i

RESPONSES TO SUBSTANTIVE COMMENTS ON 

THE DRAFT ENVIRONMENTAL IMPACT 

STATEMENT

METHODOLOGY AND PURPOSE

BACKGROUND 

The Draft Environmental Impact Statement, Personal Watercraft Rule Making: Glen Canyon National 

Recreation Area, Arizona and Utah, was released for public review in September 2002 (67 Federal Register

[FR] 178). Its release initiated a formal 60-day public comment period that ended on November 26, 2002. The 

United States Department of the Interior, National Park Service (NPS) is the lead federal agency generating the 

environmental analysis. 

The personal watercraft rule-making applies to management of personal watercraft in Glen Canyon National 

Recreation Area. The Draft Environmental Impact Statement described three alternatives that would protect the 

resources and values of the recreation area while offering recreational opportunities as provided for the area’s 

enabling legislation, purpose, mission, and goals. 

The National Park Service received 20,018 comment documents during the public comment period. Collectively, 

they contained 31,216 comments. Comments were received by letter, fax, and electronic mail; on comment 

forms collected at public meetings; as petitions; and in oral transcripts. Comment letters received included 

19,975 from individuals, 13 from businesses, 18 from organizations (organization was identified in the letter), 

and 6 from public agencies. Of the comments received, 60% were form letters in 11 separate formats. 

Respondents were very interested in the Draft Environmental Impact Statement. They invested considerable time 

and effort to voice their opinions and concerns about managing personal watercraft use on Lake Powell. The 

most commonly addressed themes included Alternatives, Visitor Use, and Visitor Conflicts and Safety. 

The most common issue that was addressed (8,271 comments) by the public was whether the use of 

personal watercraft should be continued within the recreation area. The majority of these commenters 

(98%) supported continued personal watercraft use. 

Nearly 6,700 comments were received related to visitor conflict and safety. Most of these comments 

focused on issues such as boater education and the safety of personal watercraft users if the flat-wake 

zones proposed under alternative B (the preferred alternative in the Draft Environmental Impact 

Statement) were established. 

Comments on the alternatives were largely nonsubstantive in nature and generally supported or opposed 

an alternative. Alternative A received the most support because of one petition that contained more than 

11,000 signatures. 

A process referred to as “content analysis” was used to compile and correlate similar public comments into a 

format useable by NPS decision makers. The content analysis team (comprised of the NPS interdisciplinary 

planning team and the NPS contractor for preparation of this environmental impact statement) read all comments 

and determined which comments would require a response. Pursuant to the National Environmental Policy Act

(NEPA), responses were prepared for all substantive comments, and the content of this Final Environmental 

Impact Statement also demonstrates responsiveness to public input. 

Content analysis was performed in the four steps described below. 
RESPONSES TO SUBSTANTIVE COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT 

ii

Develop a coding structure — Initially, a coding structure was developed to help sort comments into logical 

groups by topics and issues, derived from an analysis of the range of topics covered in the Draft Environmental 

Impact Statement, NPS legal guidance, and the letters themselves. The coding structure used was inclusive rather 

than restrictive; an attempt was made to capture all comment content. The codes were assigned to comments 

within letters, faxes, oral transcripts, meeting comment forms, and electronic mail. 

Create a comment database — For each comment in a correspondence, codes were assigned by one staff person, 

validated by another, and then entered into a database. 

Prepare a narrative summary — The database was used to help construct a narrative summary. Opinions, 

feelings, and preferences of one element or one alternative over another, and comments of personal and 

philosophical nature were all read and analyzed. All comments were considered, whether they were presented by 

thousands of people voicing the same concern or by a single person or organization raising a technical point. 

Read and code public comment letters — After each document was coded, a series of steps were taken to 

determine whether the individual comment was substantive or nonsubstantive, according to the criteria set forth 

in the Council on Environmental Quality regulations. 

Substantive comments are comments that raise an issue regarding law or regulation, agency procedure or 

performance, compliance with stated objectives, validity of impact analyses, or other matters of practical or 

procedural importance. Substantive comments require a response or a corresponding revision in the final 

environmental impact statement text. 

Nonsubstantive comments are comments that offer opinions or provide information not directly related to 

issues or impact analyses. Nonsubstantive comments are used as background information for the 

environmental impact statement team, but do not require a formal response. 

The purpose of reading, coding, and analyzing the contents of the comment letters was to assist the content 

analysis team in determining if the substantive issues raised by the public warranted further modification of the 

alternatives and further analysis of issues and impacts. With the information provided through the public review 

process, the agency reconsidered the draft preferred alternative (alternative B) and developed a “modified 

preferred alternative” (alternative B) as described in the “Alternatives” chapter of volume 1 of this Final 

Environmental Impact Statement. 

Although the content analysis process attempted to capture the full range of public concerns, it is acknowledged 

that comments from people who chose to respond do not necessarily represent the sentiments of the entire 

public. Further, this is not a vote-counting process; emphasis in this process was on the content of the comment 

rather than the number of times a comment was received. 

All comments received can be tracked to the original letter and can be sorted and reported in a variety of ways as 

described below. 

ORGANIZATION OF COMMENTS AND RESPONSES 

Comments and responses are categorized by topics and issues. A topic is a category of subject matter. These 

categories were developed through the scoping process and were selected in order to track major subjects 

through the Draft Environmental Impact Statement. Issues are subdivisions of topics. Each topic was separated 

into several issues to provide a better focus on the content of comments. For example, “Purpose and Need” was 

broken down into six issues, including the scope of the analysis (designated PN 1), park legislation and authority 

(PN 2), current personal watercraft regulatory framework (PN 3), objectives for taking the action (PN 4), issues 

eliminated from further consideration (PN 5), and NPS interpretation of impairment policies and mandates 

(PN 6). 
ORGANIZATION OF COMMENTS AND RESPONSES

iii

After all public comments were entered into the database by issue, substantive issue reports were generated per 

topic and issue. The team analyzed the comments and then grouped comments with similar subject matter in 

order to prepare issue statements that represented all comments in each subject matter group. Some of the more 

detailed comments that were received appear verbatim in this document, while others were summarized, 

reflecting the content of several similar comments. The issue statements were then sent to professionals in the 

respective fields (i.e., Air Quality, Water Quality, Wildlife and Habitat) for analysis and response. The resulting 

issue statement responses were reviewed by the contractor, Environmental Quality Division of the National Park 

Service, and Glen Canyon National Recreation Area interdisciplinary planning team for accuracy and 

completeness. Revisions and additions were made, as needed, and the resulting responses to public comments 

are provided in this document. 

There are two indexes provided in this document and each is described below. 

Index of Comments by Category of Author — The “Author Index” lists businesses, organizations, and public 

agencies that submitted comments. Actual locations in this document of comments/responses by these groups 

can be found by locating the “Index of Comments by Category of Author” (see p. v) to first determine the 

document locator number and then choosing the appropriate topic heading in the Table of Contents. Individual 

members of the public submitted comments that were read, coded, and analyzed as described above. However, 

because of the large number of individuals submitting comments, those comment letters were not categorized by 

author. Authors of individual letters should consult the “Index of Comments by Topic,” as described in the next 

paragraph. The majority of comments received by the National Park Service were form letters. Examples of the 

11 different types of form letters are included at the end of this volume 2. 

Index of Comments by Topic — To locate a response to a representative individual comment, refer to the “Index 

of Comments by Topic” (see p. x) to determine the topic a comment falls under, and then locate the 

comment/response section for that topic in the Table of Contents (see p. xiv). If an individual cannot find a 

representation of his or her comment in this document, the National Park Service can be contacted for a copy of 

the coded letter. All letters received will be kept at the Glen Canyon National Recreation Area headquarters. The 

authors of comments from agencies, businesses, and organizations should also consult this index to review all 

topics and issues of interest. 

References to Volume 1 Within Responses 

Within some responses to comments, readers are directed to a particular section, chapter, table, figure, or 

appendix to find more information about a particular subject. Those referrals pertain specifically to volume 1 of 

this Final Environmental Impact Statement. 
RESPONSES TO SUBSTANTIVE COMMENTS ON THE FINAL ENVIRONMENTAL IMPACT STATEMENT 

iv
v

INDEX OF COMMENT LETTERS BY CATEGORY OF AUTHOR

BUSINESS COMMENT LETTERS

ARAMARK Lake Powell Resorts and Marina - 

01178; Purpose and Need: Current Personal 

Watercraft Regulatory Framework, Recreation 

Area Operations: Enforcement. 

B.B. Financial Benefits Group, Inc. – 00195; 

Alternatives: Alternative C and Visitor Use, 

Personal Watercraft Use within GLCA. 

Charles Gustafson, P.C. Attorney at Law - 00198; 

Alternatives: Alternative C (No Action), 

Purpose and Need: Current Personal Watercraft 

Regulatory Framework, Visitor Use and 

Experience: Impacts of Personal Watercraft 

Use, Purpose and Need: NPS Interpretation of 

Impairment Policies & Mandates. 

Chiropractic Associates, Inc. - 00616; Purpose and 

Need: Park Legislation/Authority. 

Desert Phantom Inc. - 00763; Visitor Use and 

Experience: Impacts of Personal Watercraft 

Use. 

Lake Powell Waterworld - 00390; Socioeconomics: 

Impacts from Personal Watercraft Restriction, 

General Assumptions Used for Analysis: 

Personal Watercraft Use Trends and 

Assumptions. 

Steadman's Recreation Inc. - 01190; Purpose and 

Need: Current Personal Watercraft Regulatory 

Framework, Visitor Use and Experience: 

Impacts of Personal Watercraft Use. 

TAB Associates, Inc. - 00295; Alternatives: 

Alternative B (Preferred Alternative), 

Recreation Area Operations: Enforcement, 

General Assumptions Used for Analysis: 

Personal Watercraft Use Trends and 

Assumptions. 
vi

ORGANIZATION COMMENT LETTERS

American Canoe Association, Inc. - 01168; Visitor 

Conflicts and Safety: Affected Environment, 

Alternatives: Alternative A, Alternatives: 

Alternative B (Preferred Alternative), 

Alternatives: Environ. Preferred Alt./NEPA 

Section 101 & 102, Miscellaneous Topics: 

General Comments-Miscellaneous Topics, 

Threatened and Endangered Species: Impacts of 

Personal Watercraft Use, Visitor Use and 

Experience: Impacts of Personal Watercraft 

Use, Wildlife and Wildlife Habitat: Impacts of 

Personal Watercraft Use, Alternatives: New 

Alternatives or Elements. 

American Watercraft Association - 01175; 

Alternatives: Alternative B (Preferred 

Alternative), Purpose and Need: Current 

Personal Watercraft Regulatory Framework, 

Visitor Conflicts and Safety: Impacts from 

Other Vessels, Socioeconomics: Impacts from 

Personal Watercraft Restriction, Purpose and 

Need: Scope of the Analysis. 

Blue Ribbon Coalition - 01228; Socioeconomics: 

Affected Environment, Visitor Use and 

Experience: Affected Environment, Air Quality: 

Methodology and Assumptions, General 

Assumptions Used for Analysis: Personal 

Watercraft Use Trends and Assumptions, 

Soundscapes: Regulations, Methodologies and 

Assumptions. 

Bluewater Network - 01002; Visitor Conflicts and 

Safety: Affected Environment, Soundscapes: 

Affected Environment, Wildlife and Wildlife 

Habitat: Affected Environment, Water Quality: 

Affected Environment, Socioeconomics: 

Affected Environment, Threatened and 

Endangered Species: Affected Environment, Air 

Quality: Affected Environment, Visitor Use and 

Experience: Affected Environment, 

Alternatives: Alternative C (No Action), 

Purpose and Need: Current Personal Watercraft 

Regulatory Framework, Consultation and 

Coordination: General Comments, Other NEPA 

Issues: General Comments, General 

Assumptions Used for Analysis: General 

Methodology for Establishing Impacts/Effects, 

Air Quality: Human Health Impacts from 

Personal Watercraft from Airborne Pollutants, 

Soundscapes: Impacts of Personal Watercraft 

Use, Visitor Use and Experience: Impacts of 

Personal Watercraft Use, Wildlife and Wildlife 

Habitat: Impacts of Personal Watercraft Use, 

Water Quality: Impacts on Water Quality from 

Personal Watercraft Use, Socioeconomics: 

Methodology and Assumptions, Air Quality: 

Methodology and Assumptions, Purpose and 

Need: NPS Interpretation of Impairment 

Policies & Mandates, Purpose and Need: Park 

Legislation/Authority, General Assumptions 

Used for Analysis: Personal Watercraft Use 

Trends and Assumptions, Visitor Use: Personal 

Watercraft Use within GLCA, Visitor Use and 

Experience: Regulations, Methodologies and 

Assumptions, Soundscapes: Regulations, 

Methodologies and Assumptions, Water 

Quality: Regulations, Methodologies and 

Assumptions, Wildlife and Wildlife Habitat: 

Regulations, Methodologies and Assumptions, 

Visitor Conflicts and Safety: Regulations, 

Methodologies, and Assumptions, Purpose and 

Need: Scope of the Analysis. 

Escalante Wilderness Project - 01197; Alternatives: 

Alternative C (No Action), Soundscapes: 

Impacts of Personal Watercraft Use, Water 

Quality: Impacts on Water Quality from 

Personal Watercraft Use, Visitor Use: Personal 

Watercraft Use within GLCA. 

Living Rivers - 01174; Alternatives: Alternatives 

Eliminated, Alternatives: Elements Common to 

All Alternatives, Alternatives: Environ. 

Preferred Alt./NEPA Section 101 & 102, 

Alternatives: New Alternatives or Elements, 

Purpose and Need: NPS Interpretation of 

Impairment Policies & Mandates, Purpose and 

Need: Park Legislation/Authority, General 

Assumptions Used for Analysis: Personal 

Watercraft Use Trends and Assumptions. 

Multiple Access Conservation Coalition - 00209; 

Alternatives: Alternative A, Alternatives: 

Alternative B (Preferred Alternative), 

Socioeconomics: Economic Impact Analysis, 

Visitor Use and Experience: Impacts of 

Personal Watercraft Use, Alternatives: New 

Alternatives or Elements. 

National Marine Manufacturers Association - 01176; 

Alternatives: Alternative B (Preferred 

Alternative), Visitor Conflicts and Safety: 

Impacts from Other Vessels, Purpose and Need: 

Scope of the Analysis. 

National Park Conservation Association - 01248; 

Alternatives: Alternative B (Preferred 

Alternative), Alternatives: Alternative C (No 

Action), Visitor Conflicts and Safety: Impacts 

of Personal Watercraft Use, Visitor Use and 

Experience: Impacts of Personal Watercraft 

Use, Purpose and Need: Park 
ORGANIZATION COMMENT LETTERS

vii

Legislation/Authority, Visitor Use: Personal Watercraft Use within NPS units

North American Wild Sheep Utah Chapter - 01286; 

Air Quality: Methodology and Assumptions, 

Water Quality: Regulations, Methodologies and 

Assumptions. 

Page-Lake Powell Chamber of Commerce and 

Visitor Bureau - 01191; Socioeconomics: 

Impacts from Personal Watercraft Restriction. 

Personal Watercraft Industry Association and 

Members - 01344; Wildlife and Wildlife 

Habitat: Affected Environment, Soundscapes: 

Affected Environment, Shoreline/Submerged 

Aquatic Vegetation: Affected Environment, 

Alternatives: Alternative B (Preferred 

Alternative), Purpose and Need: Current 

Personal Watercraft Regulatory Framework, 

Recreation Area Operations: Enforcement, 

Miscellaneous Topics: General CommentsMiscellaneous Topics, General Assumptions 

Used for Analysis: General Methodology for 

Establishing Impacts/Effects, Soundscapes: 

Impact from Other Vessels, Socioeconomics: 

Impacts from Personal Watercraft Restriction, 

Visitor Conflicts and Safety: Impacts of 

Personal Watercraft Use, Cultural Resources: 

Impacts from Visitor Access and Other 

Watercraft, Air Quality: Impacts on Air Quality 

Related Values (visibility, vegetation), Water 

Quality: Impacts on Water Quality from 

Personal Watercraft Use, Air Quality: 

Methodology and Assumptions, Soundscapes: 

Regulations, Methodologies and Assumptions, 

Water Quality: Regulations, Methodologies and 

Assumptions, Purpose and Need: Scope of the 

Analysis. 

River Runners for Wilderness – 01179; Alternatives: 

Alternative C (No Action); Visitor Use and 

Experience: Impacts of Personal Watercraft 

Use; Visitor Use: Personal Watercraft Use 

within NPS Units; Wildlife and Wildlife 

Habitat: Impacts of Personal Watercraft Use. 

Sierra Club - 01391; Visitor Use and Experience: 

Affected Environment, Soundscapes: 

Cumulative, Soundscapes: Impacts of Personal 

Watercraft Use, Alternatives: New Alternatives 

or Elements, General Assumptions Used for 

Analysis: Personal Watercraft Use Trends and 

Assumptions, Soundscapes: Regulations, 

Methodologies and Assumptions. 

Sierra Club, Grand Canyon Chapter - 01266; 

Alternatives: New Alternatives or Elements. 

Sierra Club Utah Chapter - 01245; Soundscapes: 

Affected Environment, Alternatives: 

Alternatives Eliminated, Visitor Use and 

Experience: Cumulative, Socioeconomics: 

Economic Impact Analysis, Other NEPA 

Issues: General Comments, General 

Assumptions Used for Analysis: General 

Methodology for Establishing Impacts/Effects, 

Visitor Use and Experience: Impacts of 

Personal Watercraft Use, Alternatives: New 

Alternatives or Elements, Purpose and Need: 

Park Legislation/Authority, Visitor Use and 

Experience: Regulations, Methodologies and 

Assumptions, Purpose and Need: Scope of the 

Analysis. 

Utah Shared Access Alliance (USA-ALL) - 01239; 

Water Quality: Affected Environment, Visitor 

Conflicts and Safety: Affected Environment, 

Alternatives: Alternative A, Alternatives: 

Alternative B (Preferred Alternative), 

Alternatives: Alternative C (No Action), 

Recreation Area Operations: Enforcement, 

Recreation Area Operations: Impacts of 

Personal Watercraft Use, Shoreline/Submerged 

Aquatic Vegetation: Impacts of Personal 

Watercraft Use, Visitor Use and Experience: 

Impacts of Personal Watercraft Use, Purpose 

and Need: Objectives in Taking Action, Purpose 

and Need: Park Legislation/Authority, Water 

Quality: Regulations, Methodologies and 

Assumptions. 
viii

PUBLIC AGENCY COMMENT LETTERS

Arizona State Parks/SHPO - 00194; Alternatives: 

Alternative B (Preferred Alternative), Visitor 

Use: Personal Watercraft Use within GLCA. 

County Commission Chairman - 00056; Alternatives: 

New Alternatives or Elements, Visitor Use: 

Personal Watercraft Use within GLCA. 

Region 8 US Environmental Protection Agency - 

01393; Visitor Use and Experience: Affected 

Environment, Water Quality: Affected 

Environment, Alternatives: Alternative B 

(Preferred Alternative), Alternatives: 

Alternative C (No Action), Alternatives: 

Alternatives Eliminated, Alternatives: Elements 

Common to All Alternatives, Alternatives: 

Environ. Preferred Alt./NEPA Section 101 & 

102, Other NEPA Issues: General Comments, 

General Assumptions Used for Analysis: 

General Methodology for Establishing 

Impacts/Effects, Soundscapes: Impacts of 

Personal Watercraft Use, Air Quality: Impacts 

on Air Quality Related Values (visibility, 

vegetation), Water Quality: Impacts on Water 

Quality from Personal Watercraft Use, Air 

Quality: Methodology and Assumptions, 

Alternatives: New Alternatives or Elements, 

General Assumptions Used for Analysis: 

Personal Watercraft Use Trends and 

Assumptions, Water Quality: Regulations, 

Methodologies and Assumptions. 

State of Utah Department of Natural Resources 

Division of Parks and Recreation - 01170; 

Alternatives: Alternative B (Preferred 

Alternative), Visitor Conflicts and Safety: 

Boater Education, Purpose and Need: Current 

Personal Watercraft Regulatory Framework, 

Miscellaneous Topics: General CommentsMiscellaneous Topics, Socioeconomics: 

Impacts from Personal Watercraft Restriction, 

Socioeconomics: Methodology and 

Assumptions, Visitor Use: Personal Watercraft 

Use within GLCA. 

