GCPBA RiverNews - Basin States and Power, Glen Canyon Dam Management Perspectives - LTEMP Submissions From Non-River Interests Summary
GCPBA, as well as many individuals, explored a wide variety of angles when deliberating about what to submit to authorities putting together the Long Term Experimental and Management Plan (LTEMP) for Glen Canyon Dam. But those of us in the river community tend to have a certain perspective on the dam and how it impacts the Canyon.
Now that the LTEMP team has published its scoping report, it's instructive to take a look at how two other major players in this scenario approached future dam operations. Those two other players would be the basin states, and the irrigation and power interests.
There were two particular submissions by those entities, which we summarize below.
The Basin States submission commented on:
* Their federally recognized entitlements to water, bolstered by a rather long section on the legal basis for the current system.
* Their desire that Interior emphasize non-dam alternatives to improving the Grand Canyon.
* Their desire for an audit of the costs and benefits to water and power users, as well as to natural, recreational and cultural resources resulting from management policies and dam operations.
* The need for reporting on LTEMP activities in a manner that does not interfere with the Secretary's other responsibilities regarding the Annual Operating Plan.
* Their view that there should be reallocation of costs of construction, operation, maintenance, replacement and emergency expenditures for Glen Canyon Dam, which might result from protecting, mitigating and improving the values downstream. This would include cost shifting for lost revenues.
* They support establishing and implementing long-term monitoring programs and activities, and want to be consulted, with others, in preparing criteria and operating plans, as well as monitoring programs and activities for the LTEMP.
* They also want clear distinctions between experimental and management flows.
Interesting Quote: "Alternatives: Generally, the LTEMP EIS (Enviromental Impact Statement. ed.) should include only those alternatives that can and will remain consistent with and subject to the priorities, constraints, and requirements recognized in the GCPA. See Section A, supra. However, with the understanding that the modified low fluctuating flow (MLFF) will serve as the "No Action" alternative, the LTEMP EIS should a include a post-dam, pre-1996 ROD alternative that can isolate and demonstrate the benefits and impacts of MLFF operations.
Finally, the Basin States would like to participate in developing the LTEMP alternatives and anticipate proposing an alternative for consideration."
Comments by the Arizona Irrigation and Electrical Districts included the following:
* It's their position that last year's hydrologic experience at the dam demonstrates the need to study the effects of releasing water at full power plant capacity on a constant basis, as well as using maximum power plant capacity in a fluctuating release regimen beyond that of the Modified Low Fluctuating Flow.
* They urge that future management plans not ignore any of the hydrologic mandates that could require Reclamation to employ full use of the power plant, like those experienced this past summer.
* They want any future management plan to take into account all of the situations with which Reclamation can be faced in the future with regard to operating the Dam.
* It's their belief that any EIS that fails to study the "full power resource" will likely be rendered inadequate.
* Interesting quote: "HFE floods (High Flow Experimental floods, ed.) have failed to produce any long term discernible benefit to the beaches and sandbars.
The HFEs conducted at different times and under different sediment conditions, have one thing in common. The sand deposition created by these artificial floods largely disappears within six months. One of the reasons dams were built along the Colorado River is that it was widely considered to be the most erratic major river in the United States.
"The environment through Glen Canyon Dam, Marble Canyon and Grand Canyon prior to the construction of Glen Canyon Dam was generally and universally considered to be unstable, erratic and barren. The river corridor was barren because massive floods crashed through these canyons every year taking everything with them except sand, boulders and rocks…. The artificial floods merely recreate that instability.
"In short, the artificial floods have been widely ineffective beyond that of creating short-term beaches. The beaches and sandbars created by HFEs are merely bandaids to a much greater wound. Much like a real bandaid, when it is mixes with water, it tends to erode and wash away."
* They also recommend, as an alternative to HFEs, mechanical augmentation (evidently taking dredges into the river corridor, as noted below), which they say is economically feasible. This is an interesting quote from that section, "IEDA has researched the costs associated with obtaining and operating dredges and urges Reclamation to solicit bids. The costs associated with dredging pale in comparison to those of these artificial floods. A dredge can be broken down and transported to a dredge-site at minimal expense. Once on location, the dredge can be reassembled and used, taken apart again and floated down the river. The portability and maneuverability of the dredge provide a relatively
permanent and infrequent mitigation measure far surpassing artificial floods.
Additionally, mechanical augmentation does not involve certain economic and environmental costs associated with artificial floods. With each artificial flood, Glen Canyon Dam power purchasers are forced to purchase alternative sources of power at much higher cost, usually ranging in the millions of dollars. More often than not, the source of alternative power requires the use of other less environmentally desirable resources. Beaches are cut and rendered less accessible to persons of less than athletic ability and non-native trout are benefited at the expense of the endangered humpback chub."
* They go on to question humpback chub studies and the efficacy of the trout removal program.
* They challenge the view ("preconceived notion") that the Dam should be operated in a manner that would mimic pre-dam conditions.
* They say, "Dam management should instead seek to utilize the Dam's defining characteristic: stability. Stability of the river can make dealing with river impacts easier, but only if people are willing to consider proven management strategies and common sense solutions…"
• A final quote: "The Dam should be utilized in the way it was intended; as a load following hydropower facility that adjusts its power output as demand for electricity fluctuates. Management should adopt mitigating measures such as those described above and implement them in a way that complements hydropower production. The LTEMP EIS must examine more common sense ways to mitigate downstream impacts and stabilize downstream resources. The taxpayers and ratepayers funding this exercise deserve it. The Grand Canyon deserves it."
For GCPBA RiverNews: Rich Phillips
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