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SPECIFIC COMMENTS AND QUESTIONS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR GLEN CANYON DAM CHAPTER II Page (Pg) 33, Column (C) 2, Paragraph (P) 1. According to Randy Peterson of USBR, the timing of the 20,000 cfs release in April does not allow USBR to manage the reservoir to allow flexibility for April 1st forecast no space is left at that point. Therefore, the frequency of ,spilling would increase. Is this true? What are the ramifications of this condition? '1 Pg. 34, C. 1, P. 5. The concept of Adaptive Management is not new; some would say it has always been used at Glen Canyon Dam. What seems new is the concept that regulated river management should now consider a variety of resources not previously included, like recreation and ecology. Management of Dam operations has always reflected and incorporated into the operating plans, those resources represented as being worthy of consideration. Recreation and ecology are resources deemed by the authors to be worthy of consideration in management of Dam operations along with resources previously considered such as water demands, hydropower operations and flood, control. This seems reasonable but the trick is achieving an acceptable balance of all resource considerations. Is balancing considerations an intent? Will there be priorities? Pg. 34, C. 2, P. 3. Given the disparity of agendas each committee member is likely to pursue, this kind of arrangement would likely result in dramatic swings in operations over time. Not only would power contracts suffer from such large swings in operations, but ecological conditions downstream would be harmed. " .. " .~ -> f ;. ".- Non-operational mitigation should be used where operational mitigation would be either ineffective or less cost-effective, after considering costs to all resources. In either instance, to maintain efficiency, non-operational mitigation should be part of the overall management process. Pg. 35, C. 1, P. 1. The information base described is too narrow to provide a realistic data set for the Adaptive Management program. All resource uses and impacts must be included in the data base. This includes water and power supplies and demands. This way, Adaptive Management decisions will reflect all society'S choice on Dam operations rather than only one or two segments. Long-term monitoring and research also should look at the power system as an integral part of a total energy supply program, not .;.' ,.' ~' ~ ..; 18