Los Angeles Times

Federal flood control managers plan to unleash millions of cubic feet of water from behind Glen Canyon Dam to “flush” the huge canyon bottom with a simulated springtime flood this week, but National Park Service officials who oversee the natural wonder are worried.

Water releases meant to renew the river’s bottom are ill-timed and serve hydropower firms, park officials say.

By Janet Wilson, Los Angeles Times Staff Writer
March 4, 2008

The Grand Canyon is about to take a bath, and National Park Service officials who oversee the natural wonder are worried.

Federal flood control managers, led by Interior Secretary Dirk Kempthorne, this week plan to unleash millions of cubic feet of water from behind Glen Canyon Dam to “flush” the huge canyon bottom with a simulated springtime flood.

Bureau of Reclamation and U.S. Geological Survey specialists say the 60-hour “blowout,” followed by a series of smaller flows this fall, are needed to scour accumulated sand off the Colorado River bottom, then gradually restore sandy beaches and side pools for endangered species and campers.

The flows begin today, and a massive release is set for Wednesday in a media event with Kempthorne.

At its peak volume, 41,500 cubic feet per second of water will burst from tubes at the bottom of the dam, temporarily reducing flows to hydroelectric turbines. The experiment will not affect power or water supplies to customers, officials said.

National park officials said that 10 years of research at a cost of $80 million had shown that the flooding as planned could irreparably harm the national park’s ecology and resources.

Grand Canyon National Park Supt. Steve Martin said he was given a day to formulate comments to a cursory environmental assessment of the project. In those comments, he wrote that statements by the Bureau of Reclamation used to justify the flows’ timing were “unsubstantiated.” Far from restoring crucial sand banks and other areas, the flows could destroy habitat, Martin said.

One flood was not enough, Martin said Monday. Holding off follow-up flows for months would leave endangered humpback chub fish, sandbars used by river rafting trips, and archaeological treasures at river’s edge diminished “almost to the point of no return,” he said.

Martin suggested the timing of the flows served hydroelectric power producers who need peak production during hot summer months.

“The best time to get the most money for your hydropower is during peak energy demands, which is generally daytime hours and generally in the summer,” he said.

The U.S. Geological Survey acknowledged the floods had been timed in part to maximize power generation during peak demand.

Martin said he and his staff had been “assured” this week that they would be allowed to discuss additional releases, including the possibility of flooding during summer months.

Erosion has been a major problem since Glen Canyon was dammed for hydroelectric power and water storage in the 1960s. Congress passed the Grand Canyon Preservation Act in 1992 to address ecological problems caused by holding back massive amounts of sediment-laden spring runoff.

The first flush of the Grand Canyon, in 1996, was a mixed success at best, scientists concluded, with some spots more eroded than they were before.

A second flush, in 2004, was slightly more successful, restoring sand and sediment levels about 20 miles downstream of the dam.

“But the river is 250 miles long just in the national park,” said John Hamill, chief of the Grand Canyon monitoring and research center for the geological survey, who has been working with the Bureau of Reclamation to plan the floods. Hamill said changes had been made in the draft document to try to address some of the park service’s concerns. But he said flows would go forward as planned.

“My understanding is the proposal is to still do September and October [releases] for the next five years,” he said. He said the fish would still be helped by flows at that time, and agreed that power-production costs were a prime reason for the timing.

“There’s a fairly significant economic cost to stabilize the flows,” he said. “The peak electrical demand is in the summer . . . and subsides in September and October.”

He said that although park service officials were understandably focused on park issues, the reclamation bureau had to take into account the full picture of dam operation.

Martin said that he did not fault planners for wanting to minimize power losses, and that the dam served valuable multiple roles.

But he said the best, most current scientific data should be used to determine releases.

In a statement, Public Employees for Environmental Responsibility condemned the flush as a “staged canyon greenwash” meant to attract television cameras while following a flood timeline that would “magnify the benefits for power production at the expense of environmental benefits.”

“The Bush administration is trying to extend its control through the term of its successor — a dead man’s hand throttling the Colorado River management,” said Jeff Ruch, executive director of the environmental group.

janet.wilson@latimes.com

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Upper Colorado Regional Office

Media Contact: Doug Hendrix Dennis Kubly

(801) 524-3837 (801) 524-3715

Release Date: February 29, 2008

Reclamation Releases Final EA and FONSI Authorizing High-Flow and Steady Flow Experiments on the Colorado River

Salt Lake City – The Bureau of Reclamation today released a final environmental assessment (FEA) and a Finding of No Significant Impact (FONSI) that authorizes the initiation of an early-March 2008 high-flow test and fall steady flow experiment from Glen Canyon Dam downstream through the Grand Canyon. The FEA provides an evaluation of the environmental effects of the proposed action and no action, in compliance with the National Environmental Policy Act of 1969.

The FEA evaluates the impact of the proposed experimental flows on a wide range of environmental and socioeconomic resources. Following release of these documents, the high-flow experiment and associated research activities will be undertaken on March 4th cooperatively by scientists and resource managers from Interior’s U.S. Geological Survey (USGS), Reclamation, National Park Service, U.S. Fish and Wildlife Service, and Bureau of Indian Affairs.

