • Preservation and enhancement of a full range of recreational opportunities along the river corridor including the opportunity to experience the wilderness character of the canyon.  Wilderness experiences and benefits available in the canyon include solitude, connection to nature, personal contemplation, joy, excitement, the natural sounds and quiet of the desert and river, and extended time periods in a unique environment outside the trappings of civilization.
  • Stewardship worthy of Grand Canyon so it can be passed from generation to generation, unimpaired.

(Excerpted and/or adapted from “A Narrative of Desired Future Resource Conditions for the Colorado River Ecosystem in Grand Canyon” by Andre Potochnik and Matt Kaplinski as published in BQR Volume 14 #1, Spring 2001, and other internal GCRG documents and discussions).

2  Comments on the Purpose and Need

English: Aerial view of Glen Canyon Dam site p...

Image via Wikipedia

The Notice of Intent to prepare an EIS and conduct scoping on the adoption of a Long Term Experimental and Management Plan indicates that the Purpose and Need for Action is as follows:

               “The purpose of the proposed action is to fully evaluate dam operations and identify management actions and experimental options that will provide a framework for adaptively managing Glen Canyon Dam over the next 15 to 20 years consistent with the GCPA and other provisions of applicable Federal law. The proposed action will help determine specific alternatives that could be implemented to meet the GCPA's requirements and to minimize—consistent with law—adverse impacts on the downstream natural, recreational, and cultural resources in the two park units, including resources of importance to American Indian Tribes. 
               The need for the proposed action stems from the need to utilize scientific information developed over the past 15 years to better inform Departmental decisions on dam operations and other management and experimental actions so that the Secretary may continue to meet statutory responsibilities for protecting downstream resources for future generations, conserving ESA listed species, and protecting Native American interests, while meeting water delivery obligations and for the generation of hydroelectric power.” (Federal Register, Volume 76, Number 129, July 6, 2011)
 A) GCRG feels this Purpose Statement does not do justice to the situation at hand.  Congress passed the Grand Canyon Protection Act (GCPA) of 1992 to give guidance to the initial Glen Canyon Dam EIS, to establish and implement long term monitoring programs and research activities, and to determine if the revised dam operations were achieving the resource protection objectives of the 1995 Final EIS and the 1996 Record of Decision.  The GCPA states:

“The Secretary shall operate Glen Canyon Dam… in such a manner as to protect, mitigate adverse impacts to, and improve the values for which Grand Canyon National Park and Glen Canyon National Recreation Area were established, including, but not limited to natural and cultural resources and visitor use.” (GCPA, Section 1802)

The GCPA directive to “…protect, mitigate adverse impacts to, and improve the values…” has been watered down to “…minimize—consistent with law—adverse impacts…”  This should be changed.  The Grand Canyon should be protected and improved to the full intent of the GCPA.

B) The reference to hydropower should be dropped from the need statement.  Water storage and water delivery obligations are the primary purposes of Glen Canyon Dam, whereas hydropower is an ancillary benefit.  The construction of Glen Canyon Dam was authorized by the Colorado River Storage Project Act of 1956 (Public Law 84-485).  The underlying project purposes are outlined in Section 1 of the Act (43 United States Code [U.S.C.] ‘ 620) which authorized the Secretary of the Interior to “construct, operate, and maintain” Glen Canyon Dam:

. . . for the purposes, among others, of regulating the flow of the Colorado River, storing water for beneficial consumptive use, making it possible for the States of the Upper Basin to utilize, consistently with the provisions of the Colorado River Compact, the apportionments made to and among them in the Colorado River Compact and the Upper Colorado River Basin Compact, respectively, providing for the reclamation of arid and semiarid land, for the control of floods, and for the generation of hydroelectric power, as an incident of the foregoing purposes . . ..

(emphasis, ours)

For many years Glen Canyon Dam was operated with hydropower revenue as the main operational consideration, to the great detriment of the river corridor ecosystem.  The chief considerations for the LTEMP should be protection and recovery of that ecosystem.

Therefore, we recommend that the EIS team consider changing the Purpose and Need for Action Statement as follows:

  • Change the language of the Purpose statement to accurately reflect the language and intent of the Grand Canyon Protection Act.
  • Drop the reference to hydropower.

3  Comments on the Process

The Glen Canyon Dam near Page (AZ) as seen fro...

Image via Wikipedia

Define and ensure a substantial role for the Grand Canyon Monitoring and Research Center (GCMRC) within the LTEMP EIS process. 

  • GCMRC’s involvement is critical to draw on the body of knowledge that has been gained as the science arm of the Glen Canyon Dam Adaptive Management Program.
  • GCMRC’s involvement is also necessary for the development and evaluation of scientifically credible, well-defined alternatives to best meet program and ecosystem goals.