US Fish and Wildlife Service - Utah Field Office - 

01137; Wildlife and Wildlife Habitat: Affected 

Environment, Water Quality: Affected 

Environment, Threatened and Endangered 

Species: Impacts of Personal Watercraft Use, 

Alternatives: New Alternatives or Elements, 

Water Quality: Regulations, Methodologies and 

Assumptions.
ix

FORM LETTERS

EXAMPLES OF FORM LETTERS SUBMITTED

Cook, Jim — 00299 (Form 10) 

Fasulkey, Robert — 00013 (Form 2) 

Fields, John — 00243 (Form 7) 

Green, Jacqueline P. — 00322 (Form 4) 

Hawkins, Derrell — 01316 (Form 11) 

Jensen, Lou and Carol — 00318 (Form 5) 

Mabes, Kelli — 00221 (Form 6) 

Penner, Eric — 00630 (Form 9) 

Peterson, Kimberly — 00009 (Form 3) 

Stutz, Anne — 00492 (Form 8) 

Thompson, Kevin — 00002 (Form 1) 
x

INDEX OF COMMENTERS BY TOPIC

AIR QUALITY PAGE 3

Affected Environment 

Bluewater Network — 01002 

Human Health Impacts from Personal Watercraft 

from Airborne Pollutants 

Bluewater Network — 01002 

Impacts on Air Quality Related Values (visibility, 

vegetation) 

Personal Watercraft Industry Association 

and Members — 01344 

Region 8 US Environmental Protection 

Agency — 01393 

Methodology and Assumptions 

Blue Ribbon Coalition — 01228 

Bluewater Network — 01002 

North American Wild Sheep Utah Chapter — 

01286 

Personal Watercraft Industry Association 

and Members — 01344 

Region 8 US Environmental Protection 

Agency — 01393 

ALTERNATIVES PAGE 13

Alternative A 

American Canoe Association, Inc. — 01168 

Multiple Access Conservation Coalition — 

00209 

Utah Shared Access Alliance (USA-ALL) — 

01239 

Alternative B (Preferred Alternative) 

American Canoe Association, Inc. — 01168 

American Watercraft Association — 01175 

Arizona State Parks/SHPO — 00194 

Multiple Access Conservation Coalition — 

00209 

National Marine Manufacturers Association — 

01176 

National Park Conservation Association — 

01248 

Personal Watercraft Industry Association 

and Members — 01344 

Region 8 US Environmental Protection 

Agency — 01393 

State of Utah Department of Natural Resources 

Division of Parks and Recreation — 01170 

TAB Associates, Inc. — 00295 

Utah Shared Access Alliance (USA-ALL) — 

01239 

Alternative C (No Action) 

Bluewater Network — 01002 

Charles Gustafson, P.C. Attorney at Law — 

00198 

Escalante Wilderness Project — 01197 

National Park Conservation Association — 

01248 

Region 8 US Environmental Protection 

Agency — 01393 

Utah Shared Access Alliance (USA-ALL) — 

01239 

Alternatives Eliminated 

Living Rivers — 01174 

Region 8 US Environmental Protection 

Agency — 01393 

Sierra Club Utah Chapter — 01245 

Elements Common to all alternatives 

Living Rivers — 01174 

Region 8 US Environmental Protection 

Agency — 01393 

Environmentally Preferred Alternative/NEPA 

Section 101 & 102 

American Canoe Association — 01168 

Living Rivers — 01174 

Region 8 US Environmental Protection 

Agency — 01393 

New Alternatives or Elements 

American Canoe Association, Inc. — 01168 

County Commission Chairman — 00056 

Living Rivers — 01174 

Multiple Access Conservation Coalition — 

00209 

Region 8 US Environmental Protection 

Agency — 01393 

Sierra Club, Grand Canyon Chapter — 01266 

Sierra Club — 01391 

Sierra Club Utah Chapter — 01245 

US Fish and Wildlife Service — Utah Field 

Office — 01137 
INDEX OF COMMENTERS BY TOPIC

xi

CONSULTATION 

AND COORDINATION PAGE 25

General Comments 

Bluewater Network — 01002 

CULTURAL RESOURCES PAGE 26

Impacts from Visitor Access and Other 

Watercraft 

Personal Watercraft Industry Association and 

Members — 01344 

GENERAL ASSUMPTIONS 

USED FOR ANALYSIS PAGE 27

General Methodology for Establishing 

Impacts/Effects 

Bluewater Network — 01002 

Personal Watercraft Industry Association and 

Members — 01344 

Region 8 US Environmental Protection 

Agency — 01393 

Sierra Club Utah Chapter — 01245 

Personal Watercraft Use Trends and Assumptions 

Blue Ribbon Coalition — 01228 

Bluewater Network — 01002 

Lake Powell Waterworld — 00390 

Living Rivers — 01174 

Region 8 US Environmental Protection 

Agency — 01393 

Sierra Club — 01391 

TAB Associates, Inc. — 00295 

OTHER NEPA ISSUES PAGE 29

General Comments 

Bluewater Network — 01002 

Region 8 US Environmental Protection 

Agency — 01393 

Sierra Club Utah Chapter — 01245 

PURPOSE AND NEED PAGE 31

Current Personal Watercraft Regulatory 

Framework 

American Watercraft Association, Inc. — 

01175 

ARAMARK Lake Powell Resorts and Marina 

— 01178 

Bluewater Network — 01002 

Charles Gustafson, P.C. Attorney at Law — 

00198 

Personal Watercraft Industry Association and 

Members — 01344 

State of Utah Department of Natural Resources 

Division of Parks and Recreation — 01170 

Steadman's Recreation Inc. — 01190 

NPS Interpretation of Impairment Policies & 

Mandates 

Bluewater Network — 01002 

Charles Gustafson, P.C. Attorney at Law — 

00198 

Living Rivers — 01174 

Objectives in Taking Action 

Utah Shared Access Alliance (USA-ALL) — 

01239 

Park Legislation/Authority 

Bluewater Network — 01002 

Chiropractic Associates, Inc. — 00616 

Living Rivers — 01174 

National Park Conservation Association — 

01248 

Sierra Club Utah Chapter — 01245 

Utah Shared Access Alliance (USA-ALL) — 

01239 

Scope of the Analysis 

American Watercraft Association, Inc. — 

01175 

Bluewater Network — 01002 

National Marine Manufacturers Association — 

01176 

Personal Watercraft Industry Association and 

Members — 01344 

Sierra Club Utah Chapter — 01245 

RECREATION AREA 

OPERATIONS PAGE 44

Enforcement 

ARAMARK Lake Powell Resorts and Marina 

— 01178 

Personal Watercraft Industry Association and 

Members — 01344 

TAB Associates, Inc. — 00295 

Utah Shared Access Alliance (USA-ALL) — 

01239 

Impacts of Personal Watercraft Use 

Utah Shared Access Alliance (USA-ALL) — 

01239 
RESPONSES TO SUBSTANTIVE COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT

xii

SHORELINE/SUBMERGED

AQUATIC VEGETATION PAGE 47

Affected Environment 

Personal Watercraft Industry Association and 

Members — 01344 

Impacts of Personal Watercraft Use 

Utah Shared Access Alliance (USA-ALL) — 

01239 

SOCIOECONOMICS PAGE 50

Affected Environment 

Blue Ribbon Coalition — 01228 

Bluewater Network — 01002 

Economic Impact Analysis 

Multiple Access Conservation Coalition — 

00209 

Sierra Club Utah Chapter — 01245 

Impacts from Personal Watercraft Restriction 

American Watercraft Association, Inc. — 

01175 

Lake Powell Waterworld — 00390 

Page-Lake Powell Chamber of Commerce and 

Visitor Bureau — 01191 

Personal Watercraft Industry Association and 

Members — 01344 

State of Utah Department of Natural Resources 

Division of Parks and Recreation — 01170 

Methodology and Assumptions 

Bluewater Network — 01002 

State of Utah Department of Natural Resources 

Division of Parks and Recreation — 01170 

SOUNDSCAPES PAGE 54

Affected Environment 

Bluewater Network — 01002 

Personal Watercraft Industry Association and 

Members — 01344 

Sierra Club Utah Chapter — 01245 

Cumulative Effects 

Sierra Club — 01391 

Impact from Other Vessels 

Personal Watercraft Industry Association and 

Members — 01344 

Impacts of Personal Watercraft Use 

Bluewater Network — 01002 

Escalante Wilderness Project — 01197 

Region 8 US Environmental Protection 

Agency — 01393 

Sierra Club — 01391 

Regulations, Methodologies and Assumptions 

Blue Ribbon Coalition — 01228 

Bluewater Network — 01002 

Personal Watercraft Industry Association and 

Members — 01344 

Sierra Club — 01391 

THREATENED

AND ENDANGERED SPECIES PAGE 68

Affected Environment 

Bluewater Network — 01002 

Impacts of Personal Watercraft Use 

American Canoe Association, Inc. — 01168 

US Fish and Wildlife Service - Utah Field 

Office — 01137 

VISITOR

CONFLICTS AND SAFETY PAGE 71

Affected Environment 

American Canoe Association, Inc. — 01168 

Bluewater Network — 01002 

Utah Shared Access Alliance (USA-ALL) — 

01239 

Boater Education 

State of Utah Department of Natural Resources 

Division of Parks and Recreation — 01170 

Impacts from Other Vessels 

American Watercraft Association, Inc. — 

01175 

National Marine Manufacturers Association — 

01176 

Impacts of Personal Watercraft Use 

National Park Conservation Association — 

01248 

Personal Watercraft Industry Association and 

Members — 01344 

Regulations, Methodologies, and Assumptions 

Bluewater Network — 01002 
INDEX OF COMMENTERS BY TOPIC

xiii

VISITOR USE 

AND EXPERIENCE PAGE 76

Affected Environment 

Blue Ribbon Coalition — 01228 

Bluewater Network — 01002 

Region 8 US Environmental Protection 

Agency — 01393 

Sierra Club — 01391 

Cumulative Effects 

Sierra Club Utah Chapter — 01245 

Impacts of Personal Watercraft Use 

American Canoe Association, Inc. — 01168 

Bluewater Network — 01002 

Charles Gustafson, P.C. Attorney at Law — 

00198 

Desert Phantom, Inc. — 00763 

Multiple Access Conservation Coalition — 

00209 

National Park Conservation Association — 

01248 

Sierra Club Utah Chapter — 01245 

Steadman's Recreation Inc. — 01190 

Utah Shared Access Alliance (USA-ALL) — 

01239 

Regulations, Methodologies and Assumptions 

Bluewater Network — 01002 

Sierra Club Utah Chapter — 01245 

WATER QUALITY PAGE 83

Affected Environment 

Bluewater Network — 01002 

Region 8 US Environmental Protection 

Agency — 01393 

US Fish and Wildlife Service - Utah Field 

Office — 01137 

Utah Shared Access Alliance (USA-ALL) — 

01239 

Impacts on Water Quality from Personal 

Watercraft Use 

Bluewater Network — 01002 

Escalante Wilderness Project — 01197 

Personal Watercraft Industry Association and 

Members — 01344 

Region 8 US Environmental Protection 

Agency — 01393 

Regulations, Methodologies and Assumptions 

Bluewater Network — 01002 

North American Wild Sheep Utah Chapter — 

01286 

Personal Watercraft Industry Association and 

Members — 01344 

Region 8 US Environmental Protection 

Agency — 01393 

US Fish and Wildlife Service - Utah Field 

Office — 01137 

Utah Shared Access Alliance (USA-ALL) — 

01239 

WILDLIFE AND 

WILDLIFE HABITAT PAGE 98

Affected Environment 

Bluewater Network — 01002 

Personal Watercraft Industry Association and 

Members — 01344 

US Fish and Wildlife Service - Utah Field 

Office — 01137 

Impacts of Personal Watercraft Use 

American Canoe Association, Inc. — 01168 

Bluewater Network — 01002 

Regulations, Methodologies and Assumptions 

Bluewater Network — 01002 
RESPONSES TO SUBSTANTIVE COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT

xiv
xv

CONTENTS

Air Quality 

Affected Environment .................................................................................................................................... 3 

Issue 1: Inadequate Data Collection and Monitoring ...................................................................... 3 

Impacts to Human Health and Air Quality Related Values (Visibility and Vegetation) from 

Personal Watercraft ................................................................................................................................. 4 

Issue 1: General Impacts of Personal Watercraft on Air Quality .................................................... 4 

Issue 2: Polycyclic Aromatic Hydrocarbon Concentrations from Personal Watercraft 

Use at Glen Canyon National Recreation Area Do Not Pose Any Health Risks ............... 5 

Issue 3: Nitrogen Oxide Emissions ................................................................................................. 5 

Issue 4: The Draft Environmental Impact Statement Underestimates the Reduction of 

Personal Watercraft Emissions Over Time ........................................................................ 5 

Impacts from Other Vessels............................................................................................................................ 8 

Issue 1: General Comments About Impacts on Air Quality From Other Vessels ........................... 8 

Methodology and Assumptions ...................................................................................................................... 9 

Issue 1: Derivation of Engine Load................................................................................................. 9 

Issue 2: Inconsistent Estimates Between Water and Air Quality Analysis...................................... 9 

Issue 3: Include Updated Evaporative Standards Proposed by the Environmental 

Protection Agency............................................................................................................ 10

Issue 4: The Draft Environmental Impact Statement Fails to Mention the Impact of 

Personal Watercraft Permeation Losses........................................................................... 10 

Issue 5: The Research on Air Quality Effects of Personal Watercraft Emissions Presented 

in the Draft Environmental Impact Statement Is Not Applicable to New 

Engine Technology .......................................................................................................... 11 

Alternatives

Alternative B (Modified Preferred Alternative)............................................................................................ 12 

Issue 1: Alternative B with Changes ............................................................................................. 12 

Issue 2: Lake Management Plan Should not be an Element of Alternatives ................................. 13 

Issue 3: Monitoring Plan as an Element of Alternative B ............................................................. 13 

Issue 4: Encourage Coordination with Two States to Develop Uniform Laws ............................. 14 

Alternative C (No Action) ............................................................................................................................ 15 

Issue 1: Phase Out Two-Stroke Personal Watercraft Engines and Eventually Replace 

with Four-Stroke Technology .......................................................................................... 15 

Alternatives Eliminated ................................................................................................................................ 16 

Issue 1: Insufficient Justification for Eliminating Alternatives ..................................................... 16 

Elements Common to All Alternatives......................................................................................................... 17 

Issue 1: Lake Management Plan Should be a Component of all Alternatives............................... 17 

Environmentally Preferred Alternative/NEPA Sections 101 and 102 .......................................................... 18 

Issue 1: Alternative B Should Not Be Environmentally Preferred Alternative ............................. 18 

New Alternatives or Elements ...................................................................................................................... 19 

Issue 1: Additional Strategies for Personal Watercraft Management............................................ 19 

Issue 2: Additional Personal Watercraft Restrictions.................................................................... 19 

Issue 3: Ban Two-Stroke Engines and Allow only Four-Stroke or Direct-Injection Engines ....... 20 

Issue 4: Make Canyons Flat-Wake Zones ..................................................................................... 21 

Issue 5: New Alternative Incorporating Education, Enforcement, and Stricter Regulations......... 21 
RESPONSES TO SUBSTANTIVE COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT

xvi

Issue 6: Consider Wilderness in the Analysis of Personal Watercraft Management..................... 21 

Issue 7: Reconsider Personal Watercraft use Restriction on the Rivers ........................................ 22 

Issue 8: Permit Personal Watercraft that Meet a “Quiet Standard” ............................................... 22 

Issue 9: Inadequate Range of Alternatives .................................................................................... 23

Consultation and Coordination

General Comments ....................................................................................................................................... 24 

Issue 1: Request to Add Letters to Administrative Record ........................................................... 24 

Issue 2: Jet Ski and Boat Users Should Have Been Notified about Proposed 

Personal Watercraft Management at Glen Canyon .......................................................... 24 

Cultural Resources

Impacts from Visitor Access and Other Watercraft...................................................................................... 25 

Issue 1: Access to Areas of Cultural Significance Should be Restricted....................................... 25 

General Assumptions Used for Analysis

Personal Watercraft Use Trends and Assumptions....................................................................................... 26 

Issue 1: Unsubstantiated Personal Watercraft Use Assumption.................................................... 26 

Other NEPA Issues

General Comments ....................................................................................................................................... 28 

Issue 1: The National Park Service Is Headed for a Predetermined Outcome............................... 28 

Issue 2: The Draft Environmental Impact Statement Fails to Complete the 

Requirements of National Environmental Policy Act for Completing an 

Environmental Impact Statement ..................................................................................... 28 

Issue 3: Inclusion of Mitigation Measures with Alternatives per NEPA and 

CEQ Requirements........................................................................................................... 29 

Purpose and Need

Current Personal Watercraft Regulatory Framework ................................................................................... 30 

Issue 1: Compliance with Bluewater Network Court Settlement .................................................. 30 

Issue 2: Prescribing Personal Watercraft Use under the Superintendent’s 

Compendium Was Appropriate........................................................................................ 30 

NPS Interpretation of Impairment Policies & Mandates .............................................................................. 32 

Issue 1: Compliance with NPS Director’s Orders ......................................................................... 32 

Issue 2: Continued Personal Watercraft Use is in Violation of Federal Laws and Policies .......... 33 

Issue 3: Recreational Opportunities and the Protection of Resources ........................................... 34 

Park Legislation/Authority ........................................................................................................................... 35 

Issue 1: Restricting Personal Watercraft Conflicts with Agency’s Mandate to 

Maximize Recreational Use ............................................................................................. 35 

Issue 2: Restricting Personal Watercraft Conflicts with Agency’s Mandate to 

Maximize Recreational Use ............................................................................................. 35 

Issue 3: Protection of Resources under the Recreation Area’s Enabling Legislation 

and General Management Plan ........................................................................................ 36 

Issue 4: Potential Conflicts with General Management Plan......................................................... 38 

Scope of the Analysis ................................................................................................................................... 40 

Issue 1: Rainbow Bridge National Monument Should be Included in the Analysis...................... 40 

Issue 2: Why Is the Focus on Personal Watercraft? ...................................................................... 40 

Issue 3: Personal Watercraft Should Not Be Singled Out for Regulation ..................................... 40 

Issue 4: Personal Watercraft Can Be Singled Out for Regulation................................................. 42 
CONTENTS

xvii

Recreation Area Operations

Enforcement.................................................................................................................................................. 43 

Issue 1: Enforce the Existing Sound Standard............................................................................... 43 

Issue 2: Park Service Should Enforce Regulations such as Speed Limits on the Lake ................. 43 

Issue 3: Cooperation with Other Agencies .................................................................................... 43 

Impacts of Personal Watercraft Use ............................................................................................................. 44 

Issue 1: Additional Restrictions will Dilute Law Enforcement Effectiveness............................... 44 

Issue 2: Increase Monitoring of the Type of Watercraft Entering the Recreation Area ................ 44 

Issue 3: Visitation Effects on Recreation Area Operations ........................................................... 45 

Shoreline/Submerged Aquatic Vegetation

Affected Environment .................................................................................................................................. 46 

Issue 1: General Impacts of Personal Watercraft on Shoreline and Submerged 

Aquatic Vegetation........................................................................................................... 46

Impacts of Personal Watercraft Use ............................................................................................................. 47 

Issue 1: Impacts on Shoreline Vegetation from Waves Generated by Personal Watercraft.......... 47 

Issue 2: Inadequacy of Data to Support Statements that Personal Watercraft Use 

Impacts Submerged Aquatic Vegetation.......................................................................... 47 

Socioeconomics

Affected Environment .................................................................................................................................. 49 

Issue 1: Economic Analysis Does Not Take into Account the Economic Cost of Noise .............. 49 

Economic Impact Analysis ........................................................................................................................... 50 

Issue 1: Long-Term Economic Consequences of a Personal Watercraft Ban Are Inaccurate....... 50 

Impacts from Personal Watercraft Restriction.............................................................................................. 51 

Issue 1: The Long-term Economic Effects of a Personal Watercraft Ban Will Be Adverse ......... 51 

Issue 2: The Economic Effects of a Ban on Personal Watercraft Are Overstated......................... 51 

Issue 3: The Economic Effects of a Personal Watercraft Ban Will Go Beyond the 

Local Economy ................................................................................................................ 51

Issue 4: The Full Economic Effect of a Ban on Personal Watercraft Is Not Presented................. 52 

Soundscapes 

Affected Environment .................................................................................................................................. 53 

Issue 1: Level Time History Graph Does Not Cite Distance......................................................... 53 

Issue 2: Noise Data Indicates Violation of Utah Law ................................................................... 53 

Issue 3: Natural Ambient Sound Level Not Adequate .................................................................. 53 

Issue 4: Incorrect or Inadequate Analysis of Noise Impacts.......................................................... 54 

Issue 5: The Effects on “Biophony” Were Not Considered in the Draft Environmental 

Impact Statement.............................................................................................................. 54 

Cumulative Effects ....................................................................................................................................... 56 

Issue 1: The Draft Environmental Impact Statement Does Not Adequately Analyze 

Cumulative Effects in the “Soundscapes” Section........................................................... 56 

Impact from Other Vessels ........................................................................................................................... 57 

Issue 1: Concern That Personal Watercraft Were Singled Out for Restrictions............................ 57 

Impacts of Personal Watercraft Use ............................................................................................................. 58 

Issue 1: Suggest Implementing a Curfew on Personal Watercraft Use ......................................... 58 

Issue 2: There Is Concern Over Comparison to Residential Noise Levels.................................... 58 
RESPONSES TO SUBSTANTIVE COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT

xviii

Issue 3: What Would be the Percent Time Audible for Personal Watercraft Under 

Each Alternative? ............................................................................................................. 58 

Issue 4: Fluctuations in Personal Watercraft Noise Is Not Analyzed Adequately......................... 59 

Regulations, Methodologies and Assumptions............................................................................................. 60 

Issue 1: Personal Watercraft Exceed Noise Standards .................................................................. 60 

Issue 2: The Area Where the Noise Regulations Will Be Enforced Is Presumably Far 

Less Than the Area Where the Noise Pollution Will Make the Most 

Significant Impact ............................................................................................................ 60 

Issue 3: The National Park Service Should Conduct a Soundscape Study at Glen 

Canyon National Recreation Area Comparable to the Zion National Park Study............ 60 

Issue 4: Wilderness Management and Natural Zone Goals Were Not Properly Considered 

in the Draft Environmental Impact Statement.................................................................. 61 

Issue 5: Request for Median Quiet Intervals ................................................................................. 62 

Issue 6: The Soundscape Analysis Should Fully Assess Aircraft Noise Contribution 

to Soundscapes................................................................................................................. 62 

Issue 7: A Soundscape Baseline Without Watercraft Noise Needs to be Developed.................... 63 

Issue 8: There Is a Need for a Soundscape Management Plan and Lake Management 

Plan at Glen Canyon National Recreation Area ............................................................... 63 

Issue 9: What Is Human Threshold of Hearing for Watercraft-Specific Frequencies? ................. 63 

Issue 10: A Noise Analysis Should Be Conducted in September When Personal Watercraft 

Use Peaks ......................................................................................................................... 64 

Issue 11: Aircraft Noise Is Not Considered in the Definition of Negligible Impact 

to Soundscapes................................................................................................................. 64 

Issue 12: Lack of Quantitative Definitions for Soundscape Impact Thresholds and 

Impairment Definition...................................................................................................... 64 

Issue 13: A Report Entitled “Drowning in Noise” Was Not Applied in the Draft 

Environmental Impact Statement ..................................................................................... 65 

Issue 14: Additional Information Regarding Personal Watercraft Noise Abatement 

Technology and Design Needs to be Added to the Final Environmental 

Impact Statement.............................................................................................................. 65 

Threatened and Endangered Species

Impacts of Personal Watercraft Use ............................................................................................................. 67 

Issue 1: Personal Watercraft Use May Impact Critical Habitat..................................................... 67 

Issue 2: Incomplete Assessment of Impacts on Wildlife and Certain Threatened 

and Endangered Species................................................................................................... 68 

Regulations, Methodologies, and Assumptions............................................................................................ 69 

Issue 1: Lack of Site-Specific Data ............................................................................................... 69 

Visitor Conflicts and Safety

Affected Environment .................................................................................................................................. 70 

Issue 1: National Safety Data Not Adequately Assessed .............................................................. 70 

Issue 2: Draft Environmental Impact Statement Does Not Address Higher Rate of 

Personal Watercraft Fires and Explosions........................................................................ 71 

Boater Education .......................................................................................................................................... 72 