The 2008 high flow test will be similar to the previous high flow experiments conducted by the joint Interior agencies in 2004, but the amount of sediment available for the 2008 experiment is considerably larger. Based on the previous experiments, scientists have concluded that more sand is needed to rebuild sandbars throughout the 277-mile reach of Grand Canyon National Park than was available in 1996 or 2004. Currently, sand supplies in the river are at a 10-year high with a volume about three times greater than in 2004 due to tributary inflows below the dam over the past 16 months.

During the high-flow experiment, Reclamation will release water through Glen Canyon Dam’s powerplant and bypass tubes to a maximum amount of approximately 41,500 cubic feet per second (cfs) for about 60 hours. Current operational plans call for the experimental flows to begin increasing in the evening on March 4th, with powerplant bypass flows to begin on March 5th.

From February 8-22, 2008, Reclamation solicited public comments on the environmental assessment. The final environmental assessment and FONSI conclude that implementation of the preferred alternative – the March 2008 high-flow test and fall steady flow experiment from Glen Canyon Dam – would have no significant impacts on the quality of the human environment or the natural resources below the dam.

The FEA and FONSI are available for review at: www.usbr.gov/uc/envdocs/ea/gc/2008hfe/index.html

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http://www.peer.org/news/news_id.php?row_id=999

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Flood may help revive a river

River’s 3rd planned flood may aid fish, environment

Shaun McKinnon
The Arizona Republic
Feb. 25, 2008 12:00 AM

For 60 hours early next month, the Colorado River will reclaim some of its former glory, swelling with floodwaters that will scour and reshape miles of sandy banks on the floor of the Grand Canyon, all in the service of a 3.5-million-year-old fish.

What scientists and environmentalists want to see is what will happen to the fish - and the canyon - when the gates close at Glen Canyon Dam and the staged flood recedes.

This is the third such experiment along the river in a dozen years, and it could end as the most controversial amid questions about whether the government has shirked its obligations to protect the canyon’s natural resources.

At issue is how to manage a structure that stores water and provides electrical power for millions of people across the West, yet has also damaged a wondrous, complex ecosystem.

Federal officials insist they have progressed with long-term plans to offset the effects of the dam on the river and the Grand Canyon. The endangered humpback chub, the fish at the center of much of the dispute, has recovered some of its lost numbers since the last flood. Scientists also think they better understand when to trigger future floods.

But environmental groups argue that the upcoming flood again delays long-term changes to the river’s management, further jeopardizing the canyon’s health. They want federal officials to permanently alter the dam’s operation instead of repeating the same test, adopting a seasonally adjusted plan that better mimics nature.

Even some of the government scientists participating in the experiment seem impatient with the continued tests.

“At some point we’re going to have to draw a line in the sand and say this is the best way to manage the dam and manage resources in the Grand Canyon,” said Martha Hahn, science center director at Grand Canyon National Park. “We can’t continue to go on and on just researching. We have to make a decision. We really are losing valuable resources.”

Floods to help the fish

Glen Canyon Dam, completed in 1963, forever changed the lower Colorado River, transforming it from a warm, muddy, unpredictable force of nature into a cooler, clearer, tightly controlled water-delivery system.

Without spring floods to flush the system and help rebuild beaches and fish habitat, native species suffered even as non-native invaders, such as trout and salt cedar, thrived. The shift helped speed the extinction of four fish species and push two others, including the chub, near the edge.

In 1992, Congress passed the Grand Canyon Protection Act, which ordered the Interior Department to manage the dam in a way that better protected resources. Four years later, the government staged the first artificial flood, opening the dam’s bypass tubes for several days in a mostly unsuccessful attempt to replicate natural cycles.

A second test in 2004, while still underwhelming, taught scientists the importance of sand and sediment.

The dam traps almost all the sediment that once flowed down the river, which is why beaches and habitats have eroded. A good monsoon season can wash significant quantities of sand down the Paria and Little Colorado rivers, which empty into the big Colorado below the dam.

“There’s been a good sand season, if you want to call it that, since about 2006, and we’re thinking there’s a lot more sand in the system than there has been in past experiments,” said John Hamill, chief of the Grand Canyon Monitoring and Research Center, part of the U.S. Geological Survey.

Tests, operations at odds

What scientists hope to see are more backwater pools for young humpback chub, which need the calmer refuges off the main river to develop and grow. The chub population dwindled during the 1990s, rebounding slightly in recent years as lower levels at Lake Powell warmed water temperatures.

“Our ultimate purpose is to learn whether or not this is a viable strategy for creating sandbars and habitats for native fish,” Hamill said.

Environmental groups say the question has been answered, and they accuse the government of bowing to water users and hydropower interests, which have opposed long-term changes to the way water is released from the dam.

Under current operations, the water fluctuates during the summer as power demand peaks and ebbs. The uneven flows are thought to disrupt fish life cycles.

