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<br />. <br /> <br />. <br /> <br />Mr. Clifford I. Barrett <br />Regional Director <br />United States Bureau of Reclamation <br />ATTN: Mr. Harold Sersland <br />P.O. Box 11568 <br />Salt Lake City, UT B4147 <br /> <br />Dear Mr. Barrett: <br /> <br />SEP 09 1987 <br /> <br />Enclosed are comments on the August 1987 preview copy of the Glen Canyon <br />Environmental Studies (GCES) Draft Technical Integration Report, as requested <br />in your letter dated August 15, 1987. In general, this draft report is much <br />improved from the earlier versions. The writing is more clear and concise, <br />and the document is much better focused. Presentation and organization a1so <br />appear to be improved from the earlier documents. <br /> <br />Western Area Power Administration (Western) offers the following comments <br />based on a review of the August 1987 draft of the Technical Report. <br /> <br />Western disagrees with the baseline selected and the approach to the study. <br />The study uses a hypothetical situation of ideal conditions for white-water <br />rafting and trout fishing as a baseline for the determination of impacts <br />resulting from the present operations of Glen Canyon Dam. Any situation of <br />less-than-optimal conditions for these recreation interests is considered an <br />"impact" by the study. The study then proceeds to justify the optimization of <br />thesE recreation interests based on the II impacts II i dent if1ed. <br /> <br />Western has a number of concerns related to this approach. In the usual <br />environmental impact analysis, a hypothetical optimum cannot be used as a <br />baseline. It is recognized that this was not and is not a National <br />Environmental Policy Act (NEPA) analysis. However, it is clearly more of a <br />recreation resource optimization plan than an environmental study. Western <br />feels that the document should reflect this. The study should outline present <br />operations as part of the existing baseline situation, then examine changes <br />that could be made to this baseline condition to enhance the recreation <br />resources. <br /> <br />As discussed in the report, the construction of Glen Canyon Dam produced the <br />cold, clear water that allowed the trout fishery to flourish. The moderated <br />and regulated flow regime also allowed the development of white-water rafting <br />and day float trips. All of these recreation resources are of extremely high <br />