Issue 1: Lake Permit and Education Should be Mandatory........................................................... 72 

Impacts from Other Vessels.......................................................................................................................... 73 

Issue 1: Flat-Wake Areas for Only One Class of Watercraft Are Unsafe ..................................... 73 

Impacts of Personal Watercraft Use ............................................................................................................. 74 
CONTENTS

xix

Issue 1: Concerns with the Draft Environmental Impact Study Evaluation of Personal 

Watercraft Safety Issues................................................................................................... 74 

Visitor Use and Experience

Affected Environment .................................................................................................................................. 75 

Issue 1: Survey Concerning Visitor Satisfaction Doesn’t Take Into Consideration 

People Who Don’t Recreate at Glen Canyon National Recreation Area Due 

to Motorized Activity....................................................................................................... 75 

Issue 2: Concerns with Draft Environmental Impact Statement Evaluation of Personal 

Watercraft Safety Issues................................................................................................... 75 

Issue 3: Additional Information Needed on the Natural Zone and the Recreational 

and Resource Utilization Zone......................................................................................... 76 

Impacts of Personal Watercraft Use ............................................................................................................. 77 

Issue 1: Alternative B Denies the Public Use and Enjoyment of River Tributaries, and 

Restrictions Are Not Justified Based on the Level of Use ............................................... 77 

Issue 2: Protection of Resources Under the Recreation Area’s Enabling Legislation 

and General Management Plan ........................................................................................ 77 

Issue 3: There Is Inadequate Data on Perceptions of Nonmotorized Watercraft Users................. 77 

Issue 4: Conclusions Drawn from University of Minnesota Study Are Incorrect. It Does 

Not Include a National Sample and Underestimates Public’s Perception of 

Personal Watercraft Impact.............................................................................................. 78 

Regulations, Methodologies, and Assumptions............................................................................................ 79 

Issue 1: Assumptions that Personal Watercraft Use Would be Replaced by Other 

Watercraft Use Is Unsubstantiated and Visitors Using More Than One Type 

of Watercraft Were Not Counted Twice .......................................................................... 79 

Issue 2: Personal Watercraft Ban Does Not Automatically Lead to Decrease in Use................... 79 

Issue 3: Provide an Explanation of How Estimates of Personal Watercraft Use in the 

Tributaries Were Derived................................................................................................. 80 

Issue 4: Need to Evaluate the Effects of Personal Watercraft on Nonmotorized Users ................ 80 

Water Quality

Affected Environment .................................................................................................................................. 82 

Issue 1: Add Information on MTBE (methyl tertiary butyl ether)................................................. 82 

Issue 2: Clarify Utah State Water Quality Regulations Including Designated Uses 

for the Lake and Drinking Water Intake Locations.......................................................... 82 

Issue 3: Data Presentation and Analysis Incomplete for PAH (polycyclic aromatic 

hydrocarbons) and Other Fuel Components..................................................................... 83 

Issue 4: Data Collection (Water Quality Sampling) and Presentation........................................... 83 

Issue 5: Insufficient Detail of Monitoring Plan and Marina Best Management Practices 

Information Pertaining to Persistent Hydrocarbon Constituents...................................... 84 

Issue 6: Establish Whether Personal Watercraft Use Is Violating or Has the Potential 

to Violate State-Adopted Water Quality Standards, Including Impairment 

of Utah’s Drinking Water Source Criteria........................................................................ 85 

Issue 7: Need to Discuss Impacts on Water Quality Below the Dam............................................ 86 

Cumulative Effects ....................................................................................................................................... 87 

Issue 1: Cumulative Effects of Loading Were Ignored ................................................................. 87 

Impacts on Water Quality from Personal Watercraft Use............................................................................. 88 

Issue 1: New References to Include in Water Quality Analysis.................................................... 88 

Issue 2: Water Quality Analysis Is Inadequate Because it Omitted Relevant Research, 

Used Extreme Assumptions, or Disregarded Significant Impacts Still Present 

with New Technology...................................................................................................... 88 
RESPONSES TO SUBSTANTIVE COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT

xx

Issue 3: Insufficient Detail of Monitoring Plan and Marina Best Management 

Practices Information Pertaining to Persistent Hydrocarbon Constituents....................... 89 

Issue 4: Establish Whether Personal Watercraft Use Is Violating or Has the Potential 

to Violate State Adopted Water Quality Standards, Including Impairment 

of Utah’s Drinking Water Source Criteria........................................................................ 89 

Issue 5: Cumulative Effects of Loading Were Ignored ................................................................. 90 

Regulations, Methodologies, and Assumptions............................................................................................ 91 

Issue 1: PAH Data Presentation and Analysis Incomplete ............................................................ 91 

Issue 2: Data Collection (Water Quality Sampling) and Presentation........................................... 91 

Issue 3: Water Quality Analysis Is Inadequate Because it Omitted Relevant Research, 

Used Extreme Assumptions, or Disregarded Significant Impacts Still Present 

with New Technology...................................................................................................... 91 

Issue 4: Reference Other Water Quality Standards ....................................................................... 94 

Issue 5: The PAH Data Analysis is Inadequate............................................................................. 95 

Wildlife and Wildlife Habitat

Affected Environment .................................................................................................................................. 97 

Issue 1: Personal Watercraft Use and Human Activities Associated with Their Use May 

Not Be Any More Disturbing to Wildlife Species Than Any Other Type of 

Motorized or Nonmotorized Watercraft........................................................................... 97 

Impacts from Other Vessels.......................................................................................................................... 98 

Issue 1: Other Types of Motorized Watercraft Are Responsible for as Much or More 

Wildlife Habitat Damage as Personal Watercraft............................................................. 98 

Impacts of Personal Watercraft Use ............................................................................................................. 99 

Issue 1: Tour Boat Uses Cause Greater Effects to Wildlife and Wildlife Habitat 

Than Personal Watercraft................................................................................................. 99 

Issue 2: The Draft Environmental Impact Statement Should Acknowledge Research 

Findings That Detected Levels of Some PAH Compounds in Lake Powell 

Fish Tissue Samples......................................................................................................... 99 

Issue 3: Predicted Impacts of Personal Watercraft Use to Wildlife And Wildlife Habitats 

Described in the Draft Environmental Impact Statement Does Not Justify 

Restricting Personal Watercraft Use .............................................................................. 100 

Issue 4: Boats Powered by Outboard Motors Created Greater Effects on Wildlife 

Than Personal Watercraft in Comparison Tests............................................................. 100 

Issue 5: Wildlife Abundance Would Increase With Elimination of Personal Watercraft 

Noise and Human Disturbance....................................................................................... 100 

Issue 6: Characterization of Impact Duration Should be Changed.............................................. 101 

Issue 7: The Draft Environmental Impact Statement Does Not Adequately Disclose 

the Potential Effects of Personal Watercraft Use on Selected Bird and 

Mammal Species ............................................................................................................ 101 

Issue 8: Use of New Personal Watercraft Engine Technology Will Not Reduce 

Adverse Impacts on Wildlife.......................................................................................... 102 

Issue 9: Personal Watercraft Disproportionately Impact Wildlife............................................... 103 

Issue 10: Personal Watercraft Use Disturbs Wildlife Activity in the Immediate Vicinity 

of Lake Powell ............................................................................................................... 103 
CONTENTS

xxi

DIVIDER FOR COMMENTS AND RESPONSES

TO BE REMOVED
RESPONSES TO SUBSTANTIVE COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT

xxii

BACK OF DIVIDER (TO BE REMOVED)
3 

AIR QUALITY

Affected Environment 

Issue 1: Inadequate Data Collection and Monitoring 

A Comment: The air quality analysis uses data collected over one week, while stating that three years of 

data are required to make a reasonable assessment. The National Park Service has known about the ban on 

personal watercraft without a NEPA Environmental Impact Statement, since March 21, 2000, providing 

over two years to collect the required data and compile a report for the air quality. Even if three years 

worth of data were not available to be collected, the National Park Service clearly had more than a week 

to collect and monitor the impacts on the air quality that may be occurring from the hydrocarbon releases 

of personal watercraft. 

Response: Although the National Park Service promulgated an amended regulation in March 2000, it was 

not until April 2001 when the National Park Service, in a settlement agreement with the Bluewater 

Network, began the National Environmental Policy Act (NEPA) process to determine if personal 

watercraft use was appropriate based on an environmental impact analysis. The National Park Service 

determined that Labor Day weekend would be the best time to collect data to assess the effect of personal 

watercraft use on air quality because it is the busiest part of the visitor use season. 

Public Comment: Commenter: Affiliation: 

905G Individual 

 
4 

Impacts to Human Health and Air Quality Related Values (Visibility and Vegetation) from Personal 

Watercraft 

Issue 1: General Impacts of Personal Watercraft on Air Quality

A Comment: The California Air Resources Board (CARB) report Outboard Engine and Personal Watercraft 

Emissions to Air and Water: A Laboratory Study states that for all measured air pollutants, two-stroke 

personal watercraft and outboards were generally and substantially higher than comparable four-stroke 

engines. In the case of hydrocarbons (THC), two-stroke motors were far more polluting than comparable 

four-stroke motors. 

Response: The comment is correct for hydrocarbons, carbon monoxide (CO), and particulate matter. In 

the Final Environmental Impact Statement, the Environmental Protection Agency (EPA) NONROAD 

model was used to estimate watercraft emissions. The modeling results show that HC (hydrocarbon) 

emission factors for two-stroke carbureted personal watercraft engines are approximately 13 times greater 

than for four-stroke personal watercraft engines. This is a major factor in the EPA rule requiring the 

phase-out of carbureted two-stroke engines. A discussion of the emission factors and effects on forecast 

watercraft emissions are discussed in the “Environmental Consequences” chapter under “Air Quality” in 

each alternative discussion. 

Public Comment: Commenter: Affiliation: 

1002K Bluewater Network Organization 

 

B Comment: Direct-injected two-stroke and four-stroke personal watercraft will not solve all problems. 

California Air Resources Board research found that direct-injection two-stroke engines emit 

approximately seven times more total hydrocarbons than do four-stroke engines. Hydrocarbons are a key 

component in the formation of smog. In the case of formaldehyde, a possible human carcinogen, directinjection engines emitted more than both the carbureted two-stroke and four-stroke engines. In the case of 

nitrogen oxides (NOx) and carbon monoxide, the four-stroke engine emitted more than the direct-injection 

engines. Neither the direct-injection nor the four-stroke personal watercraft will do anything to address the 

impacts of the more than 1.1 million thrillcraft already operating on American waters. 

Response: The National Park Service acknowledges that changing from carbureted two-stroke personal 

watercraft engines to direct-injection two-stroke engines may result in increases of airborne particulateassociated PAH (polycyclic aromatic hydrocarbons). In addition, a recent study by the Tahoe Regional 

Planning Agency (2003) compared the concentrations of PAH compounds released into the water and 

found that the two-stroke carbureted outboard engine emitted lower PAH levels into the water than did the 

two-stroke direct-injected engine. The four-stroke carbureted outboard engine emitted the lowest PAH 

levels, as well as other gasoline-related contaminants into the water (TRPA 2003; CARB 2001). 

However, the two-stroke carbureted outboard engine emitted higher levels of benzene than the two-stroke 

direct-injected engine model (CARB 2001). Personal watercraft engines follow the same patterns of 

emission rates as outboard engines (CARB 2001). The TRPA (2003) study confirms other findings 

regarding emissions into the water and does not substantially change NPS conclusions regarding water 

quality impacts. The National Park Service stated a commitment in the Final Environmental Impact 

Statement to monitor for chemical compounds. 

Public Comment: Commenter: Affiliation: 

1002L Bluewater Network Organization 

 
Impacts to Human Health and Air Quality Related Values (Visibility and Vegetation) from Personal Watercraft

5 

Issue 2: Polycyclic Aromatic Hydrocarbon Concentrations from Personal Watercraft Use at Glen Canyon 

National Recreation Area Do Not Pose Any Health Risks

A Comment: Continued personal watercraft use at Glen Canyon National Recreation Area will not pose any 

adverse health risks for park visitors under even the “worst case” airborne PAH concentrations that could 

theoretically be generated by the vessels. 

Response: The commenter submitted an analysis of PAH emissions at Glen Canyon to support the 

comment. The commenter’s analysis uses many conservative assumptions and a pollutant dispersion 

model to conclude that PAH exposure to personal watercraft users from personal watercraft PAH 

emissions would be less than one thousandth of one % (<0.001%) of an Occupational Safety & Health 

Administration (OSHA) limit for PAH exposure. Shoreline exposure would be even lower. OSHA 

published the limit as part of a discussion of safety and health related to coal tar pitch volatiles. The limit 

is for total PAH, and the comment in reference to OSHA for limits of coal tar volatiles does not apply in 

the context of the Glen Canyon personal watercraft rule-making discussion. In addition, another relevant 

study concluded that there are some health effects associated with PAH emissions (see Environmental and 

Occupational Exposure to Toxic Air Pollutants from Winter Snowmobile Use in Yellowstone National 

Park (Kado et al. 2001). Therefore, the National Park Service cannot support a conclusion, as the 

commenter suggests, that personal watercraft use at Glen Canyon would pose no adverse health risks from 

toxic air pollutant emissions. 

Public Comment: Commenter: Affiliation: 

1344H Personal Watercraft Industry 

Association 

Organization 

 

Issue 3: Nitrogen Oxide Emissions

A Comment: The Final Environmental Impact Statement should also note that nitrogen oxide pollutant 

emissions, a smog precursor, are likely to increase with the conversion to more four-stroke engines.

Response: The Draft and Final Environmental Impact Statements do note in the “Air Quality” section of 

the “Environmental Consequences” chapter under “Emission Standards for Gasoline-Powered Marine 

Engines,” that nitrogen oxide contamination will increase with implementation of the EPA 1996 rule. 

Public Comment: Commenter: Affiliation: 

1393O Environmental Protection Agency Public Agency 

 

Issue 4: The Draft Environmental Impact Statement Underestimates the Reduction of Personal Watercraft 

Emissions Over Time

A Comment: There were a number of commenters concerned that the changeover to four-stroke and twostroke direct injection personal watercraft engines to meet the requirements of the EPA 2006 and CARB 

2008 emission standards is occurring much more rapidly than EPA and National Park Service has 

estimated. Amounts of emissions at Glen Canyon will accordingly continue to decline rapidly, achieving a 

reduction of approximately 90% by 2012. 

Response: All alternatives use the rate of conversion of the engines from carbureted two-stroke to clean 

engines consistent with the EPA rule, “Final Rule for New Gasoline Spark-Ignition Marine Engines” 

(EPA 1996a). The National Park Service used the EPA data where it was assumed that 21.6% of the 

carbureted two-stroke engines in use in 1998 would be replaced by 2004 and that 58.4% would be 

replaced by 2012. The commenter’s opinion is principally based on confidential, proprietary personal 

watercraft sales and forecast data prepared by personal watercraft manufacturers. This proprietary data 

was not supplied with the comment and, therefore, was not available to the National Park Service. 
AIR QUALITY

6 

The commenter states that the data indicates that the conversion of two-stoke carbureted personal 

watercraft models to cleaner direct-injection engines is occurring more rapidly than anticipated in the 

1996 EPA analysis of the effects of the conversion rule. While the National Park Service has no reason to 

doubt that personal watercraft conversions and sales may be proceeding at a greater rate than forecast by 

the Environmental Protection Agency, there is no survey or similar data available at this time that 

indicates that the engine mix at Glen Canyon is proceeding at a faster or slower rate than the EPA 

forecast. Therefore, use of the EPA rates is considered appropriate in disclosing potential impacts on air 

quality. Under the modified preferred alternative (alternative B), personal watercraft engines would be 

100% compliant after 2012. 

Public Comment: Commenter: Affiliation: 

1344E Personal Watercraft Industry 

Association 

Organization 

 

B Comment: Commenter expressed concern that personal watercraft emissions are declining faster than 

forecasted by the Environmental Protection Agency. The existing fleet of personal watercraft has 

achieved a 25% reduction compared to HC + NOx emission levels before the EPA regulation became 

effective, and will achieve reductions greater than 80% by 2012. 

Response: The comment is principally based on two assumptions made by the commenter. The first is 

based on confidential, proprietary information regarding personal watercraft sales and forecast data 

prepared by personal watercraft manufacturers. No supporting data was supplied with the comment. The 

commenter states that the data indicates that the conversion of personal watercraft models to cleaner 

engines is occurring more rapidly than anticipated in the 1996 EPA analysis of the effects of the 

conversion rule. While the National Park Service has no reason to doubt that personal watercraft 

conversions and sales may be proceeding at a greater rate than forecast by the Environmental Protection 

Agency, there is no survey or similar data available at this time indicating the engine conversion at Glen 

Canyon is proceeding at a faster or slower rate than the EPA forecast. Therefore, use of the EPA rates is 

considered appropriate, and use of an accelerated rate may be considered speculative without additional 

supporting data. 

The second assumption by the commenter is that 75% of the personal watercraft at Glen Canyon will have 

engines that comply with the California Air Resources Board (CARB) conversion rule for all years, which 

requires that marine engine emission reductions targeted by the Environmental Protection Agency for 

2006 be achieved in California by 2001. The California rule then requires further emission reductions by 

2004 and 2008 (Title 13, California Code of Regulations, sections 2440–2448). The commenter assumes 

that 50% of the personal watercraft users at Glen Canyon will be from California and all will have CARBcompliant watercraft, and that, because of manufacturing and sales efficiencies outside of California, an 

additional 25% of the Glen Canyon personal watercraft users will have CARB-compliant watercraft. The 

National Park Service concurs that many watercraft users at Glen Canyon have California-registered 

personal watercraft, and that they will meet the CARB standards. However, there is no data relative to 

personal watercraft at Glen Canyon to confirm the 75% figure assumed by the commenter. The NPS 

emission calculations are conservative only in the sense that they do not specifically account for 

watercraft that have already been or will be converted to meet CARB standards. Under the modified 

preferred alternative (alternative B), personal watercraft engines would be 100% compliant after 2012. 

Public Comment: Commenter: Affiliation: 

1344C, 1344F Personal Watercraft Industry 

Association 

Organization 

 

C Comment: Commenter believes that the draft environmental impact statement reference to moderate 

levels of air quality impacts from HC, NOx, and CO emissions associated with personal watercraft use is 

incorrect and potentially misleading. The commenter believes that these emissions, even under the “worst 

case” scenario, would not pose a health risk for park visitors. 
Impacts to Human Health and Air Quality Related Values (Visibility and Vegetation) from Personal Watercraft

7 

Response: Emission levels shown in the Air Quality analysis tables in the “Environmental Consequences” 

chapter are not directly comparable with the emission levels submitted by the commenter, because the 

National Park Service Air Quality Division calculates emissions on an annual basis, and the commenter’s 

calculations are for an average boating day during the boating season. Some assumptions made for NPS 

calculations are more conservative than those used for the commenter’s calculations. The National Park 

Service assumed that the conversions from carbureted two-stroke engines to cleaner engines would occur 

at the rate forecast by the Environmental Protection Agency. Based on the NPS model (presented in the 

tables as tons per year of estimated hydrocarbon and nitrogen oxide emissions for all alternatives), a 

21.6% conversion is assumed from 1998 levels by 2004 and a 58.4% conversion by 2012. The commenter 

assumes a faster conversion. The commenter assumes that emissions would be reduced because a 

significant portion of personal watercraft would be cleaner than EPA requirements due to compliance 

with the more restrictive California requirements. There is no data relative to personal watercraft at Glen 

Canyon to confirm the 75% figure that is assumed by the commenter. The NPS emission calculations are 

conservative only in the sense that they do not specifically account for watercraft that have already been 

or will be converted to meet CARB standards. Under the modified preferred alternative (alternative B), 

personal watercraft engines would be 100% compliant after 2012, which would result in a substantial 

reduction in emissions. Using the EPA forecast rate of emission reductions in the NPS air quality 

emissions model, and assuming a 2% annual visitor growth rate, the personal watercraft emissions 

associated with the modified preferred alternative would be up to 365 tons per year of HC + NOx by 2012 

and 2,955 tons per year of CO, which is considered by the National Park Service to be a moderate adverse 

effect. 

Public Comment: Commenter: Affiliation: 

1344F Personal Watercraft Industry 

Association 

Organization 

 
8 

Impacts from Other Vessels 

Issue 1: General Comments About Impacts on Air Quality From Other Vessels

A Comment: The Draft Environmental Impact Statement fails to mention the effects on air quality from 

other boats.

Response: The effects on air quality from other motorized watercraft at Glen Canyon were addressed in 

the cumulative impacts analysis of air quality in the “Environmental Consequences” chapter. The 

National Park Service acknowledges that other motorized watercraft emit pollutants; however, 

management of other watercraft is beyond the scope of this analysis. See responses in the “Purpose of and 

Need for Action” chapter regarding the scope of this analysis. 

Public Comment: Commenter: Affiliation: 

1209D, 132B Individual 

 
9 

Methodology and Assumptions 

Issue 1: Derivation of Engine Load

A Comment: The Final Environmental Impact Statement should disclose the derivation of the 21% average 

engine load. Given what would be a major impact in the analysis, an explanation of why this is the correct 

assumption for personal watercraft would be helpful. 

Response: The assumption of an average engine load of 21% for personal watercraft was based on the 

activity data used in the EPA NONROAD model. 

Public Comment: Commenter: Affiliation: 

1393Q Environmental Protection Agency Public Agency 

 

Issue 2: Inconsistent Estimates Between Water and Air Quality Analysis

A Comment: The Final Environmental Impact Statement should use the same percentage for how much and 

which pollutants volatize in both the air and water quality impacts sections. No estimate of the percent 

that volatilizes is given in the water quality section. In the air quality section it is stated that up to 30% of 

the fuel from personal watercraft is unburned and is discharged as gaseous hydrocarbons (Draft 

Environmental Impact Statement p. 181). The numbers should be consistent for the analysis. 

Response: The Draft Environmental Impact Statement incorrectly stated that 30% of the fuel is exhausted 

into the air. However, the Final Environmental Impact Statement correctly states that up to one-third of 

the fuel delivered to the two-stroke carbureted personal watercraft engine is unburned and discharged into 

the water. It is difficult to determine how much of the fuel is volatilized into the atmosphere. As stated in 

“Methodology and Assumptions” section under “Air Quality”, many organic pollutants that are initially 

dissolved in the water volatilize to the atmosphere, especially if they have high vapor pressures, are 

lighter than water, and mixing occurs at the air/water interface. It is difficult to assess the specific 

evaporation rates of exhaust pollutants from personal watercraft because the rates will differ according to 

the ratio of gas to oil used, by fuel brand, by engine, and operating conditions such as temperature and 

water aeration. 