It’s clear that the LTEMP team at Argonne Labs are knowledgeable and experienced, and we are sure they will do as conscientious and high-quality a job as is required for a place as unique and important as the Grand Canyon.  However, on the whole they themselves have little to no direct experience with and knowledge of the canyon and the river.  No scientific background, no matter how extensive and thorough, can impart a complete understanding of such a complex place.  Because of this we suggest:

  • Argonne Labs should work in close consultation with Grand Canyon Monitoring and Research Center (GCMRC).  They know their research well, and they also understand the context supporting their research.
  • Core members of the Argonne team should invest the time to go on a river trip through the Grand Canyon and get to know the place first hand.
  • The Argonne team should communicate with and ask questions of stakeholders during the NEPA process.

The LTEMP should reflect the societal shift to a desire for river restoration and ongoing protection.  Previous studies have examined operational restrictions to Glen Canyon Dam in terms of environmental constraints to hydropower. The dam operations and the subsequent result of the LTEMP EIS must not be viewed in terms of environmental constraints but instead, environmental responsibilities.  We therefore urge that the new LTEMP to reflect a shift in focus and language that corresponds with a statement made by Bureau of Reclamation Commissioner, Mike Connor:

 “It is certainly my goal over the next decade that Bureau of Reclamation becomes as well known for its expertise in river restoration as it is for building dams, maintaining dams, and building and taking care of other water supply infrastructure.”  (http://www.usbr.gov/river/video.html)

The National Environmental Policy Act (NEPA), the Grand Canyon Protection Act (GCPA), and the Endangered Species Act (ESA) together represent a distinct societal shift from the dam-building “man over nature” mentality to an improved understanding of, and deep desire for the protection of, the natural, cultural and visitor use values of our public lands.  The LTEMP should be one more step down the path of preserving, protecting and improving those values for future generations to enjoy.

Look to other dam managed rivers, examine their challenges and successes in restoring natural patterns and processes while a dam is still in place and utilize that expertise to inform and strengthen the LTEMP process. Existing knowledge and research should inform the decision on whether to build a Temperature Control Device (TCD) on Glen Canyon Dam.  For example, it might be useful to compare native fish recruitment and survival in the upper basin due to the affects of the Flaming Gorge TCD with what could be expected in Grand Canyon.  Or utilize the TCD at Flaming Gorge to carry out temperature variation experiments on native fish populations in the upper basin.  These results could be used for extrapolation of TCD effects in Grand Canyon.  The question that must be answered is… “whether the potential benefits to the endangered fish of operating a TCD and warming the water outweigh the potential adverse effects from potential increases in nonnative predators, parasites and diseases, or other unintended, systemic interactions in the downstream environment.” (Biological Assessment on the Operation of Glen Canyon Dam, 2007)

Ensure that the eleven affiliated tribes who live in and around the Grand Canyon and the Colorado River have a substantive role in LTEMP development which continues throughout the LTEMP process, and the life of the plan.  The LTEMP must find a way to successfully incorporate tribal values and knowledge into policy development and decision making – a distinct challenge for the Adaptive Management Program to date.

  • Towards that end, science must not be the only lens through which we view the Colorado River ecosystem (CRE), its resources, and associated values.  Respectful and thorough tribal consultation must occur at each stage and those cultural and spiritual connections must be woven into the LTEMP and incorporated more effectively into the Glen Canyon Dam Adaptive Management Program.

The LTEMP should consider more than just the last 15 years of science: 

  • Review the scientific evidence from Phase 1 of the Glen Canyon Environmental Studies (GCES) that served as the basis for the Record of Decision of the initial Glen Canyon Dam EIS.  Utilizing that information in light of what we know now, could be beneficial.
  • Examine pre-dam conditions to provide some much needed perspective for developing future management directions for the Colorado River.  We specifically recommend reviewing: “Observations of Environmental Change in Grand Canyon, Arizona,” (Webb, Melis and Valdez, 2002, http://wwwpaztcn.wr.usgs.gov/webb_pdf/WRIR4080.pdf ).  The report incorporates historical diaries, interviews with pre-dam river runners, repeat photography, and historical data and observations.

The LTEMP should be considered in the light of outside processes, such as equalization flows, that cause severe adverse impacts to the downstream resources in Grand Canyon.  In December of 2007, responding to the worst eight years of drought in a century of record keeping, the Secretary of the Interior adopted the Colorado River Interim Guidelines for Lower Basin Shortages and the Coordinated Operations of Lake Powell and Lake Mead.  The specific focus of these guidelines was to address water availability in the Lower Basin and the operations of Lakes Powell and Mead during drought and low reservoir conditions.  As we shifted to the Equalization Tier in 2011, between January 1 and August 1, the amount of sediment transported in all of Grand Canyon (from Lees Ferry to Diamond Creek), equalled 2.1 to 3.7 million metric tons, with the specific breakdown by reach as follows:

Reach                                    Sediment Exported between Jan 1 – Aug 1, 2011

English: The Colorado River near Nankoweap Cre...

