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<br />SIaleIllllllt of Governor Mike SullivlD re: <br />Glen Canyon Dam Draft Environmental Impact Statement <br />Man:h 21, 1994 Page 2 <br /> <br />would occur between the draft and final EIS." See p. 35 of the <br />dEIS and pp. 8-9 of the summary dEIS. Further, Section l804(C) of <br />the GCPA specifies that the Secretary is to adopt criteria and <br />separate operating plans "... based on the findings, conclusions <br />and recommendations made in the environmental impact statement <br />...", but we are unable to find where these specific matters have <br />been mentioned or analyzed in the dEIS at all. <br /> <br />These common elements bear closer inspection, and each are <br />briefly reviewed below: <br /> <br />AdaDtive Manaaement <br /> <br />The dEIS advises that an adaptive management program will <br />continue forward after the Record of Decision. conceptually, the <br />program is explained in part by statements such as that found on <br />pa~ of the dEIS Summary: <br /> <br />-\\ I/' "Many uncertainties exist regarding downstream <br />.,J)' <br />'t-.iJ0 ~:~~ctsTh~f c~~~:~t r:;e:~:;ti~omma~~~~m;:~y~~ <br /> <br />~~~~ based on the need for operational flexibility <br />to respond to future monitoring and research <br />findings and variable biological and physical <br />conditions." <br /> <br />The dEIS indicates the status of the adaptive management program by <br />noting that "Further development of the adaptive management process <br />would occur between the draft and final EIS." See pp. 34-35 of the <br />dEIS and pp. 8-9 of the Summary dEIS. Wyoming urges that what is <br />being done relative to "further development" in the dEIS be <br />disclosed to the public. <br /> <br />The Grand Canyon Protection Act requires that all post Record <br />of Decision research programs are to be adopted upon consultation <br />with (specified) entities, institutions and groups of interests. <br />See Section 1803 (b) of the Grand Canyon Protection Act (GCPA), <br />Attachment 2, p. Att-3 of the dEIS. Apparently, the Bureau assumes <br />that the required "consultation" means those entities will be <br />invited to participate on the Adaptive Management Work Group. The <br />State of wyoming both would appreciate and expects to be notified <br />and consulted on these matters as required in the "Law of the <br />River." <br /> <br />Flood Freauencv Reduction Measures <br /> <br />The State of Wyoming is concerned that throughout the dEIS <br />this common element continues to be framed as a procedure where <br />either of two separate methods have been identified and could be <br />used to accomplish the objective of reducing flood frequency. <br />