In 1994, the Environmental Protection Agency released a public memorandum entitled “The Effects of 

Marine Engine Exhaust on Water Quality: Summary of Findings of Various Research Studies.” This 

document summarizes 11 research papers and presents volatilization rates and dilution ratios for 

observable effects such as taste, odor, and generation of oil film. 

At temperatures commonly found in Lake Powell during the summer boating season (77oF–86oF), 78%–

84% of the gasoline/oil mixture (50:1) for carbureted two-stroke engines would be evaporated from the 

water to the air in 1.2 hours (EPA 1994). This EPA review also cites a study by the Boating Industrial 

Association (1974) that describes the two-stroke gas/oil mixture as having an 11-day half-life in still 

water (such as a laboratory tank) and a half-life of less than one day in open, aerated water (such as a 

lake). A description of the volatile nature of five gasoline constituents has been provided in the “Water 

Quality” section of the “Affected Environment” chapter. 

Public Comment: Commenter: Affiliation: 

1393V Environmental Protection Agency Public Agency 

 

B Comment: On page 181, the National Park Service states that even though personal watercraft exhaust is 

initially expelled in the water, “a portion” of the exhaust pollutants end up in the atmosphere. This 

conclusion leaves the impression with the reader that personal watercraft do not have a significant impact 

upon Glen Canyon’s air quality. However, in the water quality section of the affected environment 

chapter, the National Park Service states that a vast majority of personal watercraft unburned hydrocarbon 
AIR QUALITY

10 

pollution, which can represent nearly a third of all emissions discharged from a typical two-stroke 

personal watercraft, ends up in the air. In particular, the National Park Service notes that “about 85% of 

these [hydrocarbon] compounds are highly volatile.” These two statements about the fate of personal 

watercraft pollutants contradict each other and appear to be an attempt to downplay the impact personal 

watercraft have on both air and water quality. 

Response: As stated in the “Methodology and Assumptions” section under “Air Quality” in the 

“Environmental Consequences” chapter, many organic pollutants that are initially dissolved in the water 

volatilize to the atmosphere, especially if they have high vapor pressures, are lighter than water, and 

mixing occurs at the air/water interface. As stated in the previous response, studies have indicated that at 

temperatures between 77oF–86oF, 78%–84% of the unburned gasoline and fuel additives are evaporated. 

However, the specific evaporation rate is difficult to assess on the lake because rates differ according to 

fuel mixture, fuel type, engine, and operating conditions such as temperature and water aeration. Under 

the modified preferred alternative (alternative B), all personal watercraft engines would be 100% 

compliant with EPA standards after 2012. The analysis of air quality in the Final Environmental Impact 

Statement demonstrates that there would be a substantial reduction in emissions of pollutants into the air 

under alternative B compared to alternative A (continuing current management). Furthermore, the 

National Park Service finds that the modified preferred alternative (alternative B) presented in the Final 

Environmental Impact Statement (including the provision for continued personal watercraft use, if 

implemented), would not result in an impairment of park air or water quality. 

Public Comment: Commenter: Affiliation: 

1002AD Bluewater Network Organization 

 

Issue 3: Include Updated Evaporative Standards Proposed by the Environmental Protection Agency

A Comment: It should be noted in the Final Environmental Impact Statement that in July 2002, EPA 

proposed cleaner evaporative standards for personal watercraft. If promulgated, these standards will be 

relevant for future environmental studies of this issue. 

Response: The text in the “Air Quality Methodology and Assumption” section of the “Environmental 

Consequences” chapter has been changed to include the proposed EPA evaporative standards. Also see 

response to comment 4 A below. 

Public Comment: Commenter: Affiliation: 

1393U Environmental Protection Agency Public Agency 

 

Issue 4: The Draft Environmental Impact Statement Fails to Mention the Impact of Personal Watercraft 

Permeation Losses

A Comment: Permeation is the process by which individual fuel molecules may penetrate the walls of the 

various assembly components of a fuel system directly to the outside air. According to the California Air 

Resources Board (CARB), evaporative and permeation emissions from nonroad engines/fuel systems and 

gas tanks are significant. For example, CARB research found that a typical nonroad engine (5-gallon fuel 

tank filled to half its capacity) is likely to emit over 7 grams of hydrocarbon pollution in a 24-hour 

summer diurnal cycle. According to the EPA, many of America’s approximately 10 million off-road 

vehicles such as all-terrain vehicles, personal watercraft, and snowmobiles have similar tanks. 

Response: Nonexhaust hydrocarbon emissions from watercraft are less than exhaust emissions but are not 

insignificant. For watercraft, the principal sources of nonexhaust emissions are evaporative emissions 

from fuel tanks when the engine is not in use and refueling emissions. The quantities of these emissions 

are related to the number of pieces of equipment, number of trips, and watercraft fuel tank volume. The 

phase-out of carbureted two-stroke personal watercraft engines varies by alternative, resulting in 

variations in exhaust emissions. In addition, fuel tank volumes would not be anticipated to change 
Methodology and Assumptions

11 

significantly. The number of trips per year was not expected to differ between alternatives over the next 

10 years. Therefore, nonexhaust emissions would be very similar for all alternatives. In July 2002, the 

Environmental Protection Agency proposed new evaporative standards for gasoline-fueled boats and 

personal watercraft. These proposed standards would require most new boats produced in 2008 or later to 

be equipped with low-emission fuel tanks or other evaporative emission controls. The Final 

Environmental Impact Statement text reflects the change to include a discussion of nonexhaust emissions 

in the “Air Quality Methodology” section of the “Environmental Consequences” chapter. 

Public Comment: Commenter: Affiliation: 

1002V Bluewater Network Organization 

 

Issue 5: The Research on Air Quality Effects of Personal Watercraft Emissions Presented in the Draft 

Environmental Impact Statement Is Not Applicable to New Engine Technology

A Comment: National Park Service notes that recent studies suggest changing from two-stroke carbureted to 

two stroke direct injection personal watercraft engines might increase PAH emissions. A study by 

Norman Y. Kado et al, Airborne Particle Emissions from two- and four-stroke Outboard Marine Engines: 

Polycyclic Aromatic Hydrocarbon and Bioassay Analysis, (Kado study) quantified PAH concentrations in 

airborne particulate emissions. The Kado study showed that the PAH emissions from the direct-injection 

two-stroke engines tested were greater than from carbureted two-stroke engines. The direct-injection twostroke outboard engine used in that study was a 1999 model and represented very early technology, and 

the results of the study are not applicable to newer model direct-injection outboard engines, much less 

personal watercraft engines. 

Response: The commenter rejects the applicability of the Kado study to newer engines including PWC 

engines. Because many older engines would still be allowed to operate at Lake Powell through 2012, the 

National Park Service assumes that there would still be PAH emissions and the Kado study is relevant. In 

addition, a recent study by the Tahoe Regional Planning Agency (2003) compared the concentrations of 

PAH compounds released into the water and found that the two-stroke carbureted outboard engine emitted 

lower PAH levels into the water than did the two-stroke direct-injected engine. The four-stroke carbureted 

outboard engine emitted the lowest PAH levels, as well as other gasoline-related contaminants into the 

water (TRPA 2003; CARB 2001). However, the two-stroke carbureted outboard engine emitted higher 

levels of benzene than the two-stroke direct-injected engine model (CARB 2001). Personal watercraft 

engines follow the same patterns of emission rates as outboard engines (CARB 2001). The TRPA (2003) 

study confirms other findings regarding emissions into the water and does not substantially change NPS 

conclusions regarding water quality impacts.

Nevertheless, while conversion of some carbureted two-stroke engines to direct-injection two-stroke 

engines would result in increased PAH emissions, the concurrent conversion to four-stroke engines would 

result in reduced PAH emissions. As shown by the commenter, using Kado data, the combined PAH 

emissions of one direct-injection two-stroke engine and one four-stroke engine would be slightly less than 

the PAH emissions of the two carbureted two-stroke engines that would be replaced. Therefore, the 

increase or decrease of PAH emissions as carbureted two-stroke engines are converted to cleaner engine 

types would depend on the relative numbers of the types of cleaner engines. In addition, in speaking with 

local personal watercraft businesses, the majority of newer personal watercraft models being sold are 

four-stroke engines, not two-stroke direct-injection engines but no specific data is available. The 

speculation of the mix of engine types would not appreciably change NPS conclusions made in the Final 

Environmental Impact Statement. 

Public Comment: Commenter: Affiliation: 

1344G Personal Watercraft Industry 

Association 

Organization 

 
12 

ALTERNATIVES

Alternative B (Modified Preferred Alternative)

Issue 1: Alternative B with Changes

A Comment: The preferred alternative should keep personal watercraft entirely out of the Dirty Devil, the 

Colorado beyond the highway bridge (not further upstream at Sheep Canyon), all of the Escalante and at 

least as much of the San Juan arm as in Alt B. In effect, restrict them to the main body of the reservoir 

only. 

Response: The Final Environmental Impact Statement includes additional restrictions for alternative B 

(the modified preferred alternative) that would prohibit personal watercraft use on the Dirty Devil River 

beyond the Highway 95 bridge. This restriction would provide a recognizable geographical location for 

visitors and law enforcement, maintain traditional fishing values, reduce conflict among users, and 

improve safety. 

Public Comment: Commenter: Affiliation: 

139E Individual 

 

B Comment: Commenter recommends that if the Park Service chooses to enact its preferred alternative 

(alternative B), it should be modified to create more areas of Glen Canyon National Recreation Area that 

are off-limits to personal watercraft use. Specifically, the commenter recommends that National Park 

Service prohibit personal watercraft use in any of the canyons of Lake Powell or tributary rivers where the 

shore-to-shore (or canyon wall-to-canyon wall) distance is less than one-half mile. 

Alternative B should be modified as follows: (1) No-wake zones should apply to all craft, not just 

personal watercraft to improve safety. (2) No-wake zones should apply to all narrow canyons (width to be 

determined). 

Response: Under Utah State law, all boaters must operate at flat-wake speeds or idle speed within 

150 feet of another boat, a person in or floating on the water, a waterskier (except those being towed), a 

shore fisherman, a launching ramp, a dock, or a designated swimming area. Arizona state law requires all 

boaters to operate at flat-wake speeds within 60 feet of another vessel. The modified preferred alternative 

(alternative B) addresses signing, buoys, and boater education that will enhance other watercraft 

operators’ observance of safe boating practices. 

In addition, alternative B (the modified preferred alternative) currently provides for a three-year pilot 

study to further evaluate personal watercraft use areas. Potential restrictions of personal watercraft use in 

other locations of the recreation area would be evaluated at that time. The purpose of the pilot study and a 

description of how it would be implemented are provided in appendix C. 

 

Public Comment: Commenter: Affiliation: 

1248F National Park Conservation 

Association 

Organization 

1129B Individuals 

 

C Comment: The National Park Service should develop additional management restrictions with the goal of 

elimination of the use of 2 cycle personal watercraft engines not meeting the 2006 emission standards 

over a ten (10) year time period. 

Response: If implemented, the modified preferred alternative (alternative B) in the Final Environmental 

Impact Statement would require that personal watercraft meet the EPA 2006 emission standards by the 
Alternative B (Modified Preferred Alternative)

13 

end of 2012. Personal watercraft not meeting the standards would no longer be allowed to operate in Glen 

Canyon National Recreation Area beginning in 2013. 

The National Park Service expects that by 2012, most personal watercraft owners would already be in 

compliance with the 2006 EPA marine engine standards. The impact on visitors as a result of the 2012 

ban on carbureted two-stroke personal watercraft use is expected to be small. Personal watercraft 

manufacturers currently offer models that are compliant with the EPA 2006 standards, and new personal 

watercraft purchased later than 2006 would already be compliant. The average operating life of a personal 

watercraft is 5 to 10 years, depending upon the source (see the “General Methodology” section in the 

“Environmental Consequences” chapter). As a result, it is expected that the majority of noncompliant 

personal watercraft will no longer be in operation when the engine restrictions proposed under the 

modified preferred alternative (alternative B) take effect in 2012. 

Public Comment: Commenter: Affiliation: 

641A Individual 

 

Issue 2: Lake Management Plan Should not be an Element of Alternatives

A Comment: Commenters indicated that they support alternative B, but believe the Lake Management Plan 

should be excluded from the alternative. 

Response: The National Park Service must manage Glen Canyon National Recreation Area to protect the 

recreational opportunities available at the park, as well as the natural resources found in the lake and 

surrounding lands. To accomplish this, a lake management plan will provide the tools necessary to 

analyze activities that take place on the lake and determine if unacceptable impacts are occurring. Even 

though there is rationale and need to consider management of personal watercraft under a separate 

decision-making framework, there remains the need to examine all uses of the lake collectively. As 

identified in the cumulative effects analysis under each impact topic, there are many management issues 

involving the mix of lake uses that will require additional planning. 

 

Public Comment: Commenter: Affiliation: 

209A Multiple Access Conservation 

Coalition 

Organization 

608D, 608F, 808B, 1133D, 1134D Individuals 

 

Issue 3: Monitoring Plan as an Element of Alternative B

A Comment: On page 169, it is stated that some hydrocarbons can adsorb onto suspended soil particles and 

settle out. Any monitoring plan should therefore include sediment chemistry monitoring in marinas and 

sediment deposition areas down-current for the constituents most likely to settle, including poly-aromatic 

hydrocarbons. Additionally, to understand whether current sediment conditions and aquatic health of the 

benthic community is altered from the historical baseline, the monitoring plan should include benthic 

population sampling, and bioassay of these sediments. The Final Environmental Impact Statement should 

identify whether there is potential for these sediment deposition areas to be dredged. If so, it may merit 

implementing management practices to reduce or eliminate release of toxic constituents from personal 

watercraft use. 

Response: Text has been added to the Final Environmental Impact Statement in the “Alternatives” section 

to describe the monitoring plan that was added to alternative B (the modified preferred alternative). A 

report is presently being completed for a study that was done to determine the chemical content of 

sediment at the main inflow area of the Colorado River. Funding is currently being sought for another 

study to do the same evaluation in the San Juan and Escalante inflow/sediment deposition areas. These 

studies will identify the hydrocarbon content of these sediments. In addition, another study is currently 
ALTERNATIVES

14 

being conducted that examines the dynamics of sediment re-suspension and reworking in the Colorado 

River inflow. The monitoring plan that will be developed for the lake will include polycyclic aromatic 

hydrocarbons (PAH), as well as other gasoline constituents that may become re-suspended when there is 

down-cutting of the sediment deposits as a result of lowering lake level. The monitoring program that will 

be developed will also consider the most likely places for contamination, such as marina areas and areas 

downstream from major sediment depositional zones, if appropriate. The data from a study examining 

visitor effects (including hydrocarbon contamination) in three canyons will be used to develop water 

quality baselines for Glen Canyon National Recreation Area. A lake-wide monitoring plan will then be 

developed using the data gathered and the methods tested in these three studies (sediment, three canyons, 

and synoptic). Plan development will be guided by the Technical Advisory Committee that was formed in 

1996 by the National Park Service, the Departments of Environmental Quality Water Divisions of Utah 

and Arizona, and other interested organizations and agencies (including the Environmental Protection 

Agency) to protect Lake Powell water quality. The Technical Advisory Committee provides an excellent 

vehicle for establishing standards and protocols for Lake Powell that are acceptable to the states and that 

conform with the states’ regulations developed under authority of the Clean Water Act. Benthic 

population sampling and bioassay may be included in the monitoring plan as determined to be appropriate 

by the Technical Advisory Committee. Dredging to remove sediment is not contemplated by the National 

Park Service. 

Public Comment: Commenter: Affiliation: 

1393I, 1393J Environmental Protection Agency Public Agency 

 

Issue 4: Encourage Coordination with Two States to Develop Uniform Laws

A Comment: The National Marine Manufacturers Association encourages the National Park Service to work 

with the states of Arizona and Utah to develop unified law for the operation of all motorized vessels in the 

Glen Canyon National Recreation Area should it feel uniformity of the state boating laws is necessary to 

reduce visitor conflict. 

Response: As an element of alternative B (the modified preferred alternative), the National Park Service 

would work cooperatively with the states of Arizona and Utah in an attempt to develop unified laws for 

personal watercraft operations within the boundaries of the recreation area. 

Public Comment: Commenter: Affiliation: 

1176E National Marine Manufacturers 

Association 

Organization 

 
15 

Alternative C (No Action)

Issue 1: Phase Out Two-Stroke Personal Watercraft Engines and Eventually Replace with Four-Stroke 

Technology

A Comment: I support continued use of personal watercraft on Lake Powell with the long-term goal of 

eventually replacing two-stroke machines as they end their normal working life with four-stroke 

replacements and encourage those engaged in business of providing rental units to upgrade to these 

superior machines as soon as practicable. I oppose any outright ban on personal watercraft use, now, or in 

the future. 

Response: The modified preferred alternative (alternative B) in the Final Environmental Impact 

Statement would require that personal watercraft meet the EPA 2006 emission standards by the end of 

2012. Personal watercraft not meeting the standards would no longer be allowed to operate in Glen 

Canyon National Recreation Area beginning in 2013. 

The National Park Service expects that by 2012, most personal watercraft owners would already be in 

compliance with the 2006 EPA marine engine standards. The impact on visitors as a result of the 2012 

ban on carbureted two-stroke personal watercraft use is expected to be small. Personal watercraft 

manufacturers currently offer models that are compliant with the EPA 2006 standards, and new personal 

watercraft purchased later than 2006 would already be compliant. The average operating life of a personal 

watercraft is 5 to 10 years, depending upon the source (see the “General Methodology” section in the 

“Environmental Consequences” chapter). As a result, it is expected that the majority of noncompliant 

personal watercraft would no longer be in operation when the engine restrictions proposed under the 

modified preferred alternative (alternative B) take effect in 2012. The concessioner for the recreation area 

has already instituted a technology replacement program that replaces carbureted two-stroke engines, 

including personal watercraft, to engines compliant with the EPA 2006 marine engine emission standards. 

Public Comment: Commenter: Affiliation: 

312B, 1120C, 1119A Individual 

 
16 

Alternatives Eliminated

Issue 1: Insufficient Justification for Eliminating Alternatives

A Comment: The Draft Environmental Impact Statement states that limiting personal watercraft use to the 

main channel of Lake Powell reservoir would be, “...inconsistent to the objectives of the recreation area 

as defined in its enabling legislation. The objectives of the recreation area are to manage the area so that it 

provides maximum recreational enjoyment to the American public and its guests....” Limiting personal 

watercraft use to the main channel in no way compromises a visitor’s recreational enjoyment. So long as 

the Park Service provides for this opportunity at a reasonable number of locations, there would be no 

conflict with the spirit of the enabling legislation. 

Response: Alternative B (the modified preferred alternative) currently provides for a three-year pilot 

study to further evaluate personal watercraft-use areas. Potential restrictions of personal watercraft use in 

other locations of the recreation area would be evaluated during the pilot study. The purpose of the pilot 

study and a description of how it would be implemented are provided in appendix C. 

 

Public Comment: Commenter: Affiliation: 

1174C Living Rivers Organization 

1180E Individuals 

 
17 

Elements Common to All Alternatives

Issue 1: Lake Management Plan Should be a Component of all Alternatives

A Comment: Given that Glen Canyon national recreation area has already determined there is a “need for a 

comprehensive Lake Management Plan to more thoroughly explore all water-based recreation” (Draft 

Environmental Impact Statement p. 12), it is not clear why the Lake Management Plan is included only 

under alternatives B and C. EPA suggests that the National Park Service commit to doing the Lake 

Management Plan, and include in the Final Environmental Impact Statement a more detailed description 

of how this rule-making differs from the plan and what the plan will cover. 

Response: The development of a lake management plan is now a component of all the alternatives 

analyzed in the Final Environmental Impact Statement. Glen Canyon National Recreation Area 

management has submitted a funding request to develop a lake management plan. 

 

Public Comment: Commenter: Affiliation: 

1393Y, 1393S Environmental Protection Agency Public Agency 

1174F Living Rivers Organization 

139R Individual 

 
18 

Environmentally Preferred Alternative/NEPA Sections 101 and 102

Issue 1: Alternative B Should Not Be Environmentally Preferred Alternative

A Comment: The National Park Service has designated alternative B as the environmentally-preferred 

alternative. EPA believes that an alternative that allows only the cleaner personal watercraft engines 

and/or limits personal watercraft in areas where the soundscapes, wildlife or wilderness qualities in the 

Natural Zone are impacted, would be environmentally preferred over alternative B in that it balances the 

recreational use objectives of personal watercraft with the NPS’s policies requiring environmental 

protection. We suggest again further analysis of this in the Final Environmental Impact Statement. 

Response: Alternative B (the modified preferred alternative) is considered the environmentally preferred 

alternative because it best meets the six criteria identified in section 101 of the National Environmental 

Policy Act. Alternative B (the modified preferred alternative) provides the best balance between the 

population and resource use without degradation or risk to health or safety. Under this alternative, the 

phasing out of carbureted two-stroke personal watercraft engines by 2012 would provide enhanced 

protection of the recreation area’s natural resources while continuing access of personal watercraft 

operators to the recreation area. The personal watercraft use restrictions identified for the rivers under the 

modified preferred alternative (alternative B) were identified as areas of known or higher potential for 

conflict between motorized and nonmotorized users. The development of a lake management plan, 

supported by information obtained in a three-year pilot study, would allow the National Park Service to 

further mitigate specific areas in the future where impacts from personal watercraft and other motorized 

vessels are not consistent with Glen Canyon National Recreation Area goals. Enhanced educational 

programs that would be developed with implementation of the modified preferred alternative (alternative 

B) would provide a benefit to all lake users by increasing awareness of regulations pertaining to personal 

watercraft use and safety. The programs would reduce safety risks and visitor conflicts. Compared to the 

modified preferred alternative (alternative B), the elimination of personal watercraft use in the recreation 

area, under alternative C, would not maintain a variety of recreational choices or achieve as great a 

balance between visitor use and resource use. 