“They’re trading off maximum hydropower revenue for diminished Grand Canyon resources,” said Nikolai Lash, senior program director for the Grand Canyon Trust, a Flagstaff-based group that has long fought the government over its management of the dam.

Lash said the March flood was hastily planned after the Trust sued the government last year for failing to protect the river. The experiment was purposely designed as a single test, he said, even though most scientists think floods must occur regularly.

“They’re trying to make it appear that they’re doing something beneficial when they’re just doing it for appearances,” he said. “It’s being manipulated to be a ‘one and done,’ even though we know that doesn’t work.”

What environmental groups want is a long-term plan to stage floods as often as conditions allow - annually, if possible - and eliminate the extreme fluctuations in water releases from the dam during the summer and fall.

Hamill said scientists want to quantify how many backwater habitats the flood creates and how long they provide shelter for the chub.

Between floods, scientists have tried to help native fish in other ways, such as removing thousands of trout from the river near the confluence of the Little Colorado, the canyon’s only remaining chub spawning ground.

“I think we know just doing one of these every five or six years won’t get the job done in the long run,” Hamill said. “What we don’t know is even if we did it regularly whether it would be a viable strategy for conserving habitat.”

The test will also examine the effects on the river’s beaches, which provide habitat for other animals as well as canyon tourists.

A regular series of floods could help capture sand from the tributaries before the river washes it into Lake Mead, said Hahn, the Grand Canyon’s science center director. Already, huge sandbars line the riverbanks as it reaches the lake.

“I really believe the science is there to tell us what we need,” Hahn said. “It’s a matter of when are we going to get to the point we will integrate this knowledge and incorporate it into a management decision.”

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Tuesday, February 12, 2008
The multiple federal agencies planning a large, five-day flood in the Grand Canyon in hopes of washing more sand into the Colorado River ecosystem have prepared an analysis of potential costs and benefits.

The experiment is expected to cost about $8 million in research costs and lost power, as the water released from the dam will bypass power turbines. The flood is expected to help build beaches in the river and potentially aid endangered humpback chub overall, by improving the backwaters they inhabit, according to an environmental analysis by the Bureau of Reclamation. Most of the sand that used to flow through the Colorado River in the Grand Canyon is now trapped upstream of Glen Canyon Dam.

It’s also anticipated some of the young endangered chub may be washed away in the flood and killed, according to an opinion from the U.S. Fish and Wildlife Service.

Overall, the same amount of water is typically released from the Glen Canyon Dam year to year, due to interstate agreements regarding the Colorado River system.

But this proposed experiment would change when in the year some of the water will be released, which leads to reduced ability to generate power during the hottest and coldest times of the year.

The March 4-9 flood has yet to receive final approval.

To read more, see www.usbr.gov/uc/envdocs/ea/gc/2008hfe/GCDexprelEA.pdf.

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Comments should be submitted to:

GCexpReleases@uc.usbr.gov.

The Environmental Assessment is available for public review on the Internet by following the link at www.usbr.gov/uc/envdocs/ea/gc/2008hfe/index.html

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The Department of the Interior has proposed conducting a high-flow experiment from Glen Canyon Dam. The proposed experiment is tentatively scheduled to begin on the evening of March 4, when the water will begin ramping up. The water will continue ramping up to 42,000-CFS on March 6. It will stay at this level for 60 hours and begin the down-ramp on the afternoon of March 8. Normal dam operations will begin on March 9. The stated purpose of this experiment is to rebuild beaches in the Grand Canyon, establish back waters that native fish might or might not use, and protect archeological sites in the Grand Canyon.

Despite the fact that I and many others consider this experiment to be a staged political event and a total and complete waste of time, money, and resources, we do not feel that this experiment will have any long lasting negative impacts on the Lees Ferry trout fishery. We have lived through two previous high-flow experiments and we expect everything to return to normal shortly after the high water event. To put this water flow in historical perspective, I first started guiding here at Lees Ferry in 1983 and the water releases from Glen canyon dam were 35,000 to 45,000-cfs every day for more than a year.

Lee Ferry Anglers is not scheduling any fishing trips during the high flows but we will return to normal operations on March 10. Immediately following the last 2 experimental flows, the fish were eager to eat and our customers experienced fishing success that was “off the charts” due to the vast amount of food (scuds and worms) that is stirred up in the higher flow. We expect the fish to move out of normal spots and congregate in areas where this food is deposited, such as near sand beaches, around corners, and back-eddies. After a few days, the trout will begin moving back into the main channels and riffles to resume normal feeding behavior.

