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<br />'I <br />.. <br />il <br />'I <br /> <br />Mr. Lee J. McQui vey <br />April 1.1., 1.994 <br />Page 2 <br /> <br />t <br /> <br />this adverse environmental impact. The scientists also seem <br />satisfied that the range of minimum releases being produced by the <br />existing interim operating criteria are adequate to maintain the <br />food resources within the river system for native and non-native <br />fish. We note that the fluctuating flows have been demonstrated to <br />cause . the transportation of food resources downstream to the <br />benefit of downstream fish populations. We also note that controls <br />of the daily change in releases has had a beneficial effect on <br />beaches and that scientists have been better ab1.e to identify the <br />factors that affect the transfer of sediment between beaches and <br />sandbars and sandbars and riverbed. The scientists have also begun <br />to separate the impacts of the existence of Glen canyon Dam. from <br />the impacts of its operation. <br /> <br />~I <br /> <br />.~ <br />.~ <br /> <br />Even so, there have been some notable failures in the process. <br />Most recently, changes in the interim operating criteria were <br />subj ected to the consultation process required by the Grand canyon <br />Protection Act of 1.992. Asa result of that process, including 2 <br />publ.ic meetings, recommendations were forwarded to the commissioner <br />of Reclamation and the Secretary of the Interior for adjustments in <br />2 of the 5 operating parameters for the interim operating criteria. <br />Hot onl.y did the Commissioner not consider those changes and <br />forward them to the Secretary of the Interior for his <br />consideration, the recommendations were unilaterally withdrawn by <br />the Acting Regional Director of the Bureau of Reclamation in Salt <br />Lake City, totally vitiating the consultation process. This <br />monumental fail.ure calls into question whether an iterative process <br />driven by scientific. measurement can in fact be put in place for <br />ongoing review of the operation of Glen Canyon Dam. <br /> <br />Unfortunately, much of the confidence in moving the EIS process <br />forward to a decision is eroded by this dramatic failure of the <br />first attempt to make a science-based adjustment in operating <br />criteria. There are many unanswered questions about the riparian <br />and riverine resources of the Colorado River between Glen Canyon <br />Dam and Lake Mead. There may be more unanswered questions than <br />answered. Going forward now without these answers was based in <br />large part on the confidence the interested parties previously had <br />in the iterative process already developed being molded into a new <br />process for dealing with further science and further answers in the <br />future. This new process has been labeled "adaptive management". <br />Congress thought enough of this concept to require consultation on <br />it in the 1992 Act. Clearly, the first attempt to exercise this <br />concept has failed. If it cannot be relied upon in the future with <br />any confidence, then many of the unanswered questions assume much <br />more importance in terms of their being answered before any final <br />decision resulting from this environmental impact statement is <br />made. <br /> <br />'~:I <br /> <br />:, <br />, <br /> <br />, <br /> <br />.'; <br /> <br />if, <br /> <br />,~.. <br />I' <br />'>' <br /> <br />~.: <br /> <br />~:' <br />