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. . PaQe eOlll1lents 69 Figure VII-6. Release pattern, as referred to in the text in the 1st paragraph, is missing. General note: The discussion in the second paragraph would indicate that rafters do not place such a high value on "naturalness" after all. 75 Last paragraph. Why is the option of artificially protecting camping beaches summarily rejected with little or no investigation? This would seem to be a reasonable direction to take, unless it can be shown not to be viable. The costs, feasibility, and possible impacts of making operational modifications were considered beyond the scope of the study, but changes to operations were not eliminated from consideration on the same grounds. 76 1st paragraph. In keeping with the study approach proposed by Western, conclusion (1) is better phrased, "Downstream environmental and recreational resources would benefit from the elimination of flood releases and minimization of fluctuating flows. II Last paragraph. Western di sagrees that "Daily fl uctuat ions degrade the natural character of the environment " any more than artificially b10ck-loaded flows would. 77 2nd Paragraph. Fluctuating flows do not lead to a loss of backwater habitat. These backwaters formed in a fluctuating flow regime in the post-dam period--there were no pre-dam backwaters. Possible flow patterns exist that would result in the creation of more backwater area, or may result in the preservation of backwaters existing at a given point of time. This again points out the inappropriateness of using an idealized baseline for comparison. 4th paragraph. Under conclusion (2), why was it decided that only the CRSP water delivery requirements were binding? As an assumption in the various technical analyses it made sense to use this parameter, but this passage indicates it has some higher importance than all of the other provisions of the CRSP act and other "1aw of the River" components. The text to recognize that the area downstream of Glen eanyon Dam is and always has been a dynamic environment. Grand Canyon itself was formed by the "degradation" of natural resources. Steady releases of annual runoff may preserve for the short run the status quo, but it wi 11 not be II natura l" at all. 78 Under ManaQement Options, the stUdy seeks to convince the Secretary of the Interi or that "impacts" to the recreati on resources are justifica- tion for taking action. Western disagrees with this approach. The question before the Secretary is whether or not improving the recrea- tional resource is worth the costs to other river interests. The GCES should have focused its efforts more on providing the Secretary with options that would achieve the study's goals, and the potential costs of these options, than trying to justify a change based on "impacts" to 7