My rational for opposing this type of experiment is based upon my 25 years experience on the Colorado River, a simple grasp of logic and common sense. Since the construction of Glen Canyon dam, all the sediment that is normally transported in the Colorado River is now collected in Lake Powell. During these high releases there is no sediment transported through the dam, the high flows are clear and sediment free. The only sediment that currently accumulates in the Colorado River below Glen Canyon dam is transported to the river via side channels (flash floods) and 2 perennial streams (Paria and Little Colorado rivers). The sediment load of the post-dam Colorado River is a fraction of a fraction of the pre-dam river. All of the sediment that is going to be used to rebuild beaches is transported out of the river. The last statistic I saw was that 97% of this sediment is transported down river, while only 3% is deposited along the river (not all of it on beaches or where the sand is wanted or needed). Then gravity takes effect… the wind blows, the river rises and falls, a few rain storms and the beaches erode back into the river. A couple of years after the experiment the beaches are back where they were pre-experiment and Lake Mead is filling with sand quicker than it would without the experimental flow.

A local guide described it best when he said “using high water flows to build beaches is like using an atomic bomb to dig a hole,” you’ll certainly get a hole dug but at what other expense! Many believe that if you want beaches that will last in the Grand Canyon, there is technology available to achieve this goal using nondestructive methods. As for the two other goals of this experiment, creating back-waters for native fish and protection for archeological sites, there is no science that demonstrates that native fish use back-waters created by these high flows…Period. Archeological site protection from blowing sand??? Whatever happened to professional archeological stabilization or a shovel and wheel barrow to place the sand where you want and need it??? There are those that will say that this is the Grand Canyon National Park and this type of corrective measure is not a “natural process.” I would like to remind everyone that when a trail in the Grand Canyon washes out, they use modern engineering methods and equipment to repair it, same with the Grand Canyon National Park infrastructure.

Earlier I called this experiment a staged political event. The Adaptive Management Workgroup (AMWG) is made up of numerous stakeholders who make river management recommendations to the Secretary of the Interior. A few months back the AMWG voted 14 to 2 against conducting a high-flow experiment. Shortly afterward, news came from Washington DC that everyone should plan for an experiment. Where did this come from? Could it have something to do with, or simply be a coincidence, that this is an election year and someone wants to look like they are being environmentally proactive?

Piggy backed onto the high flow experiment is a proposed 5-year series of low steady flow experiments, during the months of September and October. This proposal is based upon a desire to benefit the Hump Back Chub (HBC), an endangered species that lives in the Little Colorado River. The proposal is likely a result of a lawsuit recently filed by the Grand Canyon Trust against the Bureau of Reclamation (BOR) calling for year-around steady flows. The electricity generated by Glen Canyon Dam supplies electrical needs all over the western United States. In a steady flow environment the ability of the BOR and Glen Canyon Dam to produce electricity will be dramatically reduced. If this steady flow experiment is enacted, there will be less clean and inexpensive energy available to the western populace. I’m sure that there is alternative mean of producing replacement electricity through additional coal fired generation, but given the alternative of allowing Glen Canyon Dam to continue producing clean power or replacing it with other polluting methods is a no brainer.

What can you do? This is a proposed experiment but you can expect it to happen, come hell or high water (I couldn’t resist). The Secretary of the Interior is asking for public comments, the comment period is from Feb. 8-23. I urge each of you to write a letter expressing your concerns regarding the proposed experiment…and pass the word to all your friends to write a letter too.

My letter is going to ask the Secretary of the Interior to:

1: Not conduct this experiment and instead investigate nondestructive methods of building beaches in the Grand Canyon and to use common sense and sound judgment in dealing with this and all future planned experiments on the Colorado River.

2: To remove the proposal for low steady flows in September and October from the experiment. I support clean energy and encourage the use of power generation from Glen Canyon Dam.

3: Be sure to state that support the NO ACTION ALTERNATIVE

Tags: Public Comment Articles // 1 Comment »

Mark Steffen 02-12-08

Federation of Fly Fishers/Northern Arizona Flycasters (FFF/NAF)

Regarding: Reclamation Environmental Assessment, Experimental releases from Glen Canyon Dam, Arizona, 2008 through 2012.

I STRONGLY OPPOSE THE RECLAMATION PROPOSED EXPERIMENTS, THE HIGH TEST FLOW AND THE FALL STEADY FLOWS!

I STRONGLY SUPPORT THE “NO ACTION ALTERNATIVE”, and offer the following comments:

It is unfortunate that Reclamation and the Department of the Interior, including the National Park Service (NPS) and the US Fish and Wildlife Service (FWS) have chosen to force these experiments on the public with a complete lack of consideration and in defiance of five years of collaboration by Stakeholders in the Glen Canyon Dam Adaptive Management Program (GCDAMP). Stakeholders including FFF/NAF worked hard to design appropriate flow experiments, only to be forced now to accept these Bureau of Reclamation experiments which were repeatedly voted down by GCDAMP Stakeholders.

Grand Canyon Monitoring and Research Center (GCMRC) scientists, Reclamation bureaucrats, the NPS, the FWS and the Grand Canyon Trust wear rose colored glasses and assume that high flows and steady flows will be a panacea for all resources downstream of Glen Canyon Dam. This is an outrageously fallacious, dangerous and irresponsible assumption that ignores the negative consequences of all past grandiose, extreme flow experiments that have had disastrous impacts on the aquatic ecosystem in a fanatical, zealous and blind obsession to manipulate sand in the Grand Canyon.