Image via Wikipedia

0 to 30 mile                1.4 to 1.6 million metric tons

30 mile to 60 mile     .2 to .5 million metric tons

61 mile to 87 mile     .5 to 1 million metric tons

87 mile to 225 mile   0 to 0.6 million metric tons

(GCMRC unpublished data presented at the August 24-25, 2011 AMWG meeting).

The magnitude of sediment erosion caused by the equalization flows is sobering, and efforts to rebuild that sediment (which is a foundational element for the health of many Colorado River resources) may have been set back years. Clearly higher flow volumes have a direct and profound effect on sand transport, which is also corroborated in the modeling simulations of sand transport for hypothetical annual release volumes as published in USGS Open File Report 2010-1133, Evaluation of Water Year 2011 Glen Canyon Dam Flow Release Scenarios on Downstream Sand Storage along the Colorado River in Arizona (Wright and Grams, 2010).

GCRG therefore considers it essential that the LTEMP process should take a proactive stance to managing for the possibility of future equalization needs that will help achieve LTEMP and GCDAMP goals rather than the current reactive mode that clearly thwarts those goals and makes them all the more difficult to achieve.

Desired Future Conditions (DFCs) developed within the GCDAMP with DOI input and approval should be utilized in analyzing the impacts of LTEMP alternatives and applied as a benchmark for defining identified objectives that are scientifically measurable and attainable through dam operations during the life of the Plan.  The goal should be to “ensure that park resources and values are passed on to future generations in as good as, or better than, the conditions that exist today.” (Section 1.4.7.1, NPS Management Policies, 2006).  Related considerations include:

  • The Core Monitoring Program under development by the Grand Canyon Monitoring & Research Center will help track progress towards those desired outcomes.
  • The DFCs must not be static, but rather they must be continually refined as new knowledge is gained, unacceptable impacts are discerned, and subject to a determination of whether the specific DFCs are achievable.

Since the Record of Decision for the initial Glen Canyon Dam EIS created the Glen Canyon Dam Adpative Managment Program, the LTEMP EIS should be able to address and improve its structure and functionality in order to meet GCDAMP mission and goals.   Simply put, we would like to see a much more balanced GCDAMP stakeholder group that has the ability and willingness to act adaptively on what is learned.

4  Comments on Alternatives

GCRG wishes to provide two kinds of comments about proposed alternatives here – elements that should be applied to all flow regime alternatives that are considered within this Draft EIS, and our suggestions for possible alternatives that should be considered for inclusion.

4.1  Elements common to all alternatives

First and foremost, it is paramount that all alternatives fully meet the intent of the 1992 Grand Canyon Protection Act. The act specifically states, ´The Secretary shall operate Glen Canyon Dam…in such a manner as to protect, mitigate adverse impacts to, and improve the values for which Grand Canyon National Park and Glen Canyon National Recreation Area were established, including, but not limited to natural and cultural resources and visitor use,” (GCPA, Section 1802).

The selected alternative should improve the quality of recreational resources for users of the Colorado River, and ensure their protection for generations to come. This is in line with Goal 9 of the Glen Canyon Dam Adaptive Management Program and the specific Management Objectives tied to that Goal (MO 9.1: quality of recreational opportunities; MO 9.2: visitor safety; MO 9.3: beaches and campsites; MO 9.4: the wilderness experience; and MO 9.5: maintaining the visitor experience affected by GCDAMP activities).  More importantly, this is the right thing to do, in keeping with the fundamental purpose of all parks to provide for the enjoyment and preservation of park resources and values, including visitor use.

All alternatives must include the continuation of a robust program of scientific research and experimentation. Our understanding of the system has greatly improved in the last fifteen years, but even so there is much left to learn.  Some ideas that were once almost axiomatic are now less clearly true.  The system is complex, and to manage it well, for the long term, we need to continue to learn about it.

