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<br />-..,- -~..-.."",- -...--......... <br /> <br />-- "'IIiiL - -~ - <br /> <br />MAYNES,BRADFORD&SHPS <br /> <br />ID:303-247-8827 <br /> <br />APR 07'94 <br /> <br />14:33 No..016 P.1S <br /> <br />'.oC .- <br /> <br />I <br /> <br />Vestern Area .Power Adminlstration <br />Generll Comments on the Burelu of R.el..atlon's <br />Operation of &len Clnyon D.. <br />EnvlroRltntal Implct $tat...nt <br />Aprtl 1114 <br /> <br />Western his identified severll mlin issues thlt should be addressed In detail In <br />the final Operation of Glen Canyon Dam environmental Impact stltement (EIS). <br />These issues arl briefly prlsented below, with rellted or clarifying comments <br />denoted by bullets. The term "resources" IS used in. this document means the <br />combined natural, cultural, humin, and economic resources unless otherwise <br />specified. If furth.r explanation of these comments is needed, please contact <br />Mr. Tony Morton at 801-524-5636. <br /> <br />I. While the draft EIS is clelr about its focus on dam operations, many people <br />expect that this will be the definitive resource management master plan for <br />the Grand Canyon. Reclamation should ensure that the limited nature of <br />this EIS is clearly understood by the public, or expand the EIS to <br />encompass thl stlted, and desired, needs. Within its self-imposed <br />limitations, the draft [IS has good coverage. <br /> <br />. There Is a disconnect between the scope of the EIS and the need to <br />balance and protect downstream resources. It Is assumed that <br />rlleases from the dam are the only cluse of Impacts on downstream <br />resourcls and, therefore, changing dam operations ls thl only <br />management technique for ..naglng Ind enhancing those resources. <br />These Ire faulty assumptions. <br /> <br />. Th, EIS should make clear that It Is not a long-term resource <br />manageMent plan, and that it addresses only a portion of the <br />actlvltles that would be r.quired in a comprehensive management plan. <br /> <br />2. lh.r. has been a graduIl shift In the central question Iddressed ln the [IS <br />of "how can we modify flows" to "how can we best manage the resources." <br />There is now In opportunity to address holistlc rlsource manage..nt <br />approaches for the long tl,.. W.stern supports the Investigation of both <br />operatlonll and non-operatlonal management technlques, practlces, and <br />programs to determinl the best.solutlons to the difficult problems that <br />face resource .Inagers. <br /> <br />. Research by the Glen Canyon Environmental Studies team and oth.rs has <br />demonstrated that water releases can help manage some resources, but <br />are not effective for othlrs. Changing thl flow regime at Glen <br />Canyon Dam is not the only, nor necessarily the best, melns of <br />achieving positive resource changes. <br /> <br />. The opportunity exists to Integrate operational and non-operational <br />manlgement options to promote thl most effectlvl means of achieving <br />management goals while optimizing, to the extent possible, each <br />individual rlsource. <br /> <br />. Humpback chub recovery will depend upon Melsures other than flow <br />modification, such IS include water tlmperaturl, inerleslng <br />turbidity, dlvlloplng new trlbutlry habitats. and reducing <br />