The comment period of 14 days is grossly inadequate and irresponsible for experiments this extreme, this excessive, this expensive and this controversial. Notification of the public for comments was extremely inadequate. Reclamation in an EA press release seeking comments, did not even give instructions on how the public should submit comments.

IMPACTS TO FISH AND FISH FOOD SUPPLIES:

1) The Little Colorado River (LCR) flooded in Late January and early February 2008 with a peak flow of 4,400 cfs. This flooding above the base flow of 200cfs certainly flushed many if not most of the young humpback chubs (HBC) born in 2007 in the LCR into the main Colorado River. The USFWS documented this during flooding of the LCR in January and March 2005 (2005 LCR spring trip report Van Haverbeke). The presence of huge numbers of the 2007 HBC LCR year class in the Colorado River should be considered before implementation of a flood flow that would be 3 times the usual March flow. Independent “Science Advisors” have cautioned against doing a test flood shortly after serious flooding from the LCR (Barron, Garret etal 2008). Nonetheless, GCMRC predicts impacts to HBC will be “minimal” (GCMRC 2008).

2) Reclamation admits in the Biological Assessment that the “high flow test” will have negative consequences to humpback chubs. Page 90, “The proposed action is likely to adversely affect humpback chubs” (Reclamation 12-2007).

3) GCMRC does not have the capability to document high test flow affects or steady flow affects on aquatic plants, aquatic insects and food supplies for fish. GCMRC does not have an Aquatic Food Base (AFB) Monitoring program. GCMRC has a “research program” intended to eventually lead to an AFB monitoring program sometime in the far distant future. GCMRC has been repeatedly criticized by independent scientist reviews for a lack of “integration” of physical and biological studies and having too much focus on studying sand and camping beaches.

4) This Reclamation EA misrepresents the concerns of Lees Ferry business owners and fishing guides (EA page 12). Concerns were not just for negative economic impacts and negative public perceptions. A main concern was the damage to aquatic plants and aquatic insects that did occur during the 2004 high flow test. That damage was not documented by GCMRC because they did not have and they still do not have an Aquatic Food Base Monitoring program. Anglers and Lees ferry business owners recommended a high test experiment be conducted in January or July, high water months when the high flow would be relatively less drastic; impacts to the aquatic ecosystem might be less severe and the test would not be in the prime fishing season of early February to late June. Also suggested but ignored in the EA, was stocking trout at Lees Ferry to mitigate possible trout impacts from the high flow and to change the current public perception that trout cannot be stocked at Lees ferry anymore (Steffen 2007). Grand Canyon River guides representative John O Brian stated at a TWG meeting that rafters would not oppose a high flow test in July, that they would enjoy rafting the high water.

5) The No Action Alternative (modified low fluctuating flows) and the cold water released from Glen Canyon Dam have been effective at protecting the Little Colorado River (the spring fed and all year round warm water home of HBC in Grand Canyon) from invasion of warm water non-native fish (channel catfish, small mouth bass, stripped bass etc.) from Lake Mead. This current Reclamation fall steady flow proposal that “might” benefit juvenile HBC by warming backwaters in the Colorado River, also will invite invasion of warm water non-native predacious fish from Lake Mead. These warm water non-native fish would be likely to enter the LCR and could exterminate all remaining HBC in the Grand Canyon. The past four years of government trout killing in the Colorado River has opened a niche and led to increases of existing non-native warm water fish (bullhead catfish and carp) in the Grand Canyon and perhaps in the LCR. Trout in the Colorado River almost never enter the LCR. After 1950 but prior to Glen Canyon Dam, highly predacious catfish were the dominant fish in Grand Canyon (Webb, Melis and Valdez, 2002) and would likely have led to extermination of HBC in Grand Canyon including the LCR. Cold water from Glen Canyon Dam and the No Action Alternative have protected and saved HBC in the Little Colorado River in Grand Canyon. The current Reclamation proposed steady flow experiment creates new threats to the Grand Canyon Little Colorado River HBC population that should not be acceptable.

HIGH FLOW TEST TIMING, MAGNITUDE AND DURATION:

6) There is no need for “expediting” a high flow test (page 6 EA). GCMRC has stated that the current enriched sediment condition will persist in the river for several years (Steffen 2007). A high flow test during a low water month is inappropriate. Damage to the aquatic ecosystem would be much less if the test occurred during a high water month such as January or July.

7) Cladophora (aquatic algae) grows intensely in spring and fall with sharp decreases in mid-summer. Increased growth of Cladophora in spring coincided with rising base flow. (Pinney 1991)

GCMRC has not justified a need for the test flow duration as excessive as the 60 hours in the current Reclamation proposal. The GCMRC science plan does not consider the impact a 60 hour duration 41,000 cfs flow relative to the normal high flow of 13,000cfs, will have on the Aquatic Food Base (GCMRC 2007).

ADVICE IGNORED BY RECLAMATION:

9) The Federation of Fly Fishers and the Northern Arizona Flycasters are listed in the EA as having been consulted. ALL advice give by these organizations was ignored!