Beach Habitat Building Flows (BHBFs) should be a well-defined, key component of all alternatives.  The BHBF is the only known mechanism to test whether sand can be sustained in the river ecosystem on a multi-year time scale and a “critical tool” according to GCMRC. (Melis, 2011, ed., USGS Circular 1366, Page 141)

  • The High Flow Experimental Protocol Environmental Assessment should be finalized and incorporated into the design of all LTEMP alternatives.
  • A science plan for the Rapid Response model should be developed.  The plan should be included if it can be successfully integrated without confounding the results of regular HFE events.
  • Recommendations from Grand Canyon Monitoring & Research Center for optimizing the results of future High Flow Experiments should be incorporated, specifically that the “…design of controlled floods for optimal sandbar deposition in the Colorado River in Grand Canyon National Park should not be based only on threshold levels of sand enrichment, but also on reach-averaged bed-sand median grain size.” (Topping, Grams, and others, 2010, Page 101)
  • Variability should be introduced into the system by changing the level and timing of the High Flow Experiments (not just 42,000 to 45,000 cfs, or early spring every time).  Flood events are a natural occurrence of free-flowing rivers and controlled floods were introduced in Grand Canyon in order to mimic those highly variable pre-dam flood events.  Experimental BHBFs could be undertaken during the historic hydrograph peak, the monsoon season, and winter flood events (Chapter 5, Figure 6, USGS Circular 1366)
  • Consider testing experimental high flows above 45,000 cfs when hydrologic conditions allow. According to GCMRC, “Testing of peak flows greater than 45,000 ft3/s is scientifically justified, but is constrained by current low reservoir levels such that the spillways at Glen Canyon Dam are inaccessible. Higher peak flows could be considered in the future if reservoir levels permit.” (Melis, 2011, ed., USGS Circular 1366, Page 139) Before Glen Canyon Dam was completed, the annual spring snowmelt floods ranged between about 35,000 and 120,000 cfs, and averaged around 55,000 cfs with peak flows of 120,000 cfs reoccurring about once every size years (Topping and others, 2003).

For all alternatives, flows between BHBFs should be designed to maximize sediment retention. In the report synthesizing the results of the three High Flow Experiments conducted to date, GCMRC notes that, “For sandbars, the intervening dam operations are important because they determine the rate of post-HFE sandbar erosion, the rate of export of sand from the system flowing tributary-derived sand inputs, and thus the amount of sand available for building sandbars during a given HFE.” (Melis, 2011, ed.,USGS Circular 1366, Page 143).

  • Address the preservation of sand deposits by designing post-High Flow Experiment hydrographs that optimize ecosystem goals (i.e. sediment retention) to the greatest extent possible.
  • Intervening dam operations must be carefully considered in the context of an ecosystem approach and the respective tradeoffs they may elicit.

All alternatives must be based on an adaptive ecosystem management approach. This is a dynamic and complex system.  Our learning and adapting/building on what we know must continue indefinitely.  According to the USGS, “The most effective strategy for future releases from Glen Canyon Dam is one that provides flexibility and adaptability – flexibility that would allow the best scientific information to be used in decisionmaking, and adaptability would allow ongoing learning to be readily incorporated in the process.” (“Effects of Three High-Flow Experiments on the Colorado River Ecosystem Downstream from Glen Canyon Dam, Arizona,” Circular 1366, Page 143)

For all alternatives, experiments need to be:

The Grand Canyon is a steep-sided gorge carved...

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  • well planned and scientifically credible,
  • of sufficient length to elicit measurable responses,
  • coupled with long term monitoring to ascertain the impacts to the various resources, and,
  • followed by a timely synthesis of that information to GCDAMP program stakeholders.

All alternatives should include an increased experimental and managerial focus on cultural resources along the river corridor.   Archaeological site conditions will continue to deteriorate at unknown rates due to impacts from erosion and visitor use.  Impacts that the NPS views as being directly related to dam operations include: bank slumpage and gullying/arroyo cutting in locations where drainage systems are actively entrenching to achieve grade with the present-day “highest discharge” terrace levels formed under dam-controlled flows. (SCORE Report, Page 182).  Additionally, any reduction in beach size and distribution exacerbates crowding and congestion along the river corridor, which in turn can lead to impacts to the high terraces where archaeological sites are often located.

All alternatives should include a thorough and rigorous socio-economics study.  Flows from Glen Canyon Dam run through a very complex system.  For managers to make wise decisions now and protect the river corridor for generations to come, they need a clear understanding not just of the mechanics and interrelationships of system components, but also the value of those components.  For example, the estimated cost of analyzing, permitting, building and operating a sediment replacement system should be used to determine the value of the sediment removed by MLFF flows (or other LTEMP alternative flows), and as a comparison to values obtained from use of the power plant for peaking flows.

Additionally, a lack of a strong socio-economic study has been a major weakness of the Glen Canyon Dam Adaptive Management Program.  In their comments for the 1996 ROD, the GSA specifically mentioned that socio-economic understanding of the system was weak, and little has been done to correct that weakness in fifteen years since.

When developing and choosing alternatives, the focus should be on benefiting, protecting and preserving all of the downstream resources (such as camping beaches, cultural sites, etc) and their associated values. The LTEMP should go beyond a focus on mass sediment balance and fish.

