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Mr. Lee J. MCQui vey April ~~, ~994 Page 3 : , Moreover, the out of hand rej ection of the recommendation for changes in the interim operating criteria stemming 1'rom the consultation process has eroded con1'idence in the EIS process itself. The lack of detail in the discussion of adaptive management in the draft environmental impact statement has caused many to question whether, in this political environment, the process can go forward without the complete description of the adaptive management process. Since that can only occur after the public comment period has closed, a second public comment period may be necessary in order to provide the detail and the opportunity to comment necessary to restore confidence in this exercise. r: ,. We have taken the pains to outline these general comments to you in order that our specific comments concerning the draft environmental impact statement would be better understood. The following summary lists our specific comments in six (6) areas. The attached detailed comments about the draft environmental impact statement relate to a variety of subj ects discussed in that document (Attachment 1). " ;~ ~ '- ~~ .> -. '1'BB DI'J.'BRDI OPERATING CRr.rERIA ALTERHATIVE SBOUID BE MODIFIED TO INCLUDE '1'BB 2 CHARGES RBCOMMBRDBD BY '1'BB CONSULTATION PROCESS MID DESIGHATBD AS '1'BB PROPOSED PRBFERRBD ALTERNATIVE :-- We sense from attending the most recent meeting of the Cooperating Agencies with the research scientists a growing realization that the interim operating criteria, while not perfect, have provided a fluctuating flow regimen that, assessed as to all resources, significantly benefits riparian and riverine resources below Glen Canyon Dam while providing a minimal number of adverse environmental impacts. In the spirit of this growing realization, the consultation process resulted in a recommendation to relax 2 of the 5 interim operating criteria parameters. The proposed change in the upramping rate was seen as having no adverse environmental impact and likely no measurable change in observable river flows. The change in the maximum release criterion (not actual water release) was also seen as having no likely environmental impact and very likely a beneficial environmental impact in terms of beginning to wet areas that had previously been wetted and are now suffering under an absence of moisture. In other words, the rich marsh environment created by the construction of Glen Canyon Dam and the fluctuating flow water release regimen has suffered because of overly restrictive interim fluctuating criteria and can be benefited by a measured relaxation in those criteria. These 2 proposed changes would also benefit power generation, a result consistent with the provisions of the ,~ ~~ :"': .~'; ~:.i .t "~ ,