10) The Glen Canyon Dam Adaptive Management Work Group (AMWG) has not recommended a high flow test or steady flows. The Glen Canyon Dam Adaptive Management Technical Work Group (TWG) voted not to recommend an identical high flow test proposed by the Grand Canyon Trust in November 2007. The AMWG and TWG have repeatedly voted not to recommend any periods of steady flows.

11) In this EA, Reclamation continues to ignore advice from AMWG and TWG including AFB experiments proposed by WAPA and the Federation of Fly Fishers (FFF) to determine AFB impacts from fluctuating flows and steady flows. Experiments proposed by WAPA and FFF included brief but significant daily flow fluctuations that would attenuate to steady flows 60 miles downstream by the Little Colorado River and chub locations.

12) The expense of this test is grossly excessive. A total cost of twelve million dollars for benefits that will be minimal, maybe only to some camping beaches and to scientist’s resumes (academic reports, graduate degree dissertations etc.).

BACKWATERS:

13) Backwaters are less than 5% of shoreline according to GCMRC data. Backwaters could be destroyed by a high flow. Vegetated shorelines are more important for chubs and may also be destroyed by high flow.

14) IF backwaters are improved even temporarily for chubs, the timing of the test in March will not benefit chubs. A test in July would produce the hypothetical improvement when chubs are actually flushed from the LCR, in July and August by monsoon rains.

STEADY FLOW ISSUES:

15) Steady flows in October will lead to colder, not warmer water temperatures in backwater areas, due to low air temperatures in October, negating and reversing the intent of creating warm backwaters. Fluctuating flows maintain a relatively warm temperature of 50 degrees Fahrenheit in backwater areas even in winter when steady flows would result in very cold shoreline water temperatures.

16) Steady flows would exacerbate the effect of low dissolved oxygen that can occur in fall. Fluctuations increase dissolved oxygen in dam water releases.

17) Reclamation and this EA irresponsibly disregard evidence of benefits and even dependence of aquatic plants, aquatic insects and fish, on daily fluctuating flows. The Colorado River Aquatic Ecosystem (CRE) has evolved, adapted and become dependent on daily flow fluctuations. The CRE is now essentially a “tidal” or “estuarial” ecosystem. Steady flows would be extremely disruptive and analogous to government bureaucrats proposing that some particular ocean organism would benefit if the government could only stop the ocean tides!

18) Cessation of fluctuating flows would likely reduce drifting simmulids, gammarus (fresh water shrimp) and chironomids, important food sources for HBC. Cladophora (aquatic algae) drift was significantly higher during upramp and downramp than during steady flows. Gammarus composed the bulk of HBC diet by volume, although simmulids were the most common by number. (Valdez 1995)

19) Fluctuating flows increase the availability of food, increasing the dislodgement and movement of algae and invertebrates. Invertebrates in trout stomachs increased during periods of fluctuating flow. Anglers favor fluctuating flows because they believe rising water stimulates feeding by fish. Trout growth rates could decline due to an absence of fluctuating flows. (GCES final report introduction January 1988)

20) Fluctuating flows can lead to increased diversity of diatoms that produce mucilage which protects Cladophora against effects of dessication from dewatering during fluctuating flows. (Peterson 1984)

21) Cladophora is conditioned evolutionarily for the submergence-emergence of fluctuating flows in regulated rivers. (Pinney 1991)

22) Cladophora composed 77% of HBC stomach contents in the 1980’s, chironomids and terrestrial insects only 10%. (Kubly 1990)

23) Cladophora was heavily exploited by carp, trout, channel catfish, flannelmouth and bluehead suckers. Oil droplets from diatoms attached to Cladophora provide a major energy source for fish. (Carothers and Minkley 1981)

24) Cladophora and associated diatoms are the foundation of the aquatic food web and are utilized by both Gammarus and Rainbow Trout in Glen Canyon. (Pinney1991)

25) Diatoms associated with Cladophora provide 95% of Gammarus diet at Lees Ferry. Gammarus grazed on diatoms without ingesting the host Cladophora. (Pinney 1991)

26) Diatoms associated with Cladophora appear to be an important food source for Trout below Glen Canyon Dam. Trout derive nutritional benefit from diatom lipids and achieve increased digestive efficiency from a full stomach of indigestible Cladophora. . (Liebfried 1988)

27) Gammarus show a preference for ingesting diatoms that grow best on Cladophora during fluctuating flows versus diatoms that grow under steady flows. Achnanthes affinis-minutissima and Rhoicosphenia curvata versus Cocconeis pediculus. Gammarus had difficulty removing and ingesting the diatom pediculus from cladophora. Pediculus increased with steady flows and decreased with fluctuating flows. Ingestion of A. affinis was high during fluctuating flows and affinis exhibits “hitch hiking” ability on drifting Cladophora. (Pinney 1991)

28) Gammarus become mobile during fluctuating flows. (Pinney 1991)

29) Stomachs of HBC from the Colorado River contained more food than HBC from the Little Colorado River. (Minckley 1996)

Literature cited:

Barron, Dale, Fowler, Gunderson, Kitchell, Robertson, Tyus, Wohl and Garrett.