  • River users care about all that makes Grand Canyon unique, including cultural resources, tribal perspectives and the rich cultural heritage of the Colorado River.
  • Reaching a certain metric for mass sediment balance is not sufficient – The LTEMP needs to focus on whether the sediment adequately benefits, protects, and improves the individual resources along the Colorado River.  A positive mass sediment balance is not very meaningful if that sediment is not where it is most needed.
  • The Endangered Species Act specifies that it is not just the fish that require protection, but also their habitat.

Examine potential alternatives and develop science plans in a broader context, and use that information to improve the quality of scientific and management perspectives.  In his introductory memo to the Technical Work Group, the new chief of GCMRC pointed out that an “expansion in research perspective would provide GCMRC and the GCDAMP the opportunity to place the issues of Colorado River science and management in Grand Canyon in a larger perspective and thereby increase the quality of science support provided to the GCDAMP.” (memo from Jack Schmidt to the TWG, dated 10/18/2011)  He specifically pointed to studies in Cataract Canyon, upstream from Lake Powell on the Colorado River mainstem.  Additionally, the GCMRC Chief noted that the majority of research has been conducted on the mainstem between Glen Canyon Dam and Lake Mead, and that it had been “more than a decade since any ecosystem process level studies have been conducted on humpback chub populations in the Little Colorado River.  Nevertheless, the key to understanding trends in native fish populations might lie in understanding the tributaries better.”  There is much to be learned in other areas that would deepen our understanding of the resources that we are charged with protecting.

No alternative should lock the Glen Canyon Dam Adaptive Management Program into a single flow regime for the next 15 to 20 years.  Flow regime experiments should be run long enough to be thoroughly tested and evaluated, and then adjustments should be made based on the new understanding of the system.  The time frame for flow regime experiments should be determined by the needs of science.

All alterntatives should be developed in a way that reflects not only “Law of the River” release requirements but also proactively manages for outside processes such as the equalization criteria.  An experimental plan that reflects the de facto management requirements of Glen Canyon Dam will be more likely to succeed than one that is developed without considering the bigger picture.

4.2  Suggested Alternatives

Include a Seasonally Adjusted Steady Flows alternative. The original Glen Canyon Dam EIS included a SASF alternative, and it was included again in the matrix of alternatives for the short-lived 2007 Long-Term Experimental Plan EIS effort.  At the close of the Glen Canyon Dam EIS, Grand Canyon River Guides did not support the preferred alternative (MLFF) as we were unconvinced that it would best conserve terrestrial riparian habitat in the canyon, especially in regards to crucial sediment needs.  We did support a rigorous test of the SASF alternative to determine whether releases that closely mimic pre-dam flows would better restore the endangered species and severely eroded beaches.  To date, the four-month duration Low Summer Steady Flow (LSSF) experiment in 2000 “is the longest planned hydrograph that departed from MLFF operations since the Record of Decision in 1996” (Ralston, 2011).  Although the intent of the LSSF was to “mimic predam river discharge patterns by including a high, steady discharge in the spring and a low, steady discharge in the summer,”  the duration was insufficient to determine its effects on the ecosystem.  Further testing of this concept is necessary to assess system response and to test the RPA of the U.S. Fish and Wildlife Service.

Include a Year-round Steady Flow alternative. This is the “best case scenario” presented in the article “Is there Enough Sand? Evaluating the Fate of Grand Canyon Sandbars” (Wright and others, 2008).  It is based on the conclusion that the “optimal intervening dam operation for rebuilding and maintaining sandbars is year-round steady flows, which would export the least amount of sand compared to other potential dam operations.” (USGS Circular 1366, page 143)

Include a “Stewardship Alternative” where the flow regime is designed to best serve the ecological, cultural and recreational resources of the Grand Canyon with no consideration given to the sales of hydropower.  This alternative would be in best alignment with the Grand Canyon Protection Act, which makes no mention of hydropower beyond calling for a report on “economically and technically feasible methods of replacing any power generation that is lost through adoption of long-term operational criteria for Glen Canyon Dam,” and the original purpose for the construction of Glen Canyon Dam, in which power generation was seen as an incidental benefit as referenced previously in our comments.  At this time it is not clear that changes in dam operations alone will be sufficient to protect and improve the river corridor in the Grand Canyon.  However, for the next 15 to 20 years, we should take our very best shot at doing that.

5   Environmental Impacts that should be taken into consideration

English: Rafters pass one of the rapids of the...

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As alternatives are considered, please note that while a positive sediment mass balance for the river corridor in Grand Canyon is necessary to rebuild sandbars, restore campable areas and improve the recreation experience, it is not necessarily a sufficient measure of success.  We need enough sand, but we also need it in the right places.

