PUBLIC COMMENTS NEEDED FOR NEW EIS & DAM DECOMMISSIONING
Deadline: Friday, April, 2, 2004
The Bureau of Reclamation (BOR) is proposing modifications to Glen Canyon Dam as part of its failing effort to halt the extinction of endangered fish in Grand Canyon National Park caused by the dam’s four decades of operation. Four native fish species have already been lost, and a fifth is eminent–the humpback chub. The BOR is attempting to fast-track a cursory environmental assessment of this proposal, and avoid any serious analysis of its failure to comply with Endangered Species Act, Grand Canyon Protection Act, and National Park Service Organic Act. Living Rivers/Colorado Riverkeeper and a broad coalition of partners are joining scientists in demanding that a more detailed environmental review, in the form of an Environmental Impact Statement (EIS) be undertaken. Integral to this analysis must be the evaluation of a dam-decommissioning alternative, which a growing number of experts are suggesting is the only way to save Grand Canyonís famed river ecosystem. Ten years ago there were 8,000 adult humpback chubs in Grand Canyon and now there are only 1,100. Razorback suckers could still be spotted in the Canyon’s mainstem, but now there are none. Dam managers were charged by law to recover both. They have failed. Instead, new species have established themselves, such as the Asian tapeworm, which is a parasite to the humpback chub. Also, the New Zealand mud snail, which is now overgrazing the river bottom and further depleting the river’s native food web. Such creatures will proliferate in warmer water, as will the non-native fish species (catfish, carp and brown trout) which feed on the young humpback chub. Yet warmer water in Grand Canyon is what BOR hopes to achieve by installing a “temperature control device” (TCD) on Glen Canyon Dam. Since 1964, when hydropower came on-line at Glen Canyon Dam, the waterdischarged into the Grand Canyon has been too cold to stimulate the reproduction of the native fish. This is one of a number of issues associated with Glen Canyon Dam’s operations, which has caused the steady decline and extinction of Grand Canyon’s native species Nine years ago the Glen Canyon Dam Environmental Impact Statement recommended a host of new dam operating strategies to reverse this decline. One measure involved installing this temperature control device to the penstocks of Glen Canyon Dam to extract warmer surface water from Lake Powell reservoir. The BOR now wants to get rapid environmental clearance to build this TCD–relying on the outdated 1995 study which has proven ineffective in guiding any recovery of native species in Grand Canyon. Please join us and demand that a new Environmental Impact Statement be initiated, not only for the TCD, but the dam’s operations as a whole.
A sample letter is attached below.
More information on the TCD and the campaign to restore Glen and Grand Canyons can be found at our web site: http://www.livingrivers.org/archives/article.cfm?NewsID=570 You can automatically submit a version of this sample letter (with any additional comments) by clicking “ACT NOW” at our affiliate’s, Waterkeeper Alliance, web site: http://www.waterkeeper.org/mainarticledetails.aspx?articleid=154 Groups supporting this new EIS include: Alliance for SustainableCommunities, American Whitewater, Arizona Wilderness Coalition, Biodiversity Conservation Alliance, Bluewater Network, Buckeye Forest Council, California Save Our Streams Council, Californians for Western Wilderness, Center for Biological Diversity, Clearwater Biodiversity Project, Coastal Land Trust, Colorado Plateau River Guides, Conserv America, Electors Concerned about Animas Water, Endangered Habitats League, Escalante Wilderness Project, Eyak Preservation Council, Forest Watch, Friends of Arizona Rivers, Friends of the Animas River, Friends of the Earth, Friends of the Eel River, Friends of the River, Great Old Broads for Wilderness, International Rivers Network, Kern Valley River Council, Kettle Range Conservation Group, Maricopa Audubon, Montana River Action, National Forest Protection Alliance, Native Forest Network, Northwest Rafters Association, Northwoods Wilderness Recovery, Oregon Natural Desert Association, Outdoor Adventure River Specialists, Inc., Ridgeline & Open Space Coalition, River Runners for Wilderness, Sacramento River Preservation Trust, Seeds of Simplicity, Sky Island Alliance, Southern Utah Wilderness Alliance, Spirit of the Sage Council, Sublette Riders Association, Superior Wilderness Action Network, Tag-A-Long Expeditions, Inc., Taxpayers for the Animas River, Utah Environmental Congress, Virginia Forest Watch, Waterkeeper Alliance, Western Watersheds Project, Western Wildlife Conservancy, Wetlands Action Network, Wild South, Wild Wilderness and Wilderness Watch.
To lend your groups name to our initiative, please contact:
John Weisheit
Colorado Riverkeeper
435-259-1063
***********SAMPLE LETTER***********
Please write by Friday, April 2, 2004 to:
Ms. Nancy Coulam
Bureau of Reclamation
125 South State Street, Room 6103
Salt Lake City, UT 84138-1102
Phone: 801-524-3684
Fax: 801-524-5499
Email: ea_comments@uc.usbr.gov
Dear Ms. Coulam,
I submit the following scoping comments for the draft Environmental Assessment (EA) that the Bureau of Reclamation (BOR) is presently preparing for the proposed temperature control device (TCD) at Glen Canyon Dam, Arizona. While it is critical that urgent action be taken to address the decline of endangered species in Grand Canyon National Park caused by Glen Canyon Dam’s operations, the TCD initiative now underway may only further the native ecosystem’s collapse. Its operation could actually bring the few remaining native fish closer to extinction, constituting an incidental take of endangered species.The situation is particularly critical for the humpback chub, whose numbers have declined 85 percent since 1982. This decline, combined with bundant new information about the condition of the ecosystem in Grand Canyon since the TCD was recommended in 1995, compelled the BOR to halt the fast-tracking of the TCD proposal and undertake a more thorough review of the situation in Grand Canyon, including the full range of alternatives available to address them. Specifically, I request the BOR address the following:
1) The present environmental review process be expanded to a full Environmental Impact Study to address the TCD and all new information that has come forward since the first Glen Canyon Dam EIS was completed in 1995.
2) Other alternatives to warming the water, including permanently lowering the reservoir and decommissioning the dam.
3) The potential for the TCD’s operation to increase the population of non-native fish such as catfish, carp and brown trout, which are known to prey on the young of endangered fish species.
4) The effect the TCD will have on water quality, including new and increased levels of exotic animals and parasites. Specifically, it should address impacts to the New Zealand mud snail and the Asian tapeworm, which are not native to Grand Canyon ecosystem; and how will these impacts affect the recovery of the native fish, which were not addressed in the original EIS.
5) The TCD’s potential impacts on the aquatic food web for Grand Canyon’s native fish. This includes the impacts associated with the worsening drought situation and the quality and quantity of nutrients to provide carbon for the river’s food chain.6) The complimentary role other mitigation measures must play, especially sediment augmentation to replace the loss of 95 percent of Grand Canyon’s sediment and nutrients trapped behind the dam, and the restoration of flow regimes that mimic the rivers annual, natural hydrograph.
7) The safety risks that these modifications to the penstocks my pose to Glen Canyon Dam, especially at low water levels.
Thank you for the opportunity to submit these comments.
Sincerely,