1-13-2008. Review of the “Science Plan for Potential 2008 Experimental High Flow at Glen Canyon Dam”.

GCMRC, 12-27-2007. Science Plan for Potential 2008 Experimental High Flow at Glen Canyon Dam.

GCMRC, 1-13-2008. GCMRC responses to SA comments on Science Plan for Potential 2008 Experimental High Flow.

Kubly, 1990.The endangered humpback chub in Arizona.

Liebfried and Blinn, 1986 The effects of steady versus fluctuating flow below Glen Canyon Dam.GCES report B-8

Liebfried,1988. The utilization of Cladophora and diatoms as a food resource by Trout in the Colorado river below Glen Canyon Dam.

Minckley, 1996. Observations on the biology of the HBC in the CR basin 1908-1990.

Peterson, 1984. Benthic diatom community dynamics in the Colorado river: Interactive effects of periodic dessication.

Pinney, 1991. The response of Cladophora and associated diatoms to regulated flow, and the diet of Gammarus, in the tailwaters of glen canyon Dam.

Reclamation, 12-2007. Biological Assessment on the Operation of Glen Canyon Dam and Proposed Experimental Flows for the Colorado River Below Glen Canyon Dam During the Years 2008-20012.

Steffen, 12-02-2007. Report on Lees Ferry meeting about 2008 Beach-habitat-building-flow.

Valdez, 1995 Life History and Ecology of the Humpback Chub in the Colorado River, Grand Canyon, Arizona.

Van Haverbeke, USFWS, May 2005. Monitoring of Native Fishes of the Little Colorado River Ecosystem in Grand Canyon. Spring 2005 trip report.

Webb, Melis and Valdez, 2002. Observations of Environmental Change in Grand Canyon, Arizona.

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Trout and Native Fish Conflicts

Perceived conflicts between Trout and native fish in Arizona have led to real conflicts between Trout, government agencies and environmental groups. These conflicts are shaping up to be a battle ground between sportsmen and science and government… Powerful and well-funded environmental groups are leading the charge against anything “non-native” that swims in western waterways. Through the court system and activism, these groups are shaping policy that will have a long ranging affect on sport fishing as we know it today.

In the vision of Teddy Roosevelt, the National Park Service stocked Trout in Colorado River Tributary creeks in the Grand Canyon from 1923 until 1964. The cold side streams were a perfect habitat for these non-native sport fish and the Trout thrived. In 1963, the gates to Glen Canyon Dam were closed and the Colorado River changed from a silt laden, warm river, to a cold and clear stream. Most of the native fish that lived in this stretch could not handle the new conditions. Meanwhile, Rainbow Trout were stocked directly below the dam at Lees Ferry. Anglers from around the world soon discovered the tremendous angling opportunity that this river offered and flocked to Lees Ferry. Local infrastructure grew to accommodate the millions of dollars that these anglers brought to our area to spend…guide services, lodges, restaurants, and retail shops thrived on the sport fishing dollar. These dollars have been especially precious to the local economy, which includes the northwestern section of the Navajo Reservation. According to The National Geographic Society, this area has the lowest per-capita income of any area in the United States.

A few years back, the political winds shifted and the fish that no one had seen in years became the hero and Trout became the villain. Environmental groups and scientists had begun to speculate that the reason these native fish were disappearing from the Colorado River was that those evil Trout were eating all the native fish. Forget for a moment that the native habitat had been radically altered by the dam, that there was now clear cold water, that the food chain had changed…it just has to be those pesky and voracious Trout that were eating and out competing the native fish! The scientists even had produced proof that this was the case…they were killing Trout and sampling their stomachs and found fish in the stomachs of Rainbow Trout. When we pressed for specifics, we were told that of the thousands of Rainbow Trout killed, less than 1% (LESS THAN ONE PERCENT!!!) of the Rainbow Trout had fish (unidentifiable but probably suckers and not endangered fish) in their stomachs. Fifteen percent of the Brown Trout killed (less than 500) had fish in their stomachs. We concede that Brown Trout can be predatory, but to have Rainbow Trout lumped together and made a public enemy is irresponsible.

The Trout have been accused (without proof) of eating the 500,000 juvenile native Humpback Chubs a year that are flushed by monsoon rains out of the Little Colorado River into the Grand Canyon. Starting in 2003, six times a year, for four years, Trout were killed by the Grand Canyon Monitoring and Research Center (GCMRC) scientists, in a 17 mile section of the Colorado River in the Grand Canyon approximately 60 miles downstream of Lees Ferry at a cost of 4 Million Dollars. Predictions in 2002 were that one million trout lived in the Grand Canyon and that 70,000 Trout lived in the 17 mile stretch by the LCR. They thought there must be way too many Trout and they must be eating or crowding out the native fish. The GCMRC claimed a 90% killing effectiveness, yet in four years and 24 trips they killed just 20,000 Trout. Obviously there were many fewer Trout in the Grand Canyon than GCMRC thought…somebody screwed up and overestimated the trout population by a factor of 7 times. In the mean time, millions of dollars were spent seeking a solution to a problem that did not exist in the first place. The Trout killing experiment was for four years and now will be “shut off” for four years. The scientists from GCMRC have said they would like to keep killing Trout to “continue collecting data”.