Climate Change:  The effects of climate change must be taken into account and prepared for in the LTEMP and during the life of the plan.  The Colorado River watershed is likely to become warmer and drier in coming years, which will have a wide range of effects.  It is noteworthy that the water managers who developed the agreement that serves as the cornerstone for the “Law of the River” most likely had water surpluses rather than water deficits in mind.  In fact, “The period from 1905 to 1922, which was used to estimate water production allocated under the Colorado River Compact, had the highest long-term annual flow volume in the 20th century, averaging 16.1 million acre feet at Lees Ferry.” (SCORE Report, Circular 1282, Page 59).  In stark contrast, “By using either actual annual annual flow data or annual flow records adjusted for consumptive uses in the upper basin, it was found that runoff from 2000 through 2004 was the lowest in the period of record (99-110 years).” (SCORE Report, Circular 1282, Page 66)

Tamarisk Leaf Beetle: The tamarisk beetle has recently entered the Grand Canyon, an occurrence that will elicit a watershed-scale change for the river corridor ecosystem in the Grand Canyon.  The NPS is currently poised to proactively and comprehensively prepare for the future through their new Watershed Stewardship Program.  We’ll need to learn what the tamarisk leaf beetle will mean for dam releases and future adaptive management efforts.  Every effort should be made to coordinate with Grand Canyon National Park towards this end.

6  Mitigation

Several concepts should be taken into consideration, studied for an understanding of their risks, rewards and costs, and potentially acted upon during the lifetime of the LTEMP.  These should be considered for all alternatives.

  • Sediment Augmentation.
  • A Temperature Control Device.
  • Beach/campsite work.  Flow regimes with lower variation tend to remove less sediment from the system, but they also encourage plant growth in the riparian zone.  Some beaches lose more campable area to vegetation encroachment than to sediment erosion.  Whatever the cause, loss of camping space on beaches directly affects the recreational experience.
  • Reintroduction of extirpated native species.  Native species of plants and animals are part of the values for which Grand Canyon National Park was initially created.  Reintroduction should be part of a mitigation strategy.

7  Conclusion

English: Ancestral Puebloan granaries high abo...

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Grand Canyon River Guides and its members would like to thank you for the opportunity to provide scoping comment for the development of a Draft Environmental Impact Statement for the Long Term Experimental and Management Plan for Glen Canyon Dam.  We also understand and appreciate the hard, thoughtful work you’ll do in producing a new plan, in keeping with the directive outlined in the Senate committee report regarding the 1978 Redwood Amendment, which stated clearly,

 “The Secretary has an absolute duty, which is not to be compromised, to fulfill the mandate of the

1916 Act to take whatever actions and seek whatever relief as will safeguard the units of the national park system.” (emphasis, ours) (NPS Management Policies, Section 1.4.2, Page 10)

The Grand Canyon is utterly unique —one of the seven natural wonders of the world, a World Heritage Site, and one of the last, best, wild places that belong to us, the American people.  Grand Canyon offers life-changing experiences to those who venture into its depths and down its mighty river, and it even means a great deal to many people who may never have the opportunity to visit it themselves.  It is our profound honor and responsibility to carefully protect Grand Canyon and pass it on to future generations in the best, most pristine condition we possibly can.

Please contact us if you have questions.

Respectfully,

Grand Canyon River Guides, Inc.

Lynn Hamilton          Executive Director

Sam Jansen             Adaptive Management Work Group representative

Jerry Cox                   Technical Work Group representative

Nikki Cooley             President

Latimer Smith                       Vice President

Kim Fawcett              Director

Robert Jenkins         Director

Ariel Neill                   Director

Roger Patterson       Director

Greg Woodall                        Director

Kelly Wagner                        Director

8  References

Grand Canyon, Arizona. The canyon, created by ...

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Boatman’s Quarterly Review, Volume 5 #4, Fall 1992

Bureau of Reclamation, 1995, Operation of Glen Canyon Dam Final Environmental Impact Statement.

Bureau of Reclamation, video of Commissioner Mike Connor: http://www.usbr.gov/river/video.html

Colorado River Storage Project Act of 1956 (Public Law 84-485)

Federal Register, Volume 76, Number 129, July 6, 2011

Gloss, S.P., Lovich, J.E., and Melis, T.S., eds, 2005, The State of the Colorado River Ecosystem in Grand Canyon: A   report of the Grand Canyon Monitoring and Research Center, 1991-2004:U.S. Geological Survey Circular 1282

Glen Canyon Dam Adaptive Management Program, Adaptive Management Work Group (AMWG) meeting minutes, August 24-25, 2011meeting, Phoenix, AZ

Glen Canyon Dam Adaptive Management Program, Strategic Plan, August 17, 2001

Grand Canyon Protection Act of 1992, Title XVIII, Section 1802, Public Law 102-575

Melis, T.S, ed, 2011, Effects of Three High-Flow Experiments on the Colorado River Ecosystem Downstream from Glen Canyon Dam, Arizona: U.S. Geological Survey Circular 1366

Potochnik, A. and Kaplinski, M., A Narrative of Desired Future Resource Conditions for the Colorado River Ecosystem in Grand Canyon, as published in the Boatman’s Quarterly Review, Volume 14 #1, Spring 2001.