 

Public Comment: Commenter: Affiliation: 

1393T Environmental Protection Agency Public Agency 

1174E Living Rivers Organization 

1168B American Canoe Association Organization 

192A, 905K, 905J, 1180R, 1180D Individual 

 
19 

New Alternatives or Elements

Issue 1: Additional Strategies for Personal Watercraft Management

A Comment: The Draft Environmental Impact Statement does not adequately address strategies for the 

management of personal watercraft at Glen Canyon National Recreation Area. The Draft Environmental 

Impact Statement leaves much of the strategy and management to a future Lake Management Plan which 

may or may not be developed depending on the alternative selected. We recommend that the Final 

Environmental Impact Statement analyze reducing noise impacts from personal watercraft in the Natural 

Zone, or allowing four-stroke engines only to avoid future environmental damage. A commitment to do a 

Lake Management Plan should be included in the Final Environmental Impact Statement, no matter 

which alternative is selected. 

Response: The development of a lake management plan is now a component of all the alternatives 

analyzed in the Final Environmental Impact Statement. Glen Canyon National Recreation Area 

management has submitted a funding request to develop a lake management plan. Soundscape 

management will be addressed as a component within the lake management plan so that sound monitoring 

will be conducted within the recreation area. The “Alternatives” chapter in the Final Environmental 

Impact Statement has been modified to describe the soundscape management study. 

Public Comment: Commenter: Affiliation: 

1245L Sierra Club, Utah Chapter Organization 

 

Issue 2: Additional Personal Watercraft Restrictions

A Comment: Commenters suggest additional alternatives to restrict personal watercraft to specific areas 

such as: Wahweap Bay, Warm Creek Bay, the areas near Hall’s Crossing and Bullfrog Bay, and the 

Colorado River from Warm Creek to the Dam (excepting Navajo and Antelope Canyon). At a minimum, 

restrict their usage to the less remote areas of the lake, e.g. the main channel and certain large bays. 

Response: Alternative B (the modified preferred alternative) currently provides for a three-year pilot 

study to further evaluate personal watercraft-use areas. Potential restrictions of personal watercraft use in 

other locations of the recreation area would be evaluated during the pilot study. The purpose of the pilot 

study and a description of how it would be implemented are provided in appendix C. 

Public Comment: Commenter: Affiliation: 

3B, 87B, 1246B, 386A, 315A, 79B, 

84B 

 Individual 

 

B Comment: The areas proposed for personal watercraft restrictions under alternatives A and B are low 

personal watercraft use areas on Lake Powell. These proposals provide no benefit to the visitor experience 

in more than 190 other side canyons that are to remain accessible to personal watercrafts. Similar 

problems with noise and competing uses, which are the primary justification for the presentation of 

alternative A and B, also occur in Navajo, Antelope, Moqui, Lake, and manhoter canyons. These areas 

must be given equal consideration in the analysis. 

Response: The alternatives were developed based upon the best information available. The area 

restrictions under alternative B (the modified preferred alternative) on personal watercraft use were 

identified because of the levels of nonmotorized and passive uses that pose present or potential conflicts. 

Alternative B currently provides for a three-year pilot study to further evaluate personal watercraft-use 

areas. Potential restrictions of personal watercraft use in other locations of the recreation area would be 

evaluated during the pilot study. The purpose of the pilot study and a description of how it would be 

implemented are provided in appendix C. 
ALTERNATIVES

20 

 

Public Comment: Commenter: Affiliation: 

1245O, 1245P Sierra Club, Utah Chapter Organization 

1266A Sierra Club, Grand Canyon Chapter Organization 

1174 B Living Rivers Organization 

1194A, 1194B, 1194D, 3A, 3F, 

787A, 114B, 193B, 300A, 303A, 

767A, 843B, 1088A, 1244B, 1204D, 

1513D, 377C, 1177A, 68B, 121D, 

156D, 473A 

 Individual 

 

C Comment: One commenter requested restricting personal watercraft access to Rainbow Bridge. 

Response: Rainbow Bridge National Monument is a separate unit of the National Park Service. The scope 

of the Final Environmental Impact Statement is on management of personal watercraft within Glen 

Canyon National Recreation Area. Personal watercraft use at Rainbow Bridge National Monument is 

currently prohibited under the National Park Service amended regulation that was implemented in March 

2000 (36 CFR 3.24 (a), 2000). 

Public Comment: Commenter: Affiliation: 

1183A Individual 

 

Issue 3: Ban Two-Stroke Engines and Allow only Four-Stroke or Direct-Injection Engines

A Comment: Personally, our preference would be to see the ban on all jet skis throughout the entire body of 

water. Recognizing however, that this is not a wilderness designated area, we would much prefer that the 

manufacturing industry, its distributors, and the ultimate user be required to move entirely to the 

purportedly quieter and cleaner four-stroke, direct-injection engines. 

Response: If implemented, the modified preferred alternative (alternative B) of the Final Environmental 

Impact Statement would require that personal watercraft meet the EPA 2006 emission standards by the 

end of 2012. Personal watercraft not meeting the standards would no longer be allowed to operate in Glen 

Canyon National Recreation Area beginning in 2013. 

The National Park Service expects that by 2012, most personal watercraft owners would already be in 

compliance with the 2006 EPA marine engine standards. The impact on visitors as a result of the 2012 

ban on carbureted two-stroke personal watercraft use is expected to be small. Personal watercraft 

manufacturers currently offer models that are compliant with the EPA 2006 standards, and new personal 

watercraft purchased later than 2006 would already be compliant. The average operating life of a personal 

watercraft is 5 to 10 years, depending upon the source (see the “General Methodology” section in the 

“Environmental Consequences” chapter). As a result, it is expected that the majority of noncompliant 

personal watercraft would no longer be in operation when the engine restrictions proposed under the 

modified preferred alternative (alternative B) take effect at the end of 2012. 

Public Comment: Commenter: Affiliation: 

1245Q Sierra Club, Utah Chapter Organization 

1118A, 81A, 167B, 148A, 533B, 

837B, 369B, 44C, 494B, 139D, 

1245Q, 641A, 168A, 1210B 

 Individuals 

 
New Alternatives or Elements

21 

Issue 4: Make Canyons Flat-Wake Zones

A Comment: Commenters suggested restricting speed in narrow canyons or making major canyons 

flat-wake zones to reduce visitor conflicts. 

Response: Under Utah State law, all boaters must operate at flat-wake speeds or idle speed within 

150 feet of another boat, a person in or floating on the water, a waterskier (except those being towed), a 

shore fisherman, a launching ramp, a dock, or a designated swimming area. Arizona State law requires all 

boaters to operate at flat-wake speeds within 60 feet of another vessel. The modified preferred alternative 

(alternative B) addresses signing, buoys, and boater education that will enhance other watercraft 

operators’ observance of safe boating practices. 

In addition, alternative B (the modified preferred alternative) currently provides for a three-year pilot 

study to further evaluate personal watercraft-use areas. Potential restrictions of personal watercraft use in 

other locations of the recreation area would be evaluated during the pilot study. The purpose of the pilot 

study and a description of how it would be implemented are provided in appendix C. 

Public Comment: Commenter: Affiliation: 

827C, 674B Individuals 

 

Issue 5: New Alternative Incorporating Education, Enforcement, and Stricter Regulations

A Comment: Several comments received indicated that a new alternative should incorporate increased 

education, strict enforcement, and testing and licensing of personal watercraft operators. 

Response: The states of Arizona and Utah mandate the current operational age of personal watercraft 

users. The licensing of boat or personal watercraft operators rests with the state governments and is not 

the mandate of the federal government. Currently, the state of Utah provides an extensive and nationally 

recognized mandatory education program for personal watercraft users. The National Park Service will 

continue to support this existing program. In addition, the modified preferred alternative (alternative B) 

would provide enhanced educational materials and programs highlighting personal watercraft issues to 

distribute to the public and seek funding to increase visitor protection staff. 

Public Comment: Commenter: Affiliation: 

68C, 130D, 138B, 155B, 200B, 

444A, 909A, 7D, 158A, 1196D 

 Individuals 

 

Issue 6: Consider Wilderness in the Analysis of Personal Watercraft Management

A Comment: Half of the recreation area shoreline which is managed as wilderness should be given special 

consideration in the Environmental Impact Statement. This should include restrictions of personal 

watercraft where they are likely to impair the wilderness experience of Glen Canyon National Recreation 

Area visitors. Alternatives A and B are both likely to adversely impact the qualities of solitude and a 

natural ambience for these wilderness areas. The National Park Service must seek an alternative which 

recognizes the importance of wilderness lands and manages those lands appropriately. 

Response: The Natural Zone portion of the Lake Powell shoreline when the lake is full (3,700 feet in 

elevation) equals 712 miles. Sound from personal watercraft use on the lake would impact wilderness 

values of solitude and natural quiet, as it would carry beyond the shoreline itself and be heard at some 

distance within the Natural Zone. The sound could be heard up to a maximum of 2 miles from the source 

over a flat surface, but the topography surrounding Lake Powell is not flat. Assuming that a natural barrier 

to the sound would exist where there is an elevation change of 50 feet (approximate height of a five-story 

building) approximately 16,000 acres would be affected (between 3,700 and 3,750 feet in elevation). This 

equals 2.3% of the Natural Zone (668,670 acres). Time of day and season of use would also reduce actual 
ALTERNATIVES

22 

impacts on visitors in the Natural Zone, because the sound would not be continuous, would be 

encountered only during daylight hours, and would be minimal between October and May. 

Although noise does intrude on desired wilderness and Natural Zone soundscape values, the inescapable 

juxtaposition of the Natural Zone and the Recreation and Resource Utilization Zone make it impossible to 

avoid all adverse impacts on the Natural Zone/wilderness soundscape. As shown above, only 2.3% of the 

Natural Zone’s area would be affected, and those soundscape effects would be offset even further by 

diurnal/nocturnal and seasonal reductions in watercraft noise. 

There is a potential conflict in the management objectives between the Recreation and Resource 

Utilization Zone and the Natural Zone that is extremely difficult to avoid because the zones are adjacent 

to each other. However, the percentage of the Natural Zone that is adversely affected by personal 

watercraft noise, as shown in the preceding paragraph, is small. The noise generated by watercraft in the 

Recreation and Resource Utilization Zone, including personal watercraft, is consistent with Glen Canyon 

National Recreation Area’s enabling legislation “. . . to provide for public outdoor recreation use and 

enjoyment of Lake Powell and the lands adjacent thereto.” See the “Soundscape” section in the 

“Environmental Consequences” chapter for a description of the methodology used to assess impacts on 

soundscape in the Natural Zone. 

The preparation of a lake management plan, is now included under all alternatives in the Final 

Environmental Impact Statement, would provide an opportunity for the National Park Service to further 

evaluate impacts of all lake users on all resources, including soundscape. Alternative B (the modified 

preferred alternative) currently provides for a three-year pilot study to further evaluate personal watercraft 

use areas. Potential restrictions of personal watercraft use in other locations of the recreation area would 

be evaluated during the pilot study. The purpose of the pilot study and a description of how it would be 

implemented are provided in appendix C. 

Public Comment: Commenter: Affiliation: 

1245N, 1245J Sierra Club, Utah Chapter Organization 

 

Issue 7: Reconsider Personal Watercraft use Restriction on the Rivers

A Comment: Both upstream and downstream travel can be allowed on certain times of the year. With 

appropriate guidelines, the rivers are an extremely safe and enjoyable path for personal watercraft users. 

Please reconsider the river restrictions as well. 

Response: Alternative A, which allows for the continuation of current conditions, restricts personal 

watercraft travel upstream in the San Juan, Escalante, Colorado, and Dirty Devil Rivers at locations 

similar to those under alternative B (the modified preferred alternative). See table 4 for specific 

restrictions. The management actions under the modified preferred alternative (alternative B), for the San 

Juan, Escalante, Colorado, and Dirty Devil Rivers, would additionally restrict travel downstream on the 

same stretches of river as alternative A. Access would also be restricted in both directions on 10 

additional miles of the Dirty Devil River and 23 miles on the Colorado River. Based on the best available 

information, the National Park Service would implement these restrictions on the rivers to reduce visitor 

conflicts with river rafters, fishermen, and backcountry hikers; promote visitor enjoyment; and ensure 

visitor safety. 

Public Comment: Commenter: Affiliation: 

854C Individual 

 

Issue 8: Permit Personal Watercraft that Meet a “Quiet Standard”

A Comment: . Perhaps allowing “quiet standard” personal watercraft to operate in areas that may presently 

be restricted in the proposed plan because of noise considerations, would be an option. 
New Alternatives or Elements

23 

Response: Alternative B (the modified preferred alternative) currently provides for a three-year pilot 

study to further evaluate personal watercraft-use areas. Potential restrictions of personal watercraft use in 

other locations of the recreation area would be evaluated during the pilot study. The purpose of the pilot 

study and a description of how it would be implemented are provided in appendix C. 

Public Comment: Commenter: Affiliation: 

383E Individual 

 

Issue 9: Inadequate Range of Alternatives

A Comment: Selection of alternative B provides no significant benefit, except to areas at the extreme ends of 

the tributaries where there is no significant visitation, (and now no access). Additional alternatives are 

available that allow personal watercraft’s access to enjoy Lake Powell without destroying the experience 

of other users. 

Response: The NPS Director’s Order 12: Conservation Planning, Environment Impact Analysis and 

Decision-Making (NPS 2001b) states that a full range of alternatives must be examined, and that “. . . the 

alternatives carried forward for analysis must meet project objectives to a large degree, although not 

necessarily completely.” The National Park Service believes the Draft and Final Environmental Impact 

Statements contain a reasonable range of alternatives under this definition. 

Public Comment: Commenter: Affiliation: 

3F Individual 

 

B Comment: The American Canoe Association does not believe that the Draft Environmental Impact 

Statement provides an adequate range of alternatives. An alternative that specifically limits personal 

watercraft use to the large, wide open portions of Lake Powell and prohibits personal watercraft use from 

a greater portion of the lake’s narrow coves and canyons is needed. Also, none of the alternatives offer a 

shoreline buffer adequate to protect other waterway users and wildlife from the safety hazards and 

disruption associated with personal watercraft use. The Draft Environmental Impact Statement simply 

fails to represent a full spectrum of reasonable options. 

Response: The NPS Director’s Order 12: Conservation Planning, Environment Impact Analysis and 

Decision-Making (NPS 2001b) states that a full range of alternatives must be examined, and that “. . . the 

alternatives carried forward for analysis must meet project objectives to a large degree, although not 

necessarily completely.” The National Park Service believes the Draft and Final Environmental Impact 

Statements contain a reasonable range of alternatives under this definition. 

In addition, the modified preferred alternative (alternative B) provides for a three-year pilot study to 

further evaluate personal watercraft-use areas. Potential restrictions of personal watercraft use in other 

locations of the recreation area would be evaluated during the pilot study. The purpose of the pilot study 

and a description of how it would be implemented are provided in appendix C. 

Public Comment: Commenter: Affiliation: 

1168A American Canoe Association Organization 

 
24 

CONSULTATION AND COORDINATION

General Comments

Issue 1: Request to Add Letters to Administrative Record

A Comment: Why did the plan not recognize the thousands of public comments received on the NPS 

personal watercraft rulemaking opposing continued use of these vessels in units of the National Park 

Service. We request that the 30,000 Citizen letters be added to the administrative record as supporting a 

personal watercraft ban at the Glen Canyon National Recreation Area. In addition, we ask that the 

National Park Service please include all of Bluewater Network’s previous letters and correspondences 

sent to Glen Canyon concerning personal watercraft activity in the administrative record for the general 

evaluation of personal watercraft use. 

Response: The “Methodology and Purpose” section at the beginning of this volume 2 provides a detailed 

explanation of how public comments were received, reviewed, and ultimately responded to in this 

document. The criteria for determination of substantive comments is found in CEQ regulations (1503.4 

CFR) and amplified in Director’s Order 12: Conservation Planning, Environmental Impact Analysis, and 

Decision Making (section 4.6 (B)). Public comments, as well as other factors, were used by Glen Canyon 

National Recreation Area to modify the “preferred alternative” (alternative B) that was analyzed in the 

Draft Environmental Impact Statement. A description of the modified preferred alternative (alternative B) 

is found in the “Alternatives” chapter. 

The National Park Service acknowledges the 30,000 citizen comments submitted on the NPS personal 

watercraft rulemaking. The Draft and Final Environmental Impact Statements contain analyses for the 

continuation of and banning of personal watercraft use at the recreation area through the various impact 

topics. The controversy regarding personal watercraft use in park units is summarized in the “Personal 

Watercraft Use Regulatory Background” section in the “Purpose of and Need for Action” chapter. 

Public Comment: Commenter: Affiliation: 

1002M, 1002N Bluewater Network Organization 

 

Issue 2: Jet Ski and Boat Users Should Have Been Notified about Proposed Personal Watercraft 

Management at Glen Canyon

A Comment: Why were registered jet skiers not notified of the plan to manage personal watercraft at Glen 

Canyon National Recreation Area? The government has access to the owners of jet skis and boats because 

of registration requirements. Outreach for public comment should have extended beyond the local area. 

Response: In accordance with requirements of the National Environmental Policy Act, the National Park 

Service provided notices to the public on numerous occasions and opportunities for the public to comment 

on the Draft Environmental Impact Statement. A notice of intent to prepare an environmental impact 

statement was published in the Federal Register in August 2001. Public scoping workshops were held in 

August of 2001 in Salt Lake City, UT; Phoenix, AZ; and Page, AZ. In September 2002 the Draft 

Environmental Impact Statement was made available to the public and a notice of availability was 

published in the Federal Register. The Draft Environmental Impact Statement was sent to interested 

parties that were on the mailing list compiled from attendees at meetings and from written comments 

received at the recreation area. In addition the document was available on the recreation area website, and 

hard copies of the document were available on request. Public meetings were held in October 2002 to 

provide an opportunity for the public to comment on the Draft Environmental Impact Statement. The 

National Park Service has been diligent in keeping the public involved in the planning process through 

public meetings and news releases, and by posting information on the internet. 

Public Comment: Commenter: Affiliation: 

1133F, 1134F, 608A Individuals 

 
25 

CULTURAL RESOURCES

Impacts from Visitor Access and Other Watercraft

Issue 1: Access to Areas of Cultural Significance Should be Restricted

A Comment: The Draft Environmental Impact Statement notes that the recreation area’s geographic features 

and natural landscape are considered sacred to Native Americans. The National Park Service identifies a 

potential concern that the ability of personal watercraft operators to access remote areas of Glen Canyon 

National Recreation Area unit could intrude on traditional tribal activities and make certain cultural sites 

vulnerable to trampling, looting, and vandalism. 

 The Draft Environmental Impact Statement does not document any instances where these problems have 

occurred. Nor is there any reason to believe that personal watercraft users are more likely to pose these 

concerns than canoeists, kayakers, hikers, or others who might access these same areas. Even so, 

alternative B proposes to prohibit personal watercraft use in several areas to protect against potential 

adverse impacts on these resources. 

Response: Navajo practitioners conduct traditional activities as individuals, and generally do not share 

this information with others. Almost universally, American Indians are extremely reticent to share 

sensitive information about personal religious activities with the public. Out of respect for these 

traditional beliefs, and in keeping with various laws and mandates, the National Park Service does not 

include descriptions of specific traditional activities or their locations in a public document. For these 

reasons, Glen Canyon National Recreation Area does not have documentation of specific instances where 

personal watercraft users have intruded on traditional activities by tribal practitioners. However, the 

National Park Service is aware of the potential for conflicts with visitor use along the shorelines, 

particularly in more isolated areas. 

Public Comment: Commenter: Affiliation: 

1344V Personal Watercraft Industry 

Association 

Organization 

 

B Comment: The restrictions on personal watercraft use proposed under alternative B should help to protect 

cultural resources and activities from intrusion. There is no legitimate reason, however, for National Park 

Service to impose these restrictions on personal watercraft users only. 

Response: The plan was not designed to determine if personal watercraft caused more environmental 

damage to park resources than other boats, but rather, to determine if personal watercraft use was 

consistent with Glen Canyon National Recreation Area’s enabling legislation and management goals and 

objectives. The overall objective is to meet the terms of the settlement agreement with Bluewater Network 

(see the “Introduction” in the “Purpose of and Need for Action” chapter). An analysis was done on the 

management of personal watercraft in order to meet the terms of the settlement agreement between 

Bluewater Network and the National Park Service. With completion of this Final Environmental Impact 

Statement, the National Park Service may either take action to adopt special regulations to manage 

personal watercraft use at Glen Canyon, or may choose to discontinue personal watercraft use. 

Public Comment: Commenter: Affiliation: 

1344V Personal Watercraft Industry 

Association 

Organization 

 
26 

GENERAL ASSUMPTIONS USED FOR ANALYSIS

Personal Watercraft Use Trends and Assumptions

Issue 1: Unsubstantiated Personal Watercraft Use Assumption

A Comment: Throughout the Draft Environmental Impact Statement there are references to alternative C 

which state “by the end of the ten-year analysis period, most former personal watercraft users would have 

returned to the recreational area with other motorized watercraft.” This unsubstantiated conclusion is used 

to support the supposition that implementing alternative C would not significantly affect air quality, water 

quality, noise, visitor experience, etc. over the medium to long term. The Draft Environmental Impact 

Statement contains no data or analysis to back-up this prediction. Permanently banning personal 

watercraft use does not necessarily mean that powerboat and houseboat groups which use personal 

watercraft will use an additional vessel, merely that they will have one less recreational activity associated 

with their time on Lake Powell reservoir. While many of these users will continue to take part in 

motorized reservoir activities, there is no data or analysis presented for why these groups will necessarily 

incorporate additional watercraft to replace personal watercraft. Nor is there any evidence to suggest that 

there would be a one-to-one relationship over time to the replacement of personal watercraft lost with 

other vessels. Lastly, there is also no evidence to support that the small percentage of groups that only use 

personal watercraft will use the reservoir at all, given that their preferred activity is permanently banned. 

A much more likely scenario is that any change in motorized use on the reservoir will occur at a pace 

consistent with current trends, regardless of personal watercraft use. 

Response: The text was modified in the Final Environmental Impact Statement to show the results of the 

analysis of use trends within units of the national park system compared to use trends within Glen Canyon 

National Recreation Area. For all alternatives, the Final Environmental Impact Statement uses a visitor 

use forecast of –2% and +2% average annual change to 2012. The rationale for expected use trends that 

would follow a ban on personal watercraft has been revised in the Final Environmental Impact Statement

under the “Visitor Use and Experience” section, in the “Environmental Consequences” chapter. The 

analysis in the Final Environmental Impact Statement carries forward the assumption from the Draft 

Environmental Impact Statement that, following a ban on personal watercraft the total number of 

watercraft operating hours on the lake would be decreased in the short-term. This is substantiated by 

public comments received from personal watercraft users stating that they would not choose to visit the 

recreation area if personal watercraft were banned. Based on national park system use trends, it is 

assumed however that total watercraft operating hours under alternative C would recover by 2012 to use 

levels similar to the range predicted under alternatives A and B. This would be due to either natural 

growth in visitation (assuming a 2% annual increase in use) or increased visitation by individuals who 

previously avoided the recreation area because of personal watercraft and who would then choose to visit 

if personal watercraft were absent. This assumption is substantiated by public response by non-personal 

watercraft users who commented during the public review period that they would visit the recreation area 

if personal watercraft were banned. 

