March 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. Your scoping comments are needed to ensure Glen Canyon dam's decommissioning and other critical issues are addressed in a new environmental review process to halt the extinction of Grand Canyon's native fish.
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 the Endangered Species Act, Grand Canyon Protection Act, and the National Park Service Organic Act. Utah based Living Rivers, the Colorado Riverkeepers and a broad coalition of partners including River Runners for Wilderness, are joining scientists in demanding that a more detailed environmental review be undertaken. The above groups are asking for an Environmental Impact Statement (EIS) that ensures the recovery of Grand Canyon's famed river ecosystem as was mandated over a decade ago.
In the early 1980's, it was estimated there were 8,000 adult humpback chubs. Now that estimate is 1,100. Razorback suckers could still be spotted in the river's mainstem, but now there are none. Dam managers were charged by law to recover both. According to John Weisheit of Living Rivers, "They have failed."
Weisheit notes that 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, is 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 the early 1970's, when hydropower came on-line at Glen Canyon Dam, the water discharged 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 have 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.
The Deadline for comments submitted by letter or fax is April 2, 2004. NOTE: The Bureau of Reclamation's web page and email are down due to a court order pertaining to DOI mismanagement of tribal trust funds. Send your letter via FAX or US Postal Service.
SAMPLE LETTER: Temperature Control Device/Environmental Assessment
Ms. Nancy Coulam
Bureau of Reclamation
125 South State Street, Room 6103
Salt Lake City, UT 84138-1102
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 abundant 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) 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.
3) 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 effect the recovery of the native fish, which were not addressed in the original EIS.
4) 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.
5) 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.
6) The safety risks that these modifications to the penstocks may pose to Glen Canyon Dam, especially at low water levels.
7) Other alternatives to warming the water, including permanently lowering the reservoir and decommissioning the dam.
Thank you for this opportunity to provide these comments. It is my hope that the Bureau of Reclamation will perform responsibly and fulfill its mandate to recover endangered fish species in Grand Canyon National Park.
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