Public Comment Period is Over
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
Entries Tagged as 'Public Comment Articles'
Experimental Flow Statement by Terry Gunn
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.
Comments On Experimental Releases 2008-2012
Mark Steffen 02-12-08
Federation of Fly Fishers/
Regarding: Reclamation Environmental Assessment, Experimental releases from Glen Canyon Dam,
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
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
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).
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
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. (
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
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
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
GCMRC, 12-27-2007. Science Plan for Potential 2008 Experimental High Flow at
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
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
Minckley, 1996. Observations on the biology of the HBC in the CR basin 1908-1990.
Peterson, 1984. Benthic diatom community dynamics in the
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.
Van Haverbeke, USFWS, May 2005. Monitoring of Native Fishes of the Little Colorado River Ecosystem in
Webb, Melis and
Trout and Native Fish Conflicts in the Grand Canyon
Trout and Native Fish Conflicts
Perceived conflicts between Trout and native fish in
In the vision of Teddy Roosevelt, the National Park Service stocked Trout in Colorado River Tributary creeks in the
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
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
Humpback Chubs are warm water fish living mainly in the
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
In 2003, during a NPS feasibility study using a weir at the mouth of
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
$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
On June 2nd 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
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