Public Comment: Commenter: Affiliation: 

1174A Living Rivers Organization 

 

B Comment: Only alternative C prohibits water pollution with fuel discharged into the reservoir from the 

two stroke engines currently used in manufacturing personal watercraft. The Draft Environmental Impact 

Statement notes other laws require the fleet of watercraft manufactured after 2006 should include at least 

75% of watercraft meet low emission standards. The Draft Environmental Impact Statement states that 

12% of personal watercraft used on the reservoir already complied with low emission standards. The 

projection of rapidly progressing towards cleaner personal watercraft in the Glen Canyon National 

Recreation Area seems hopelessly optimistic. The manufacturing of lower emission personal watercrafts 

does not necessarily equate with higher usage of low emission personal watercrafts in any particular 
Personal Watercraft Use Trends and Assumptions

27 

location. In fact locations which do not tightly restrict the use of two stroke engines may be burdened with 

an over representation of the polluting personal watercrafts. 

Response: If implemented, the modified preferred alternative (alternative B) in the Final Environmental 

Impact Statement would require that personal watercraft meet the EPA 2006 emission standards by the 

end of 2012. Personal watercraft not meeting the standards would no longer be allowed to operate in Glen 

Canyon National Recreation Area beginning in 2013. 

The National Park Service expects that by 2012, most personal watercraft owners would already be in 

compliance with the 2006 EPA marine engine standards. The impact on visitors as a result of the 2012 

ban on carbureted two-stroke personal watercraft use is expected to be small. Personal watercraft 

manufacturers currently offer models that are compliant with the EPA 2006 standards, and new personal 

watercraft purchased later than 2006 would already be compliant. The average operating life of a personal 

watercraft is 5 to 10 years, depending upon the source (see the “General Methodology” section in the 

“Environmental Consequences” chapter). As a result, it is expected that the majority of noncompliant 

personal watercraft would no longer be in operation when the engine restrictions proposed under the 

modified preferred alternative (alternative B) take effect in 2012. 

Public Comment: Commenter: Affiliation: 

1245M Sierra Club, Utah Chapter Organization 

 
28 

OTHER NEPA ISSUES

General Comments

Issue 1: The National Park Service Is Headed for a Predetermined Outcome

A Comment: Commenters are concerned that the NPS’ review of personal watercraft and their impact upon 

Glen Canyon resources is directed toward a predetermined outcome. In particular, they believe the 

National Park Service has already rejected alternative C, the no-action alternative, and regardless of the 

environmental impact discovered during the environmental impact statement process, personal watercraft 

will be authorized at Glen Canyon. Materials released to the public, as well as NPS statements to the press 

have led to this conclusion. 

Response: The CEQ regulations, which implement the National Environmental Policy Act (NEPA) of 

1969, define the “preferred alternative” as the agency’s preferred course of action at the time a draft 

environmental impact statement is released for public review (1502.14(e), 40 Questions, 4(a)). The 

National Environmental Policy Act is designed as a planning process that is used for public disclosure of 

the range of reasonable alternatives, the consequences of those alternatives, and the agency’s proposed 

course of action at the time the draft environmental impact statement is released. The NEPA process also 

provides opportunities for public comment on the proposed alternatives and analysis. The Draft and Final 

Environmental Impact Statements contain a full disclosure of impacts associated with discontinued use of 

personal watercraft at the recreation area. Disclosing the proposed preferred alternative in the draft 

environmental impact statement, or in the course of public scoping, does not mean the agency would 

necessarily implement that alternative. Rather, it merely gives the public an opportunity to comment on 

the preferred alternative (along with other alternatives proposed), to suggest other alternatives and 

mitigation measures, and to present information or data to help the agency in its subsequent decision 

making. This Final Environmental Impact Statement contains a “modified preferred alternative” 

(alternative B) that reflects changes and edits in response to public input, among other factors, received 

during the public comment period on the Draft Environmental Impact Statement. The final decision on the 

alternative that will be implemented will be contained in the Record of Decision that will be available no 

sooner than 30 days after the Environmental Protection Agency publishes the Notice of Availability of the 

Final Environmental Impact Statement in the Federal Register. 

Public Comment: Commenter: Affiliation: 

1002R Bluewater Network Organization 

3E Individual 

 

Issue 2: The Draft Environmental Impact Statement Fails to Complete the Requirements of National 

Environmental Policy Act for Completing an Environmental Impact Statement

A Comment: The current Draft Environmental Impact Statement fails to meet the requirements of NEPA in 

several ways. In preparing an environmental impact statement the National Park Service must “provide 

full and fair discussion of significant environmental impacts and shall inform decision makers and the 

public of the reasonable alternatives which would avoid or minimize adverse impacts or enhance the 

quality of the human environment” 40 CFR Sec 1502.1 (emphasis added). The Draft Environmental 

Impact Statement fails to meet the standards required by NEPA for completing an environmental impact 

statement and for this reason the Draft Environmental Impact Statement should be withdrawn and a new 

Draft Environmental Impact Statement with a reasonable set of alternatives should be proposed. 
General Comments

29 

Response: The NPS Director’s Order 12 states that a full range of alternatives must be examined and that 

“the alternatives carried forward for analysis must meet project objectives to a large degree, although not 

necessarily completely.” The National Park Service believes the Draft and Final Environmental Impact 

Statements contain a reasonable range of alternatives under this definition. Objectives were developed, in 

part, from the recreation area’s enabling legislation. 

Public Comment: Commenter: Affiliation: 

1245S Sierra Club, Utah Chapter Organization 

 

Issue 3: Inclusion of Mitigation Measures with Alternatives per NEPA and CEQ Requirements

A Comment: This Draft Environmental Impact Statement does not include examples of best management 

practices to avoid or reduce pollution to the recreation area. We encourage you to use all available 

practices to meet the intent of guidance issued by the Council on Environmental Quality (CEQ) 

integrating pollution prevention opportunities in NEPA planning, documents and decisions (Pollution 

Prevention and the National Environmental Policy Act, CEQ, January 1993). Pertinent provisions of 

executive orders should be addressed in the Final Environmental Impact Statement and the future Lake 

Management Plan referenced in this rule-making. 

Response: Each impact topic contains a summary of the applicable laws and regulations that were applied 

in the analysis of the effects of personal watercraft on Glen Canyon National Recreation Area resources 

and values. 

The NPS Hazardous Waste Management and Pollution Prevention Team have developed a Spill 

Prevention Control and Countermeasures Plan (NPS 1998c) that provides recommendations and 

requirements to prevent environmental damage resulting from the spills of oil. These plans are required by 

the Environmental Protection Agency as stated in 40 CFR, Part 112. All marina operators and National 

Park Service must comply with these requirements and Best Management Practices. The National Park 

Service manages the water of Lake Powell in accordance with the water quality standards of Arizona and 

Utah. Water quality in Lake Powell is regulated by the Arizona and Utah Departments of Environmental 

Quality under water quality standards and regulations that are promulgated in the Arizona Administrative 

Code (R18-11-107) and Utah Administrative Code (R317-2), respectively. Consistent with federal 

regulations, Arizona and Utah have established numerical and narrative standards that protect existing and 

designated uses of state waters and implement the antidegradation requirements. Compliance with the 

numerical standards for water quality is determined at control points that are specified in the regulations. 

In the case of the Draft and Final Environmental Impact Statements, three alternatives for personal 

watercraft management were analyzed. The alternatives also consider means to mitigate the effects of 

personal watercraft on park resources and values, including limiting use in areas where management 

objectives strive to create a visitor experience without intrusion of these vessels or where important park 

resources must be protected. The modified preferred alternative (alternative B) in the Final Environmental 

Impact Statement includes mitigation measures to protect other park users from potential conflicts with 

personal watercraft (refer to the modified preferred alternative section in the “Environmental 

Consequences” chapter, as well as other measures to protect species of special concern and water and air 

resources). Phasing out of carbureted two-stroke personal watercraft at the end of 2012 under the 

modified preferred alternative (alternative B) would further mitigate impacts of these vessels on recreation 

area resources. The National Park Service finds that the modified preferred alternative, if implemented, 

including the provision for continued personal watercraft use, would not result in an impairment of park 

resources and values for which the Glen Canyon National Recreation Area was established. 

Public Comment: Commenter: Affiliation: 

1393AA Environmental Protection Agency Public Agency 

 
30 

PURPOSE AND NEED

Current Personal Watercraft Regulatory Framework

Issue 1: Compliance with Bluewater Network Court Settlement

A Comment: The draft environmental impact statement does not comply with the court settlement 

agreement between the National Park Service and Bluewater Network regarding the analysis of effect 

personal watercraft have on recreation area resources. It appears that in several instances in the draft 

environmental impact statement, the National Park Service has overlooked relevant information, reached 

baseless conclusions, submitted contradictory information, and not conducted current site-specific studies 

of personal watercraft impacts, thereby violating this agreement. 

Response: A summary of the NPS rulemaking process and associated personal watercraft litigation is 

contained under “Personal Watercraft Regulatory Framework” in the “Purpose of and Need for Action” 

chapter. The National Park Service believes it has complied with the court order and has assessed the 

impacts of personal watercraft on those resources specified by the judge, as well as other resources that 

could be affected. These analyses were done for every applicable impact topic with the best available 

data, as required by the CEQ regulations (40 CFR 1502.22). Where data was lacking, best professional 

judgment prevailed using assumptions and extrapolations from scientific literature, other park units where 

personal watercraft are used, and personal observations of park staff. 

 

Public Comment: Commenter: Affiliation: 

1002S Bluewater Network Organization 

1168H American Canoe Association Organization 

 

Issue 2: Prescribing Personal Watercraft Use under the Superintendent’s Compendium Was Appropriate

A Comment: We disagree with certain special interest groups’ assertion that the NPS’ personal watercraft 

Final Rule was “arbitrary and capricious.” We believe the enabling legislation of Glen Canyon 

specifically supports the use of all forms of watercraft and that the National Park Service was well within 

its realm of authority in prescribing personal watercraft use within the context of the Superintendent’s 

Compendium. 

Response: The settlement agreement and the final personal watercraft rule did not supercede or overturn 

Glen Canyon’s enabling legislation. Both the personal watercraft settlement agreement (described in 

“Personal Watercraft Use Regulatory Background” in the “Purpose of and Need for Action” chapter) and 

the authorizing legislation for Glen Canyon were considered when developing alternatives for this 

environmental impact statement. 

The “Introduction” section in the “Purpose of and Need for Action” chapter states that the overall 

objective for the plan is to evaluate a range of alternatives and strategies to manage personal watercraft 

with the goal of ensuring protection of recreation area resources and values. This objective was derived 

from the enabling legislation for Glen Canyon National Recreation Area. As further stated in this section, 

an analysis on the management of personal watercraft is provided under each alternative to meet the terms 

of the settlement agreement between the Bluewater Network and the National Park Service. As a result, 

the alternatives presented in the Draft and Final Environmental Impact Statements protect resources and 

values while providing recreational opportunities at Glen Canyon National Recreation Area. As required 

by the settlement agreement and NPS Management Policies, the impacts associated with personal 

watercraft and other recreational uses are evaluated under each alternative (refer to the “Environmental 

Consequences” chapter) to determine the potential for impairment to park resources. The National Park 
Current Personal Watercraft Regulatory Framework

31 

Service finds that the modified preferred alternative (alternative B), including the provision for personal 

watercraft use, would not result in impairment of park resources and values for which the Glen Canyon 

National Recreation Area was established. Thus, by ensuring resources are protected for future 

generations, the National Park Service is representing the interests of the general public. 

 

Public Comment: Commenter: Affiliation: 

1178B ARAMARK Business 

830E Individual 

 
32 

NPS Interpretation of Impairment Policies & Mandates

Issue 1: Compliance with NPS Director’s Orders

A Comment: The National Parks Omnibus Management Act requires the National Park Service to base its 

resource management decisions upon scientific and technical information. Moreover, Director’s Order 12

(DO 12) says that if such information cannot be obtained, the National Park Service will modify a 

proposed action “to eliminate the action causing the unknown or uncertain impact or other alternatives 

will be selected.” DO 12 also states that when it is not possible to eliminate an activity with unknown or 

uncertain potential impacts, the National Park Service will provide background on the completeness of 

such information, the relevance of missing information, a summary of adverse impacts, and an evaluation 

of those impacts. 

It appears that the National Park Service at Glen Canyon has concluded that much information regarding 

personal watercraft use is too expensive and/or impossible to collect. The National Park Service 

determination at Glen Canyon that personal watercraft cannot be eliminated from the preferred alternative 

runs counter to the actions at dozens of parks across the country that have prohibited these machines. 

Bluewater Network believes that a proper reading of the stipulations in DO 12 requires the National Park 

Service to choose an alternative which eliminates personal watercraft operation. 

Response: A summary of the NPS rulemaking process and associated personal watercraft litigation is 

contained under “Personal Watercraft Regulatory Framework” in the “Purpose of and Need for Action” 

chapter. The National Park Service believes it has complied with the court order and has assessed the 

impacts of personal watercraft on those resources specified by the judge, as well as other resources that 

could be affected. These analyses were done for every applicable impact topic with the best available 

data, as required by CEQ regulations (40 CFR 1502.22). Where data was lacking, best professional 

judgment prevailed using assumptions and extrapolations from scientific literature, other park units where 

personal watercraft are used, and personal observations of park staff. 

Regarding compliance with Director’s Order 12, the order states that a full range of alternatives must be 

examined and that “the alternatives carried forward for analysis must meet project objectives to a large 

degree, although not necessarily completely.” The National Park Service believes the Draft and Final 

Environmental Impact Statements contain a reasonable range of alternatives under this definition. 

In the case of the Draft and Final Environmental Impact Statements, three alternatives were analyzed 

under various personal watercraft scenarios. The alternatives also consider means to mitigate the effects of 

personal watercraft on park resources and values, including limiting use in areas where management 

objectives strive to create a visitor experience without intrusion of these vessels or where important park 

resources must be protected. The modified preferred alternative (alternative B) in the Final Environmental 

Impact Statement includes mitigation measures to protect other park users from potential conflicts with 

personal watercraft (refer to the discussion for the modified preferred alternative [alternative B] in the 

“Environmental Consequences” chapter, as well as other measures to protect species of special concern 

and water and air resources). 

The National Park Service finds that implementation of the modified preferred alternative (alternative B) 

presented in the Final Environmental Impact Statement (including the provision for continued personal 

watercraft use) would not result in an impairment of park resources and values for which the Glen Canyon 

National Recreation Area was established. 

Public Comment: Commenter: Affiliation: 

1002Q Bluewater Network Organization 

 
NPS Interpretation of Impairment Policies & Mandates

33 

Issue 2: Continued Personal Watercraft Use is in Violation of Federal Laws and Policies

A Comment: Several comments were received citing the Organic and Redwood Acts and the mission of the 

National Park Service to leave the resources and wildlife “unimpaired for future generations.” A number 

of letters were received stating federal law clearly prohibits activities that impair or derogate the 

recreation area resources. 

Response: The “Summary of Laws and Policies” section in the “Environmental Consequences” chapter 

summarizes the three overarching laws that guide the National Park Service in making decisions 

concerning protection of park resources. These laws, as well as others, are also reflected in the NPS 

Management Policies. An explanation of how the Park Service applied these laws and policies to analyze 

the effects of personal watercraft on Lake Powell resources and values can be found under “Impairment 

Analysis” in the “Methodology” section of the “Environmental Consequences” chapter. An impairment to 

a particular park resource or park value must rise to the magnitude of a major impact, as defined by its 

context, duration, and intensity and must also affect the ability of the National Park Service to meet its 

mandates as established by congress in Glen Canyon National Recreation Area’s enabling legislation. For 

each resource topic, the Final Environmental Impact Statement establish thresholds or indicators of 

magnitude of impact. An impact approaching a “major” level of intensity is one indication that 

impairment could result. For each impact topic, when the intensity approached “major,” the 

interdisciplinary planning team would consider mitigation measures to reduce the potential for “major” 

impacts, thus reducing the potential for impairment. In response to growing concern regarding potential 

impacts of personal watercraft use, the National Park Service began an extensive review and regulation 

process. While comments were received opposing continued use of personal watercraft within units of the 

Park Service, other comments supported its use, under certain conditions designed to protect park 

resources and values. Recognizing that some units needed to complete more local planning and analyses 

of impacts, the final servicewide personal watercraft regulation allowed for local decision making on a 

park-by-park basis. 

Both the servicewide regulation and subsequent court settlement between the Bluewater Network and 

National Park Service acknowledged that park units proposing to continue personal watercraft use must 

complete an analysis of impacts, including a thorough analysis of the enabling legislation, its management 

objectives, and Glen Canyon National Recreation Area resources and values potentially affected by 

continued use. While public comment on continued personal watercraft use is considered, it is done so 

while also taking into account these other factors. 

In the case of the Draft and Final Environmental Impact Statements, three alternatives were analyzed 

under various personal watercraft scenarios. The alternatives also consider means to mitigate the effects of 

personal watercraft on park resources and values, including limiting use in areas where management 

objectives strive to create a visitor experience without intrusion of these vessels or where important park 

resources must be protected. The modified preferred alternative (alternative B) in the Final Environmental 

Impact Statement includes mitigation measures to protect other park users from potential conflicts with 

personal watercraft (refer to the discussion for alternative B in the “Environmental Consequences” 

chapter, as well as other measures to protect species of special concern and water and air resources). 

The National Park Service finds that the modified preferred alternative (alternative B) presented in the 

Final Environmental Impact Statement (including the provision for continued personal watercraft use) 

would not result in an impairment of park resources and values for which the Glen Canyon National 

Recreation Area was established. 

 

Public Comment: Commenter: Affiliation: 

1174D Living Rivers Organization 

1002O Bluewater Network Organization 

 
PURPOSE AND NEED

34 

Issue 3: Recreational Opportunities and the Protection of Resources

A Comment: There is absolutely no reason why any federally managed lands anywhere should allow these 

highly polluting two-stroke engines to operate in such massive numbers. The damage is unavoidable and 

extreme. The density of personal watercraft use within Glen Canyon National Recreation Area just 

compounds this issue. Powell may hold a lot of water, but there are literally tons and tons and tons of 

unburned petroleum being dumped into the reservoir on a regular basis. Recreation can never justify the 

slow but sure destruction of an entire ecosystem. 

Response: The Final Environmental Impact Statement addresses water quality protection at Glen Canyon 

National Recreation Area and provides an analysis of surface water quality impacts. The “Water Quality” 

section (in the “Environmental Consequences” chapter) describes the estimated minimum threshold 

volume of water in Lake Powell for which concentrations of gasoline constituents from personal 

watercraft or other outboard engines would be potentially toxic to aquatic organisms or humans. Using the 

estimated threshold volumes, the surface area of the minimum lake pools, and the chemicals identified, it 

is possible to identify unacceptable risks to human health or the environment. There are a limited number 

of EPA criteria for the protection of human health (via ingestion of water and aquatic organisms or 

ingestion of aquatic organisms only). Chronic ecotoxicological and human health benchmarks for 

contaminants were acquired from various sources. The evaluation presents the most restrictive thresholds 

for the pollutants, based on both federal and state water quality standards. 

The modified preferred alternative (alternative B) in the Final Environmental Impact Statement includes 

mitigation measures to further protect park resources. Under the modified preferred alternative, personal 

watercraft engines would be 100% compliant after 2012, which will further reduce petroleum-related 

pollution. Based on the analysis presented, the National Park Service finds that, if implemented, the 

modified preferred alternative (alternative B) presented in the Final Environmental Impact Statement

(including the provision for continued personal watercraft use) would not result in an impairment of park 

water quality. 

Public Comment: Commenter: Affiliation: 

139C Individual 

 
35 

Park Legislation/Authority

Issue 1: Restricting Personal Watercraft Conflicts with Agency’s Mandate to Maximize Recreational Use

A Comment: Alternative C, the No Action, banning personal watercraft, is in direct contradiction to Public 

Law 92-593, which established Glen Canyon National Recreation Area in 1972, and its general 

management plan NPS 1978a. 

Response: The settlement agreement between Bluewater Network and the National Park Service did not 

supercede or overturn any legislation. Both the personal watercraft settlement agreement (described in 

“Personal Watercraft Use Regulatory Background” in the “Purpose of and Need for Action” chapter) and 

the authorizing legislation for Glen Canyon National Recreation Area were considered when developing 

alternatives to be analyzed in the Draft and Final Environmental Impact Statements. 

The “Introduction” section in the “Purpose of and Need for Action” chapter states that the overall 

objective for the plan is to evaluate a range of alternatives and strategies to manage personal watercraft 

use, with the goal of ensuring protection of recreation and resource values. This objective was derived 

from the enabling legislation for Glen Canyon National Recreation Area. As further stated in this section, 

a special analysis on the management of personal watercraft was also provided under each alternative to 

meet the terms of the settlement agreement between the Bluewater Network and the National Park 

Service. 

As a result, the alternatives presented in the Draft and Final Environmental Impact Statements protect 

resources and values while providing recreational opportunities at Glen Canyon National Recreation Area. 

As required by the settlement agreement and NPS Management Policies, the impacts associated with 

personal watercraft and other recreational uses are evaluated under each alternative (refer to the 

“Environmental Consequences” chapter) to determine the potential for impairment to park resources. The 

National Park Service finds that the modified preferred alternative (alternative B), which allows for 

personal watercraft use, would not result in impairment of park resources and values for which the Glen 

Canyon National Recreation Area was established. Thus, by ensuring resources are protected for future 

generations, the National Park Service is representing the interests of the general public. 

Public Comment: Commenter: Affiliation: 

170D Individual 

 

Issue 2: Restricting Personal Watercraft Conflicts with Agency’s Mandate to Maximize Recreational Use

A Comment: Alternative B would deny operators of personal watercraft access to the important areas of the 

full pool shoreline of Lake Powell. In times of low lake level, much of the 25-mile section of the 

Colorado River channel proposed for closure is flowing water that provides a novel and unparalleled 

experience for personal watercraft users. This conflicts with the agency’s mandate to maximize 

recreational use of the recreation area. 