Ralston, B.E., 2011, Summary report of responses of key resources to the 2000 Low Steady Summer Flow Experiment, along the Colorado River downstream from Glen Canyon Dam, Arizona: U.S. Geological Survey Open File Report 2011-1220

Schmidt, J.C., memo to the Technical Work Group, 10/18/2011

Topping, D.J., Rubin, D.M, Grams, P.E., Griffiths, R.E., Sabol, T.A., Voichick, N., Tusso, R.B.,Vanaman, K.M., and McDonald, R.R., 2010, Sediment Transport During Three Controlled-Flood Experiments on the Colorado River Downstream from Glen Canyon Dam, with Implications for Eddy-Sandbar Deposition in Grand Canyon National Park, Open File Report 2010-1128

Topping, D.J., Schmidt, J.C., and Vierra, L.E., Jr., 2003, Computation and analysis of the instan­taneous-discharge record for the Colorado River at Lees Ferry, Arizona—May 8, 1921, through September 30, 2000: U.S. Geological Survey Professional Paper 1677, 118 p. (Also available at http://pubs.usgs.gov/pp/pp1677/.)

U.S. Department of Interior, 1996, Record of Decision, Operation of Glen Canyon Dam: Washington, D.C., Office of the Secretary of the Interior.

U.S. Department of the Interior, 2007, Bureau of Reclamation, Upper Colorado Region, Biological Assessment on the Operation of Glen Canyon Dam and Proposed Experimental Flows for the Colorado River below Glen Canyon Dam During the Years 2008-2012.

U.S. Department of the Interior, National Park Service Management Policies, 2006

Walters, C.J., 1986. Adaptive Management of Renewable Resources. McMillan, NewYork, NY, USA.

Webb R.H., Melis, T.S., Valdez, R.A., 2002, Observations of Environmental Change in Grand Canyon, Arizona, U.S. Geological Survey, Water Resources Investigations Report 02-4080, prepared in cooperation with Grand Canyon Monitoring and Research Center, http://wwwpaztcn.wr.usgs.gov/webb_pdf/WRIR4080.pdf

Wegner, D.L., Adaptive Management and Glen Canyon Dam, Glen Canyon Environmental Studies, February 4, 1994

Wright, S.A., Schmidt, J.C., Melis, T.S., Topping, D.J, and Rubin, D.M., 2008, Is there enough sand? Evaluating the fate of Grand Canyon Sandbars: Geological Society of America Today, V18, N8

Wright, S.A., and Grams, P.E., 2010, Evaluation of Water Year 2011 Glen Canyon Dam Flow Release Scenarios on Downstream Sand Storage along the Colorado River in Arizona, U.S. Geological Survey, Open File Report 2010-1133

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GRAND CANYON RIVER GUIDES

GRAND CANYON RIVER GUIDES

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TALKING POINTS FOR THE DEVELOPMENT OF THE

LONG TERM EXPERIMENTAL AND MANAGEMENT PLAN

FOUNDATIONAL ELEMENTS:

  • Define and ensure a substantial role for the Grand Canyon Monitoring and Research Center (GCMRC) within the LTEMP EIS process.
  • GCMRC’s involvement is critical to draw on the body of knowledge that has been gained as the science arm of the Glen Canyon Dam Adaptive Management Program.
  • GCMRC’s involvement is also necessary for the development and evaluation of scientifically credible, well-defined alternatives to best meet program and ecosystem goals.
  • It is paramount that all LTEMP alternatives fully meet the intent of the 1992 Grand Canyon Protection Act, which specifically states, ´The Secretary shall operate Glen Canyon Dam…in such a manner as to protect, mitigate adverse impacts to, and improve the values for which Grand Canyon National Park and Glen Canyon National Recreation Area were established, including, but not limited to natural and cultural resources and visitor use.”
  • Change the Purpose and Need for Action Statement for the LTEMP as follows:
  • Change the language of the Purpose statement to accurately reflect the language and intent of the Grand Canyon Protection Act.
  • Drop the reference to hydropower which is an ancillary benefit of the dam.
  • Desired Future Conditions (DFCs) developed within the GCDAMP with DOI input and approval should be utilized in analyzing the impacts of LTEMP alternatives and applied as a benchmark for defining identified objectives that are scientifically measurable and attainable through dam operations during the life of the Plan.  Related considerations include:

o   The Core Monitoring Program under development by the Grand Canyon Monitoring & Research Center will help track progress towards those desired outcomes.

o   The DFCs must not be static, but rather they must be continually refined as new knowledge is gained, unacceptable impacts are discerned, and subject to a determination of whether the specific DFCs are achievable.