In 1992 the U.S. Congress passed the “Grand Canyon Protection Act” and created the Glen Canyon Dam Adaptive Management Work Group (AMWG). The AMWG is 26 “stakeholders” including state and federal government agencies, Native American Tribes, environmental groups and recreation groups. The Federation of Fly Fishers is one of the recreation stakeholders. The AMWG has eleven goals for the Grand Canyon below Glen Canyon Dam. The goal for Lees Ferry was to reduce the Trout population from 250,000 to 100,000. And Trout now are absolutely persona non-grata in the Grand Canyon. Two other AMWG goals are to have bigger sand camping beaches and more Humpback Chubs in the Grand Canyon. The National Park Service is the most anti-Trout stakeholder in the AMWG, largely because today the NPS does not want anything non-native in the Grand Canyon. Other intensely anti-trout stakeholders are the U.S. Fish and Wildlife Service, the U.S. Bureau of Reclamation and the Grand Canyon Trust.

Humpback Chubs are warm water fish living mainly in the Little Colorado River because it is spring fed and warm (70 degrees F.) all year. There are non-native fish (Channel Catfish, Bullheads, Carp, Shiners, etc.) that also live in the LCR. Humpback Chubs in the LCR are captured and counted five times a year by the Fish and Wildlife Service and by the Arizona Game and Fish department.

Having chubs only in the LCR is not acceptable to the NPS, the FWS, the USBR and the GCT. They are insisting that chubs must live in the Colorado River as well. This is probably impossible and also very risky to the chubs living in the LCR. Warming the water released from Glen Canyon Dam would require dam modifications costing as much as 160 million dollars. Warmer water would transform the current situation of Trout in the cold Colorado River and Chubs in the warm Little Colorado River to both rivers being conducive to non-native warm water predatory fish from Lake Mead (Stripped Bass, Smallmouth Bass, Channel Catfish, Sunfish, Shinners, Etc.).

In 2003, during a NPS feasibility study using a weir at the mouth of Bright Angel Creek, 423 Brown Trout were killed. The AMWG endorsed killing Brown Trout but not Rainbow Trout. In fall 2006, the NPS started a five year project to kill Brown Trout and Rainbow Trout in Bright Angel creek. During a thirty-day comment period, the NPS received dozens of letters opposed to their killing plans. The Arizona Game and Fish department gave the NPS a permit to kill only the Brown Trout. In 2006, 212 Brown Trout were killed in 70 days. The NPS has stated they intend to kill Rainbow Trout as well, with or without an AGF permit and without regard to public comments.

GCMRC proposes “Beach Habitat Building Flows” to increase the size of camping beaches. These spring floods would occur when enough sand has come into the Colorado River from flash floods in the Paria River at Lees Ferry. GCMRC contends that the floods will also clean out “senescent” or old aquatic plants, improving fish food supplies and create better “back water” habitat for chubs. Declines in the Lees Ferry Trout Fishery have coincided with experimental flows for beach manipulation. Particularly bad examples were the year long flow experiments in 1990-91 and the very destructive flood in November 2004. A flood was proposed for March 15 in 2007, that did not happen, but a flood has been proposed for spring of 2008.

$200,000.00 has been spent by the USBR to study the feasibility of pumping four million tons of sand and clay a year from the Navajo Canyon delta in Lake Powell to the river below Glen Canyon Dam through underwater and underground pipes. The objective is to “provide cover for Humpback Chubs” by making the river continuously muddy and to make camping beaches bigger. Appraisal cost estimates for five different designs range from 110 to 400 million dollars, with annual operating costs of around 10 million dollars.

On June 2^nd 2006, The Center for Biological Diversity and the environmental group Living Rivers gave formal notice of intent to sue the Arizona Game and Fish Department for violating the endangered species act if they stock Trout at Lees Ferry.

So what does all this mean to the sportsmen of Arizona? We must understand that the debacle that is occurring at Lees Ferry and in the Grand Canyon is the beginning of a movement to remove non-native sport fish from not just the Colorado River, but sport fish removal and eradication might just be coming to a river or lake near you.

WHAT CAN YOU DO? Get involved in the process, go to public meetings, and write letters to the government organizations and your politicians. Let all your friends know and urge them to join organizations like The Federation of Fly Fishers or Arizona Sportsmen For Wildlife Conservation, organizations dedicated to educating the public, advocating wise use, and protection of our wildlife resources and hunting and fishing heritage.

For more information about the AMWG and future experiment planning check out this USBR web page:

http://www.usbr.gov/uc/rm/gcdltep/index.html

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