Response: Under low water conditions, such as those that presently exist, it is almost impossible to go 

upstream in a personal watercraft. The channel is meandering, muddy, and unsafe. It is neither appropriate 

nor realistic for personal watercraft use to be allowed under those conditions. 

Public Comment: Commenter: Affiliation: 

1239M Utah Shared Access Alliance Organization 

 
PURPOSE AND NEED

36 

Issue 3: Protection of Resources under the Recreation Area’s Enabling Legislation and General 

Management Plan

A Comment: Glen Canyon’s enabling legislation states that the area was established to “Provide for public 

outdoor recreation use and enjoyment of Lake Powell and lands adjacent thereto in the States of Arizona 

and Utah and to preserve the scenic, scientific, and historic features contributing to public enjoyment of 

the area” (PL 92-593). The natural soundscape, the aquatic environment, and the solitude of many of Lake 

Powell’s canyons are critical components of the scenic, scientific, and historic features that National Park 

Service must protect. 

Response: NPS Management Policies for soundscapes (section 4.9), as stated in Management Policies, 

require superintendents to “identify what levels of human-caused sound can be accepted within the 

management purposes of parks. The sound considered acceptable will vary throughout Glen Canyon 

National Recreation Area, being generally greater in developed areas and generally lesser in undeveloped 

areas . . .. The service will take action to prevent or minimize all noise that . . . exceeds levels that have 

been identified as being acceptable to, or appropriate for, visitor uses at the sites being monitored.” 

Management Policies for Visitor Use (section 8.2) indicate that unless mandated by statute, the National 

Park Service will not allow visitors to conduct activities that would unreasonably interfere with the 

atmosphere of peace and tranquility, or the natural soundscape maintained in wilderness and natural, 

historic, or commemorative locations within Glen Canyon National Recreation Area. 

As written in its enabling legislation, the management purpose of Glen Canyon National Recreation Area 

is to provide public recreation, benefit, and use in a manner that will preserve, develop, and enhance, so 

far as practicable, the recreation potential and preserve the scenic, historic, scientific, and important 

features of the area. Various levels of sound are associated with some of those uses, such as boating and 

personal watercraft, and are consistent with Glen Canyon National Recreation Area’s purpose as defined 

by its enabling legislation. 

To provide a “peaceful and tranquil” experience in some locations, personal watercraft use would be 

prohibited. These prohibitions or restrictions would provide for a peaceful and tranquil visitor experience. 

All alternatives include plans and policies for enforcement of noise regulations. These elements, which 

are contained in this Final Environmental Impact Statement, are consistent with NPS Management 

Policies for soundscapes. As required by the settlement agreement and NPS Management Policies, the 

impacts associated with personal watercraft and other recreational uses are evaluated under each 

alternative (refer to the “Environmental Consequences” chapter) to determine the potential for impairment 

to park resources. The National Park Service finds that the modified preferred alternative (alternative B), 

which allows for personal watercraft use, would not result in impairment of park resources and values for 

which the Glen Canyon National Recreation Area was established. Thus, by ensuring resources are 

protected for future generations, the National Park Service is representing the interests of the general 

public. 

Public Comment: Commenter: Affiliation: 

1248C National Park Conservation 

Association 

Organization 

 

B Comment: Glen Canyon National Recreation Area’s 1979 General Management Plan does state that the 

recreation’s primary management objective is to “[provide] maximal recreational enjoyment to the 

American public and their guests.” NPS laws and policies - and substantial case law - however, make 

clear that managers must not permit any recreational activities that derogate the values embodied in, and 

the purpose defined by, the Organic Act. If the Park Service is to succeed in its mission to preserve parks 

‘unimpaired for future generations,” it must be vigilant - more vigilant than it has been in the past - about 

preventing inappropriate recreation to gain a foothold in park units. The Park Service’s own Management 

Policies tell managers that they “must always seek ways to avoid, or to minimize to the greatest degree 

practicable, adverse impacts on park resources and values (NPS Management Policies at 1.4.3).” Through 
Park Legislation/Authority

37 

its original system-wide personal watercraft rulemaking, the National Park Service acknowledged that 

personal watercraft cause resource degradation and disturb other visitors. 

Response: The impact of the elimination of personal watercraft was considered under alternative C. 

Elimination of personal watercraft is not being included under the modified preferred alternative 

(alternative B) because it was determined in the analysis of the modified preferred alternative (alternative 

B) in the Draft Environmental Impact Statement that personal watercraft use would not result in 

impairment to park resources and is consistent with Glen Canyon National Recreation Area’s purpose and 

management objectives defined by the enabling legislation for recreation area. What constitutes 

impairment is defined by resource in the “Methodology” section of the “Environmental Consequences” 

chapter. 

Public Comment: Commenter: Affiliation: 

1174E Living Rivers Organization 

1248D National Parks Conservation 

Association 

Organization 

 

C Comment: Since personal watercraft were not part of the recreational mix at the time of the enabling 

legislation it does not follow that personal watercraft are consistent with the enabling legislation. It is not 

clear that restricting or eliminating personal watercraft is inconsistent with the enabling legislation. 

Response: The settlement agreement did not supercede or overturn Glen Canyon National Recreation 

Area’s enabling legislation. Both the personal watercraft settlement agreement (described in “Personal 

Watercraft Use Regulatory Background” in the “Purpose of and Need for Action” chapter) and the 

authorizing legislation for Glen Canyon were considered when developing alternatives for the 

environmental impact statement. 

The “Introduction” section in the “Purpose of and Need for Action” chapter states that the overall 

objective for the plan is to evaluate a range of alternatives and strategies for personal watercraft use to 

ensure protection of the recreation and resource values provided at Glen Canyon National Recreation 

Area. This objective was derived from the enabling legislation for Glen Canyon National Recreation 

Area. As further stated in this section, an analysis on the management of personal watercraft is provided 

under each alternative to meet the terms of the settlement agreement between the Bluewater Network and 

the National Park Service. As a result, the alternatives presented in the Draft and Final Environmental 

Impact Statements protect resources and values while providing recreational opportunities at Glen Canyon 

National Recreation Area. As required by the settlement agreement and NPS Management Policies, the 

impacts associated with personal watercraft and other recreational uses are evaluated under each 

alternative (refer to the “Environmental Consequences” chapter) to determine the potential for impairment 

to park resources. The National Park Service finds that implementation of the modified preferred 

alternative (alternative B), including the provision for personal watercraft use, would not result in 

impairment of park resources and values for which the Glen Canyon National Recreation Area was 

established. Thus, by ensuring resources are protected for future generations, the National Park Service is 

representing the interests of the general public. 

Public Comment: Commenter: Affiliation: 

1245D Sierra Club, Utah Chapter Organization 

 

D Comment: It is quite clear that the entire Lake Powell experience has been designed to further the interests 

of those who manufacture internal combustion engines and those who sell petroleum products. There is no 

evidence that anyone has considered the interests of those such as myself who wish to hike and kayak the 

areas around Powell Reservoir in combustion-free peace. This appears to be in gross violation of the 

mandate given to the National Park Service. The promotion of recreation over other concerns—such as 

habitat and water quality—is obscene. The obscenity is further compounded when those forms of 

recreation which are the least damaging to habitat health and human enjoyment—i.e., non-polluting 
PURPOSE AND NEED

38 

activities such as hiking and kayaking—are consistently ignored in favor of more development to support 

motorized access. 

Response: The Draft and Final Environmental Impact Statements were not written to be vehicles to lobby 

for more petroleum-based recreation, or as an effort to undermine the enabling legislation. The objectives 

for the plan were derived from the enabling legislation for Glen Canyon National Recreation Area, which 

provides for management of the recreation area for public outdoor recreation and enjoyment of Lake 

Powell and adjacent lands and for the preservation of the scenic, historic, scientific, and other important 

features of the area. 

Glen Canyon National Recreation Area is a unit of the national park system and is managed under the 

same laws and policies as all units in the system. The NPS Organic Act of 1916 directs the National Park 

Service to manage units “to conserve the scenery and the natural and historic objects and the wildlife 

therein and to provide for the enjoyment of the same in such a manner as will leave them unimpaired for 

the enjoyment of future generations.” Congress reiterated this mandate in the Redwood National Park 

Expansion Act of 1978, by stating that the National Park Service must conduct its actions in a manner that 

will ensure no “derogation of the values and purposes for which these various areas have been established, 

except as may have been or shall be directly and specifically provided by Congress.” While the enabling 

legislation of Glen Canyon National Recreation Area does provide for the management of public 

recreation, it also provides for the preservation of the scenic, historic, scientific, and other important 

features of the area as discussed in the “Background” section of the “Purpose of and Need for Action” 

chapter. 

Public Comment: Commenter: Affiliation: 

139B Individual 

 

Issue 4: Potential Conflicts with General Management Plan

A Comment: “The Draft Environmental Impact Statement failed to identify potential conflicts between 

personal watercraft management alternatives and Glen Canyon National Recreation Area’s General 

Management Plan objectives relating to the Natural Zone. Clearly, alternative C goes the farthest in 

achieving these objectives. 

 It is apparent from the text on page 26 that Glen Canyon National Recreation Area has failed to act in 

accordance with its General Management Plan regarding motorized personal watercraft impacts on the 

Natural Zone. Noise from motorized personal watercraft can be heard distinctly from various points up to 

2 miles (p. 102) from the nearest lake surface. Obviously, personal watercraft management alternatives do 

affect the lands in question, and the Glen Canyon National Recreation Area’s own general management 

plan, with its directive to manage the Natural Zone as wilderness, should have been identified as having 

potential conflicts with personal watercraft management alternatives. 

 Since roughly half of the Lake Powell shoreline is within the Natural Zone, common sense would dictate 

that one or more Draft Environmental Impact Statements, Alternatives should have examined eliminating 

motorized personal watercraft use in some or all of those canyons adjoining the Natural Zone shoreline 

areas while still allowing personal watercraft in the large areas of Lake Powell with shorelines not 

adjacent to the Natural Zone. These alternatives would have met the objectives of the Glen Canyon 

National Recreation Area general management plan and would have also provided a middle ground 

between the status quo A and B alternatives and the total ban of alternative C. 

Response: There is a potential conflict in the management objectives between the Recreation and 

Resource Utilization Zone and the Natural Zone that is extremely difficult to avoid because the zones are 

adjacent to each other. However, the percentage of the Natural Zone that may be adversely affected by 

personal watercraft noise is small. The noise generated by watercraft, including personal watercraft, is 

consistent with Glen Canyon National Recreation Area’s enabling legislation “to provide for public 

outdoor recreation use and enjoyment of Lake Powell and the lands adjacent thereto.” The preparation of 
Park Legislation/Authority

39 

a lake management plan, which is included as an element of all alternatives in the Final Environmental 

Impact Statement, will provide an opportunity for the National Park Service to further evaluate impacts 

from all lake uses to recreation area resources, including soundscape. 

Public Comment: Commenter: Affiliation: 

1180D Sierra Club, Utah Chapter Individual 

 
40 

Scope of the Analysis 

Issue 1: Rainbow Bridge National Monument Should be Included in the Analysis

A Comment: The Draft Environmental Impact Statement does not include any provision for the long-term 

management of the Rainbow Bridge National Monument, which should be included in the Glen Canyon 

lake management plan. 

Response: Rainbow Bridge National Monument is a separate unit of the National Park Service. The scope 

of the Draft and Final Environmental Impact Statements is on management of personal watercraft within 

Glen Canyon National Recreation Area. Personal watercraft use at Rainbow Bridge National Monument 

is currently prohibited as a result of the National Park Service amended regulation that was implemented 

in March 2000 (36 CFR 3.24 (a), 2000). 

Public Comment: Commenter: Affiliation: 

1175B American Watercraft Association Organization 

 

Issue 2: Why Is the Focus on Personal Watercraft?

A Comment: Many commenters questioned why the focus of the analysis was on personal watercraft alone 

when other motorized watercraft have similar or greater impacts on park resources. 

Response: Although the personal watercraft industry has claimed personal watercraft cannot be regulated 

differently than other motorboats, the National Park Service determined that personal watercraft are 

different from conventional motorboats and finalized personal watercraft-specific regulations in March 

2000. The NPS definition of personal watercraft is as follows: “Personal watercraft refers to a vessel, 

usually less than 16 feet in length, which uses an inboard, internal combustion engine powering a water 

jet pump as its primary source of propulsion. The vessel is intended to be operated by a person or persons 

sitting, standing, or kneeling on the vessel, rather than within the confines of the hull” (see “Personal 

Watercraft Use Regulatory Background” in the “Background” section of the “Purpose of and Need for 

Action” chapter). 

As discussed in the “Alternatives” chapter, the National Park Service evaluated and chose the best 

regulatory approach in the modified preferred alternative (alternative B) in the Draft Environmental 

Impact Statement and the modified preferred alternative (alternative B) in the Final Environmental Impact 

Statement) in order to maintain the opportunities for various types of recreation while protecting the 

resources of Glen Canyon National Recreation Area. 

 

Public Comment: Commenter: Affiliation: 

1393E Environmental Protection Agency Public Agency 

7A, 827C, 608B Individual 

 

Issue 3: Personal Watercraft Should Not Be Singled Out for Regulation

A Comment: Commenters, including the Personal Watercraft Industry Association and the National Marine 

Manufacturers Association, advocate that any regulation or restriction on personal watercraft by the 

National Park Service should be uniformly applied to all motorized recreational vessel. By allowing other 

motorized vessels to operate in some of the proposed restricted areas would undermine the purported 

goals of reducing user conflicts and allowing for solitude and quiet. Closing these river areas to personal 

watercraft, and not other motorized vessels, would be discriminatory. 

Response: The plan was not designed to determine if personal watercraft caused more environmental 

damage to park resources than other boats, but rather, to determine if personal watercraft use was 
Scope of the Analysis

41 

consistent with Glen Canyon National Recreation Area’s enabling legislation and management goals and 

objectives. The overall objective is to meet the terms of the settlement agreement with Bluewater Network 

(see “Introduction” in the “Purpose of and Need for Action” chapter). An analysis was done on the 

management of personal watercraft in order to meet the terms of the settlement agreement between 

Bluewater Network and the National Park Service. With completion of this Final Environmental Impact 

Statement, the National Park Service may either take action to adopt special regulations to manage 

personal watercraft use at Glen Canyon, or may choose to discontinue personal watercraft use. The 

alternatives listed were based upon the best information available. As noted by the commenter, the 

management actions under the modified preferred alternative (alternative B) for the San Juan, Escalante, 

Colorado, and Dirty Devil Rivers would be implemented to reduce visitor conflicts with river rafters, 

fishermen, and backcountry hikers; promote opportunities for quiet and solitude; and ensure visitor safety. 

Following completion of this Final Environmental Impact Statement, it remains within NPS authority to 

prescribe similar use restrictions on all watercraft through the Superintendent’s Compendium. 

As required by the settlement agreement and NPS Management Policies, the impacts associated with 

personal watercraft and other recreational uses are evaluated under each alternative (refer to the 

“Environmental Consequences” chapter) to determine the potential for impairment to park resources. The 

National Park Service finds that the modified preferred alternative (alternative B), which allows for 

personal watercraft use, would not result in impairment of park resources and values for which the Glen 

Canyon National Recreation Area was established. 

 

Public Comment: Commenter: Affiliation: 

1344U, 1344D, 1344N Personal Watercraft Industry 

Association 

Organization 

1176B National Marine Manufacturers 

Association 

Organization 

 

B Comment: A number of commenters, including the Personal Watercraft Industry Association and the 

National Marine Manufacturers Association, proposed that the flat-wake zone should apply to all 

motorized vessels. Restricting only personal watercraft to flat-wake speeds presents a safety hazard if 

other vessels are permitted to operate at significantly faster speeds. 

Response: The plan was not designed to determine if personal watercraft caused more environmental 

damage to park resources than other boats, but rather, to determine if personal watercraft use was 

consistent with Glen Canyon National Recreation Area’s enabling legislation and management goals and 

objectives. The overall objective is to meet the terms of the settlement agreement with Bluewater Network 

(see “Introduction” in the “Purpose of and Need for Action” chapter). An analysis was done on the 

management of personal watercraft in order to meet the terms of the settlement agreement between 

Bluewater Network and the National Park Service. With completion of this Final Environmental Impact 

Statement, the National Park Service may either take action to adopt special regulations to manage 

personal watercraft use at Glen Canyon, or may choose to discontinue personal watercraft use. 

The alternatives listed were based upon the best information available. The management actions under 

alternative B (modified preferred alternative) for the San Juan, Escalante, Colorado, and Dirty Devil 

Rivers would be implemented to reduce visitor conflicts with river rafters, fishermen, and backcountry 

hikers; promote opportunities for quiet and solitude; and ensure visitor safety. 

Under Utah State law, all boaters must operate at flat-wake speeds or idle speed within 150 feet of another 

boat, a person in or floating on the water, a waterskier (except those being towed), a shore fisherman, a 

launching ramp, a dock, or a designated swimming area. Arizona State law requires all boaters to operate 

at flat-wake speeds within 60 feet of another vessel. The modified preferred alternative (alternative B) 

addresses signing, buoys, and boater education that will enhance other watercraft operators observance of 

safe boating practices. 
PURPOSE AND NEED

42 

 

Public Comment: Commenter: Affiliation: 

1344T, 1344D Personal Watercraft Industry 

Association 

Organization 

1176C National Marine Manufacturers 

Association 

Organization 

 

Issue 4: Personal Watercraft Can Be Singled Out for Regulation

A Comment: The personal watercraft industry has claimed that personal watercraft are recognized by the US 

Coast Guard (USCG) as “class A” vessels and therefore cannot be regulated differently than other 

motorboats. However, the USCG states that the term “class-A vessel” has no meaning insofar as Coast 

Guard regulations are concerned (see enclosed USCG letter). To date, the USCG has refrained from 

defining personal watercraft. Rather, the Coast Guard encourages other government agencies to define the 

craft. The National Park Service determined that personal watercraft are different from conventional 

motorboats and finalized personal watercraft-specific regulations in March of 2000. 

Response: The NPS definition of personal watercraft is as follows: “Personal watercraft refers to a vessel, 

usually less than 16 feet in length, which uses an inboard, internal combustion engine powering a water 

jet pump as its primary source of propulsion. The vessel is intended to be operated by a person or persons 

sitting, standing, or kneeling on the vessel, rather than within the confines of the hull” (see “Personal 

Watercraft Use Regulatory Background” in the “Background” section of the “Purpose of and Need for 

Action” chapter). 

Public Comment: Commenter: Affiliation: 

1002C Bluewater Network Organization 

 

B Comment: The personal watercraft industry has long maintained that personal watercraft riders have a 

“right” to use any boating infrastructure built using funds appropriated under the Federal Aid in Sport 

Fish Restoration Act (FASFRA). However, a 1999 Florida lawsuit negates this claim. In Kissimmee River 

Valley Sportsman’s Association v. The City of Lakeland (60 F. Supp. 2d 1289), the United States District 

Court in Florida ruled that FASFRA does not create a federal right to equal access for boats of common 

horsepower ratings at boat launch facilities constructed or maintained under the Act. This case suggests 

that government agencies may prohibit personal watercraft regardless of whether they have used 

FASFRA funds to construct boat launches and facilities. 

Response: All launch facilities are constructed with federal or federal/state funding. Funds provided 

through the NPS Fee Demo program and concessioner fees have been used for the construction of new 

launch ramps, courtesy docks, floating boat-pump-out stations, first-aid stations, and parking areas. 

Federal Aid in Sport Fish Restoration Act (FASFRA) funding has not been used at Glen Canyon National 

Recreation Area to build launches or facilities. 

Public Comment: Commenter: Affiliation: 

1002D Bluewater Network Organization 

 
43 

RECREATION AREA OPERATIONS

Enforcement

Issue 1: Enforce the Existing Sound Standard

A Comment: The sound standard at the Glen Canyon National Recreation Area is 82 decibels at 82 feet at 

full acceleration, a standard that is met by every unmodified personal watercraft. If particular modified 

personal watercraft exceed this limit, then they should be cited and/or removed from the waters of Lake 

Powell. This standard can, and should be met under alternative A. 

Response: Regulations regarding noise are enforced by state and federal visitor protection staff at Glen 

Canyon National Recreation Area. Appropriate enforcement action is taken against any vessel exceeding 

the noise standards. 

Public Comment: Commenter: Affiliation: 

1239F Utah Shared Access Alliance Organization 

 

Issue 2: Park Service Should Enforce Regulations such as Speed Limits on the Lake

A Comment: Although the accident rate this year has been better than the past years, I still see this issue as 

very important. Sufficient laws are in place to protect visitors however there needs to be more 

enforcement of these laws. 

Response: An element of alternative B (the modified preferred alternative) is to seek increased funding to 

provide additional law enforcement at Glen Canyon National Recreation Area to enforce the existing 

regulations. An increased number of law enforcement officers on the lake would have the added 

advantage of increasing the number of visitor contacts on the lake to prevent unsafe behavior. In addition, 

an active information and education program, also an element of the modified preferred alternative 

(alternative B), would help to reduce the need for enforcement actions. 

Public Comment: Commenter: Affiliation: 

156B, 156E Individual 

 

Issue 3: Cooperation with Other Agencies

A Comment: The Park Service should work with multi-jurisdictional law enforcement in order to enforce 

existing sound standards. 

Response: Regulations regarding boating noise exist at the state and federal levels. Sound standards are 

enforced at the recreation area by both state and federal visitor protection staff. See the “Soundscape” 

section of the “Affected Environment” chapter and appendix B for the specific laws. As stated in the 

Final Environmental Impact Statement, NPS rangers and personnel from the U.S. Coast Guard enforce 

both state and federal boating laws. Patrol officers from Utah State Parks and Recreation and Arizona 

Game and Fish Department enforce state boating laws. 

Public Comment: Commenter: Affiliation: 

1239H Utah Shared Access Alliance Organization 

 
44 

Impacts of Personal Watercraft Use

Issue 1: Additional Restrictions will Dilute Law Enforcement Effectiveness

A Comment: Additional rulemaking and restrictions on personal watercraft use will only serve to further 

dilute the presence of law enforcement in the recreation area. 

Response: The analyses in the Final Environmental Impact Statement acknowledge that new personal 

watercraft restrictions associated with alternatives B or C would have a short-term minor adverse effect on 

visitor protection staff. However, the adverse effects would decrease over time as visitors become familiar 

with the restrictions and as newly closed areas and flat-wake zones become self-regulating after signs and 

markers are installed. 