  • The LTEMP must be based on an adaptive ecosystem management approach.
  • This is a dynamic and complex system.  Our learning and adapting/building on what we know must continue indefinitely.
  • Clearly define agency responsibilities, improve communication, create mechanisms for productive information sharing, and eliminate project redundancies between Grand Canyon National Park and the Grand Canyon Monitoring & Research Center.
  • Ensure that the 11 affiliated tribes who live in and around the Grand Canyon and the Colorado River have a substantive role in LTEMP development which continues throughout the LTEMP process, and the life of the plan.  The LTEMP must find a way to successfully incorporate tribal values and knowledge into decision making – a distinct failure of the Adaptive Management Program to date.
  • Towards that end, science must not be the only lens through which we view the Colorado River ecosystem (CRE), its resources, and associated values.  Respectful and thorough tribal consultation must occur at each stage and those cultural and spiritual connections must be woven into the LTEMP and incorporated more effectively into the Glen Canyon Dam Adaptive Management Program.  The tribes view all canyon resources as culturally significant.
  • Funding for monitoring and management of cultural resource should be restored.  In order to comply with the Grand Canyon Protection Act, federal laws, statutes and executive orders, the importance of protecting and preserving these fragile, non-renewable resources and Traditional Cultural Properties for the benefit of future generations must not be minimized.
  • Look to other dam managed rivers, examine their challenges and successes in restoring natural patterns and processes while a dam is still in place and utilize that expertise to inform and strengthen the LTEMP process.
  • Improve the structure and functionality of the Glen Canyon Dam Adaptive Management Program in order to meet GCDAMP mission and goals.  Simply put, we would like to see a much more balanced GCDAMP stakeholder group that has the ability and willingness to act adaptively on what is learned.

RESOURCE ISSUES:Overlook over the Colorado River in the Grand ...

  • Maintain or improve the quality of recreational resource for users of the Colorado River, for generations to come.
  • Consider carrying capacity and campability — design flows and flow experiments that will ensure sufficient number, size and distribution of camping beaches to accommodate the level of use delineated by the Colorado River Management Plan and minimize crowding and congestion.
  • Focus on benefiting, protecting and preserving all of the downstream resources (such as camping beaches, cultural sites, etc…) and their associated values– the LTEMP should go beyond a focus on mass sediment balance and fish.
  • River users care about ALL that makes Grand Canyon unique, including cultural resources, tribal perspectives and the rich cultural heritage of the Colorado River.
  • Reaching a certain metric for mass sediment balance is not sufficient – The LTEMP needs to focus on whether the sediment adequately protects and preserves the individual resources along the Colorado River.
  • The Endangered Species Act specifies that it is not just the fish that require protection, but also their habitat.
  • Examine the role of time and climate change in the system.
  • Can we build up a Humpback chub population (above survival levels) during drought low flow warm water years sufficient to mitigate impacts from years with high snow levels in the Rockies and high release/cold water flows from Glen Canyon Dam?

English:FLOW SUGGESTIONS:

  • Beach Habitat Building Flows should be a well-defined, key component of LTEMP alternatives.
  • Finalize the High Flow Experimental Protocol Environmental Assessment and incorporate it into the design of all LTEMP alternatives.
  • Design intervening flows (flows immediately after, and between high flow experiments) that maximize sediment retention.
  • Address the preservation of sand deposits by designing post-High Flow Experiment hydrographs that optimize ecosystem goals (i.e. sediment retention) to the greatest extent possible.
  • Include an LTEMP alternative to test steady flows.
  • Consider an alternative that includes a seasonally adjusted steady flow alternative that includes sediment triggered Beach Habitat Building Flows, and based on the closest approximation of the pre-dam hydrograph.
  • We need a scientifically credible, well-designed steady flow experiment of sufficient longevity to produce a biological signal (more than two months in the fall) that is followed by a full synthesis of impacts to biological, physical, social, economic and cultural resources.
  • Consider a minimum flow of no less than 8,000 cfs to ensure navigability and safety for all boaters.
  • Test the “best case scenario” presented in the article, “Is there enough sand? Evaluating the fate of Grand Canyon sandbars” as proposed by USGS scientists
  •  Design an alternative based on the best chance of viability for rebuilding and maintaining sandbars.

Do Something

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