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<br />, <br /> <br />added to the Preferred Alternative and we have considerable concern <br />about their ramifications. <br /> <br />1;. <br />" <br /> <br />" <br /> <br />ELEMENTS OF THE PREFERRED ALTERNATIVE <br /> <br />operating levels of the dam under Interim Flows would be continued <br />if the Preferred Al ternati ve is adopted. However, scientific <br />information now suggests modifications to various parts of the <br />Preferred Alternative could be made with probable further <br />environmental improvements, little risk to downstream resources and <br />significant benefits to hydropower. <br /> <br />* Small upramping rates as required under Interim Flows were <br />found to be unnecessary to prevent sandbar erosion. Scientists <br />found no evidence that raising the maximum upramp of 2,500 <br />cfs/hour under Interim Flows to 4,000 cfs/hour would be <br />detrimental to downstream natural or cultural resources. <br /> <br />* Scientists also found no evidence that infrequent raising <br />of ,the maximum release from 20,000 cfs to 25,000 cfs would be <br />detrimental to downstream natural or cultural resources. <br /> <br />'. <br />!':* <br />/; <br />./; <br /> <br />* Riparian plants at the upper elevations of the New High <br />Water Zone would receive periodic watering and thereby enhance <br />their survival chances. <br /> <br />t.''' <br />;..~ <br /> <br />* High elevation wet and dry marshes would begin to grow in <br />size and number as less would be subject to drying or drowning <br />as occurs under more steady flows. <br /> <br />',. <br /> <br />:,,: <br /> <br />.... <br /> <br />* Reductions in sloughing of Cladophora would be reversed <br />somewhat thereby enhancing food supplies for Humpback chub and <br />other aquatic species in the lower river. <br /> <br />Modifications to the maximum release criterion and the maximum <br />upramping were debated by the Cooperating Agencies and other <br />interested parties in a consultation process mandated by the 1992 <br />Grand Canyon Protection Act and unanimously accepted. These <br />changes should be incorporated into the final Preferred Al ternati ve <br />adopted in the Record of Decision. <br /> <br />In addition to the need to modify the Preferred Alternative, we <br />have some concerns regarding the analysis of economic impacts. <br /> <br />-4 <br /> <br />~ :'; <br />LJ <br />:~~. <br /> <br />., <br />, <br />r,~ <br /> <br />.-:. <br />.', <br /> <br />":'"t <br />7 <br /> <br />~~ <br /> <br />", ~~ <br /> <br />* The negative direct impacts to the hydropower sector dwarf <br />any direct positive impacts resulting from changing flows. <br />The present value of positive impacts for recreation is $43 <br />million and negative impacts for hydropower is $888 million. <br /> <br />* Presently, recreation benefits are based on opinions as to <br />what would be paid (willingness-to-pay) but power impacts are <br /> <br />7 <br />