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. . Page 2 - 07 July 1998 Letter to D. Trueman, Bureau of Reclamation RE: Hopi Tribe's Comments On the Glen Canyon Dam Modifications To Control Downstream Temperatures: Preliminary Draft Plan and Environmental Assessments. Relying solely on the programmatic agreement to address all cultural resource concerns results in a false sense of compliance and will inevitably lead to places or resources of traditional value to Native Americans being adversely impacted. For example, the Havasupai Tribe has been invited to participate in the programmatic agreement and the adaptive management program, but to date has chosen not to take part. Yet, the Havasupai still have places and resources of traditional importance within the Colorado River corridor that need to be addressed in this docwnent The Bureau of Reclamation should make a concerted effort to consult with each of the Native American tribes to identify concerns related to the operation of the proposed thermal modification structure on Glen Canyon Dam. Another cultural resource issue that was not addressed in this section is the likelihood that the Glen Canyon Dam is a potentially significant historic property that is eligible to the National Register of Historic Places. Its construction and existence marks a significant period in the development of the American west and the prominent role that the Bureau of Reclamation played. Similarly, the controversy surrounding its construction played a key role in the development of the environmental movement in the west. Finally, sites associated with the construction of the dam have already been determined eligible for nomination to the National Register by the Bureau of Reclamation in consultation with the Arizona State Historic Preservation Officer. Constructing a thennal modification structure on the Glen Canyon Dam should therefore be considered in tenns of its effect on the characteristics and integrity that could make this dam potentially eligible to the National Register. A similar comment is applicable to the section on Indian Sacred Sites in this document that was made above regarding the treatment of traditional cultural resources under the programmatic agreement. The programmatic agreement deals only with Register eligible properties and may not adequately address the issues or concerns that are associated with Native American sacred sites. Moreover, the programmatic agreement deals specifically with compliance issues relating to the National Historic Preservation Act, as amended. Treatment of inadvertently discovered or intentionally excavated Native American human remains is covered under the Native American Graves Protection and Repatriation Act and is the responsibility of the federal land managing agency, the National Park Service. To reiterate the above point, it is not wise to assume that all cultural resource or Native American concerns are categorically addressed and adequately covered by the programmatic agreement. Finally, the Hopi Tribe is concerned about extensive biological monitoring program that appears to be at the base of successfully implementing the operation of this proposed project. It is unclear how such a monitoring program would be supported. Is this monitoring as it is envisioned by the Bureau of Reclamation going to be added to the responsibilities of the Grand Canyon Monitoring and Research Center? If so, will there be additional funding to cover an expanding biological monitoring program? The issue of funding should be addressed at the next Technical Work Group meeting.