Public Comment: Commenter: Affiliation: 

1178F ARAMARK Business 

 

B Comment: National Park Service efforts to seek additional funding for increased law enforcement 

activities are independent of any management alternative. Simply put, existing laws already govern the 

actions of all boaters. Additional law enforcement presence would benefit all boaters whether or not a 

personal watercraft management plan is implemented. 

Response: We agree with the commenter that increased law enforcement would benefit all boaters at the 

recreation area. Glen Canyon National Recreation Area is indeed seeking additional funding for law 

enforcement in order to increase visitor safety independently of this environmental impact analysis 

process for personal watercraft rulemaking at the recreation area. 

Public Comment: Commenter: Affiliation: 

1178F ARAMARK Business 

 

Issue 2: Increase Monitoring of the Type of Watercraft Entering the Recreation Area

A Comment: The explosion of personal watercraft on the lake has made the existing laws unenforceable. 

The size and shape of Lake Powell demands that stringent monitoring of what goes into the lake occurs 

before the watercraft launch, not afterwards. 

Response: The modified preferred alternative (alternative B) in the Final Environmental Impact 

Statement would require that personal watercraft meet the EPA 2006 emission standards by the end of 

2012. Personal watercraft not meeting the standards would no longer be allowed to operate in Glen 

Canyon National Recreation Area beginning in 2013. 

The National Park Service expects that by 2012, most personal watercraft owners would already be in 

compliance with the EPA 2006 marine engine standards. The impact on recreation area operations 

resulting from the 2012 ban on carbureted two-stroke personal watercraft use is expected to be small. 

Personal watercraft manufacturers currently offer models that are compliant with the EPA 2006 standards, 

and new personal watercraft purchased later than 2006 would already be compliant. The average 

operating life of a personal watercraft is 5 to 10 years, depending upon the source (see the “General 

Methodology” section in the “Environmental consequences” chapter). As a result, it is expected that the 

majority of noncompliant personal watercraft would no longer be in operation when the engine 

restrictions proposed under the modified preferred alternative (alternative B) take effect in 2012. 

Public Comment: Commenter: Affiliation: 

164C Individual 

 
Impacts of Personal Watercraft Use

45 

Issue 3: Visitation Effects on Recreation Area Operations

A Comment: Alternative C in the Draft Environmental Impact Statement states, “In the long term, visitors 

returning with other craft would have a direct, negligible to minor, adverse effect.” This statement is very 

troubling because it classifies visitors to Lake Powell as an “adverse effect.” 

Response: Visitation to the recreation area does have an impact on the recreation area’s resources and 

visitor protection staff. For example, increased visitor use to the recreation area, with no change in the 

number of visitor protection staff, would be a strain on park management resources and could result in an 

adverse effect. Likewise, a reduction in the number of visitors using personal watercraft at the recreation 

area could reduce the amount of time visitor protection staff spend responding to incidents or accidents 

involving personal watercraft, which is considered to be beneficial. The text in the Draft Environmental 

Impact Statement was meant to indicate that the adverse effect on park staff was a result of the visitor 

activity. 

Public Comment: Commenter: Affiliation: 

1239L Utah Shared Access Alliance Organization 

 

B Comment: What is the benefit of eliminating 26% of Lake Powell users in order to realize a 15% 

reduction in law enforcement cases? 

Response: The decision to manage personal watercraft was not based on a need to reduce law 

enforcement cases. The “Introduction” section in the “Purpose of and Need for Action” chapter states that 

the overall objective for the plan is to evaluate a range of alternatives and strategies to manage personal 

watercraft with the goal of ensuring protection of recreational and resource values. This objective was 

derived from the enabling legislation for Glen Canyon National Recreation Area. As further stated in this 

section, a special analysis on the management of personal watercraft was also provided under each 

alternative to meet the terms of the settlement agreement between the Bluewater Network and the 

National Park Service. 

Public Comment: Commenter: Affiliation: 

1239L Utah Shared Access Alliance Organization 

 
46 

SHORELINE/SUBMERGED AQUATIC VEGETATION

Affected Environment

Issue 1: General Impacts of Personal Watercraft on Shoreline and Submerged Aquatic Vegetation

A Comment: The Draft Environmental Impact Statement identified the issue of potential concern that the 

beaching and landing of personal watercraft could result in the trampling of shoreline vegetation. The 

comment refers to several other phrases in the text that discuss the affected environment and the 

indistinguishable cumulative effects of personal watercraft use and other watercraft on shoreline or 

submerged aquatic vegetation. 

Response: The National Park Service agrees that appropriate use and operation of personal watercraft in 

accordance with the manufacturer’s recommended use in shallow water would not affect submerged 

aquatic vegetation. However, this does not prevent damage to vegetative life by trampling, particularly on 

beaches where there is other concentrated recreational use. As described in the “Environmental 

Consequences” chapter, due to the nature of the reservoir and the shoreline environment, personal 

watercraft and other watercraft users, and other visitor-induced activities, all have access to the same 

shoreline areas of Lake Powell. The majority of visitor use is concentrated along the shoreline, which is 

below the maximum pool elevation. The amount of high-quality habitat in these areas is low compared to 

the amount above the high-water line. Much of the shoreline is composed of nonnative tamarisk / bare 

ground, and the lake does not have sensitive grasses or submerged aquatic vegetation, except in the 

sensitive inflow areas. 

The National Park Service must manage Glen Canyon National Recreation Area to protect the 

recreational opportunities available at the site, as well as the natural resources found in the lake and 

surrounding lands. To accomplish this, the development of a future lake management plan, which is a 

component of all alternatives, would provide the tools necessary to analyze activities that take place on 

the lake and would help determine if unacceptable impacts are occurring. Even though the rationale and 

need exist to support consideration of personal watercraft management under a separate decision-making 

framework, there remains the need to examine all uses of the lake collectively. As identified in the 

cumulative effects analysis in the “Environmental Consequences” chapter, there are many management 

issues involving the mix of lake uses that require additional planning. 

Public Comment: Commenter: Affiliation: 

1344P Personal Watercraft Industry 

Association 

Organization 

 
47 

Impacts of Personal Watercraft Use

Issue 1: Impacts on Shoreline Vegetation from Waves Generated by Personal Watercraft

A Comment: Personal watercraft damage shoreline vegetation and their wakes produce erosive effects. 

Response: According to NPS Management Policies 2001 (NPS 2000d), natural shoreline processes such 

as erosion, deposition, dune formation, overwash, inlet formation, and shoreline migration should 

continue without interference within a park unit. The Draft and Final Environmental Impact Statements

recognize that the near-shore lake environment, with its desert climate, is affected by wave erosion, highly 

variable water levels, poor soils, and generally steep shorelines. These conditions restrict vegetative cover 

to sparse stands of fast-growing vegetation species that are occasionally interspersed with small, dense 

stands of salt cedar. As described for alternative A under “Cumulative Effects,” shoreline vegetation has 

historically been subjected to many sources of disturbance since the time the recreation area was created. 

The most influential disturbance has been repeated inundation and drying as the reservoir level rises and 

falls. Compared to the substantial influences that current reservoir fluctuations and shoreline conditions 

exert on shoreline vegetation conditions, it is very unlikely that personal watercraft and other watercraft 

users would have a noticeable cumulative impact on shoreline vegetation (including submerged aquatic, 

riparian, and wetland vegetation). 

The National Park Service must manage Glen Canyon National Recreation Area to protect the recreation 

opportunities available at the site, as well as the natural resources found in the lake and surrounding lands. 

To accomplish this, the development of a lake management plan, which is a component of all alternatives, 

would provide the tools necessary to analyze activities that take place on the lake and would help 

determine if unacceptable impacts are occurring. Even though the rationale and need exist to support 

consideration of personal watercraft management under a separate decision-making framework, there 

remains the need to examine all uses of the lake collectively. As identified in the cumulative effects 

analysis under the “Environmental Consequences” chapter, there are many management issues involving 

the mix of lake uses that require additional planning. The modified preferred alternative (alternative B) 

provides for a three-year pilot study to further evaluate personal watercraft use areas. Potential restrictions 

of personal watercraft use in other locations of the recreation area would be evaluated during the pilot 

study. The purpose of the pilot study and a description of how it would be implemented are provided in 

appendix C. 

Public Comment: Commenter: Affiliation: 

689B Individual 

 

Issue 2: Inadequacy of Data to Support Statements that Personal Watercraft Use Impacts Submerged Aquatic 

Vegetation

A Comment: No evidence is disclosed that would indicate personal watercraft use harms shoreline 

vegetation. The Draft Environmental Impact Statement speculates that personal watercraft “may crush or 

uproot grasses or other submerged aquatic vegetation that occurs in shallow water” (pg ix). This 

speculation is totally specious and misleading given the lack of data. 

Response: A summary of the NPS rulemaking and associated personal watercraft litigation is contained 

under “Personal Watercraft Regulatory Framework” in the “Purpose of and Need for Action” chapter. The 

overall objective is to meet the terms of the settlement agreement between Bluewater Network and the 

National Park Service (see “Introduction” in the “Purpose of and Need for Action” chapter). An analysis 

of shoreline vegetation was done in order to meet the terms of the settlement agreement. National research 

indicates that personal watercraft accessing shallow areas may uproot or crush shoreline vegetation. At 

Glen Canyon National Recreation Area, the adverse effects of personal watercraft on shoreline vegetation 

were considered to be negligible. Under the modified preferred alternative (alternative B), mitigation 

measures would be implemented to reduce the amount of petroleum-related pollution entering the water, 

which would indirectly benefit shoreline vegetation. In addition, the modified preferred alternative 
SHORELINE/SUBMERGED AQUATIC VEGETATION

48 

(alternative B) provides for a three-year pilot study to further evaluate personal watercraft-use areas. 

Potential restrictions of personal watercraft use in other locations of the recreation area would be 

evaluated during the pilot study. The purpose of the pilot study and a description of how it would be 

implemented are provided in appendix C. 

Public Comment: Commenter: Affiliation: 

1239J Utah Shared Access Alliance Organization 

 
49 

SOCIOECONOMICS

Affected Environment

Issue 1: Economic Analysis Does Not Take into Account the Economic Cost of Noise

A Comment: On page 274 of the Draft Environmental Impact Statement, the National Park Service states 

that alternative C, a personal watercraft ban, would result in a loss of $25 to $42 million to the local 

economy. The National Park Service states this is due in part to the fact that hundreds of thousands of 

visitors will not return to Glen Canyon National Recreation Area. We believe the NPS’ figure grossly 

inflates the economic impact of a personal watercraft ban for it does not include several economic benefits 

that will result from the prohibition and assumes that park visitation will drop. 

 First, researchers have estimated that an individual personal watercraft inflicts roughly $50 dollars worth 

of noise cost each day of operation. The National Park Service estimates that personal watercraft at Lake 

Powell are in operation approximately 220,000 boat days per season. Multiplying the noise costs by the 

days of operation produces $11 million in noise costs at Lake Powell per year. Dividing this number in 

half to take into account the greater tolerance of boaters to boat noise results in $5.5 million in noise costs. 

If one adds personal watercraft pollution costs (which have been estimated at $12 per day of operation), 

the overall cost of personal watercraft operation upon natural soundscapes and air/water quality rises to 

more than $8 million. Besides overlooking the noise and pollution costs of personal watercraft operation, 

there is also no discussion of the economic costs of continued personal watercraft operation upon national 

recreation area’s wildlife, public safety, and visitor use. Obviously, banning personal watercraft 

eliminates these costs and result in significant economic benefits to the public. Moreover, elimination of 

these costs from alternative C would substantially reduce the economic impact of a personal watercraft 

ban. Unfortunately, the National Park Service neglected to include the economic benefits of a personal 

watercraft ban, as well as the fact that visitation may actually increase at the national recreation area in its 

analysis of alternative C. These oversights call into question the accuracy and thoroughness of the Park 

Service’s economic analysis. 

Response: Law Engineering and Environmental Services (LEES 2002) conducted a benefit-cost analysis 

of personal watercraft regulatory alternatives to evaluate the social welfare implications. The study 

examined whether the reallocation of society’s resources (such as those referenced by the commenter) 

promoted efficiency. That is, the analysis assessed whether the actions would result in benefits (gains in 

social welfare) greater than the associated costs to society (losses in social welfare). 

The study also showed that the number of non-personal watercraft users visiting the community of Page, 

AZ, could increase due to less noise and pollution and that this could contribute to increased enjoyment of 

the area. However, because of uncertainties in quantifying changes in visitation for this group of people, 

increases in expenditures associated with this potential change in visitation patterns were not included in 

the analysis. These changes were evaluated qualitatively based on best available data and professional 

judgment. 

The Final Environmental Impact Statement has incorporated the research noted by the commenter into the 

list of references. Text has been added to the Final Environmental Impact Statement to provide additional 

qualitative analysis of the economic costs of personal watercraft use. 

Public Comment: Commenter: Affiliation: 

1002AE Bluewater Network Organization 

 
50 

Economic Impact Analysis

Issue 1: Long-Term Economic Consequences of a Personal Watercraft Ban Are Inaccurate

A Comment: On page 67 in table 3 of the Draft Environmental Impact Statement, “In the short term and 

long term, cumulative effects would be adverse and moderate.” This describes the socioeconomic impact 

of alternative C. If this is true then why would the National Park Service assume that motorized users 

would soon return to the same level, that a reduction or elimination of personal watercraft would have 

only a temporary change in the level of motor boat use? There is an error in logic here. At one place the 

National Park Service suggests that the drop in motorized watercraft use would be transient. But here the 

National Park Service suggests the impacts on the socioeconomics of the area would be “adverse and 

moderate” in the short term and the long term. If recreational users return to a pre-ban level in a short 

time, then why would adverse, moderate effects persist into the long term? 

Response: Decisions regarding personal watercraft use can affect specific sectors of the local economy. If 

personal watercraft are permanently banned, those businesses or parts of businesses that serve personal 

watercraft users, such as personal watercraft rentals, sales, and repairs, could be eliminated from the 

economy in the long term. Review of literature and professional judgment suggests that there are 

segments of the public that would choose to visit the recreation area if personal watercraft use were 

eliminated. A long-term trend of increased nonmotorized use, or the use of other types of watercraft in the 

future to replace some of the functions of personal watercraft (e.g., remote canyon exploration), would 

offset some of the adverse economic effects of a ban on personal watercraft. These combined direct and 

indirect effects would be moderate as defined in the “Methodology” section. 

Public Comment: Commenter: Affiliation: 

1245I Sierra Club, Utah Chapter Organization 

 
51 

Impacts from Personal Watercraft Restriction

Issue 1: The Long-term Economic Effects of a Personal Watercraft Ban Will Be Adverse

A Comment: I disagree with your conclusions regarding alternative C that eventually everything will be all 

right socio-economically speaking. I believe there will be significant and lasting Short and Long Term 

effects if personal watercraft are banned at Lake Powell. 

Response: The report prepared by Law Engineering and Environmental Services (LEES 2002) and 

referenced in the Draft and Final Environmental Impact Statements fully evaluates the economic effects 

of alternative C. The study shows that the number of non-personal watercraft users visiting the 

community of Page, AZ, could increase due to less noise and pollution, and that this could contribute to 

increased enjoyment of the area. However, because of uncertainties in quantifying changes in visitation 

for this group of people, increases in expenditures associated with this potential change in visitation 

patterns were not included in the analysis. These changes were evaluated qualitatively. The study also 

reports that there are business activities that depend largely or solely on personal watercraft and that the 

adverse effects on these would be long term. 

Public Comment: Commenter: Affiliation: 

170C Individual 

 

Issue 2: The Economic Effects of a Ban on Personal Watercraft Are Overstated

A Comment: If motorized personal watercraft were eliminated from substantial areas of Lake Powell people 

who more highly value nonmotorized watercraft would recreate at the world-class Glen Canyon National 

Recreation Area in numbers that would easily offset any decline in visitation from the motorized personal 

watercraft ban. This fact also contradicts the Draft Environmental Impact Statement’s concluded adverse 

socio-economic impacts of alternative C on the economy of Page and surrounding communities. The 

Draft Environmental Impact Statement failed to identify visitor use patterns of alternative C by failing to 

account for potential users who avoid Glen Canyon National Recreation Area because of current policies. 

By ignoring the influx of visitors who would be drawn by the implementation of alternative C, the adverse 

socioeconomic impacts of alternative C are overstated. 

Response: As the commenter notes, it is reasonable to assume that with the elimination of personal 

watercraft, some individuals who have chosen not to visit the recreation area in the past may choose to 

visit with personal watercraft absent. The result would be an economic effect that would offset, to some 

degree, the economic losses that would result from elimination of personal watercraft. The Final 

Environmental Impact Statement takes this into account, qualitatively, in the discussion of likely effects 

on the local and regional economy. There is no research or literature reference that would allow an 

estimate or quantification of the number of people who may choose to visit the recreation area without 

personal watercraft present. 

Public Comment: Commenter: Affiliation: 

1180E Individual 

 

Issue 3: The Economic Effects of a Personal Watercraft Ban Will Go Beyond the Local Economy

A Comment: In the socioeconomic impact section of the study the areas affected if personal watercraft were 

excluded from Lake Powell seem very narrow and limited. Personal watercraft sales and rental businesses 

in the Salt Lake area will be affected if personal watercraft are excluded from Lake Powell. 

Response: The analysis of economic effect was focused on a limited area. Because it is anticipated that 

the economic impacts of the regulation would be concentrated in the community of Page, AZ, the analysis 

was performed for the zip code covering Page (zip code 86040). Because this is a relatively small analysis 
SOCIOECONOMICS

52 

area, the economic impact analysis may not capture some secondary impacts on other towns in Coconino 

County or other regions. The reasoning is that it is less likely that individuals residing in Page, as well as 

visitors to Glen Canyon National Recreation Area, purchase goods and services from businesses outside 

of the town. The analysis was designed to focus on the groups most affected by the regulation. The 

impacts on other cities and towns compared to the size of their economies, are expected to be very small 

relative to the impact on Page, AZ. Interviews with Page-area businesses were conducted to determine the 

character of the local business community relative to personal watercraft use. During the interviews, it 

was identified that businesses in other cities such as Salt Lake City, UT, and Grand Junction, CO, are 

affected by personal watercraft use in Glen Canyon National Recreation Area. The economic effect on 

those businesses and local economies was evaluated qualitatively in the Draft and Final Environmental 

Impact Statements. 

Public Comment: Commenter: Affiliation: 

1170C Utah Department of Natural 

Resources, Div. of Parks and 

Recreation 

Public Agency 

 

Issue 4: The Full Economic Effect of a Ban on Personal Watercraft Is Not Presented

A Comment: The full effect of alternative C has been calculated into revenues and losses. Losses would be 

greater than reported. Less business in Page would cause ripple effects to road maintenance, property 

values, water management monies, and the quality of schools. 

Response: The analysis of economic effects described in the Draft and Final Environmental Impact 

Statements accounts for both primary and secondary impacts. The economic input-output model, 

IMPLAN, was used to calculate the economic impact associated with the elimination of personal 

watercraft. IMPLAN uses locally and regionally derived multipliers to estimate how money flowing 

through the economy is initially spent in any given sector. The total revenue losses reported under 

alternative C in the “Socioeconomic Environment” section of the “Environmental Consequences” chapter, 

show losses to all sectors, including real estate and local government. The economic impact analysis 

generally addressed the following basic questions concerning an activity of interest: (1) How much 

spending does this activity bring to the region? (2) What portion of sales by local businesses is due to this 

activity? (3) How much income does this activity generate for local households and businesses? (4) How 

many jobs does this activity support? (5) How much tax revenue is generated by this activity? The 

estimated impact is summarized within the Draft and Final Environmental Impact Statements, and the 

detailed results of the input-output analysis are reported in Personal Watercraft Regulations in Glen 

Canyon National Recreation Area (LEES 2002). 

Public Comment: Commenter: Affiliation: 

235B Individual 

 
53 

SOUNDSCAPES

Affected Environment

Issue 1: Level Time History Graph Does Not Cite Distance

A Comment: “The dBA level time history graph on page 105 does not indicate the average distance between 

the noise meter and the three riders.” The commenter objects to using the decibel levels for interpretation 

of the noise being below the legal limit. 

Response: The dBA (A-weighted decibel) level time history graph in the “Soundscapes” section of the 

“Affected Environment” chapter was presented to illustrate fluctuations in personal watercraft noise levels 

representative of typical use patterns. The meter at this site, # 3, was located amid the shoreline 

vegetation. The watercraft illustrated in this graph would have been circling the area at varying distances 

from the meter. The paragraph (entitled “Watercraft Pass-by Sound Levels Measured in Glen Canyon 

National Recreation Area in August 2001”) in the Final Environmental Impact Statement describes the 

noise fluctuation but does not interpret the information on the graph relative to the legal noise limits, thus 

distance is not a relevant factor. 

Public Comment: Commenter: Affiliation: 

905I Individual 

 

Issue 2: Noise Data Indicates Violation of Utah Law

A Comment: The table 12 on page 104 presents data which show that noise levels are potentially in violation 

of Utah law and that the National Park Service should recognize the sentiment behind the Utah law. 

Response: Table 12 (in the Draft Environmental Impact Statement) (Table 14 in the Final Environmental 

Impact Statement) does not state that the noise levels were recorded on the shore nor does the 

accompanying text. Thus, no inference regarding the Utah boating and water-use activities noise 

regulation can be made. (The Utah noise regulation clearly states that the prohibition of 75 dBA noise is 

measured on shore.) The pass-by recordings were made using a microphone mounted above the front of 

an instrumented boat (HMMH 2002). The Final Environmental Impact Statement has been updated to 

include information regarding how pass-by recordings were made. Regarding the comment about intent 

and interpretation of Utah law, the National Park Service cannot determine or interpret the sentiment or 

intent of lawmakers. 

Public Comment: Commenter: Affiliation: 

1245L Sierra Club, Utah Chapter Organization 

 

Issue 3: Natural Ambient Sound Level Not Adequate

A Comment: The focus of returning natural quiet to a significant portion of the reservoir should be included 

in the analysis of alternatives. Specifically sound determinations and measurements used for a baseline 

should come from an area where personal watercraft are prohibited. The area should also be free from all 

motorized recreation and have no audible air traffic. The National Park Service should study the travel of 

noise through canyon systems including the distance noise may travel through confined canyons. The 

National Park Service should establish standards which tend to restore natural quiet and create zones 

where natural quiet predominates. 

Response: Director’s Order 47 (NPS 2000b) specifies that the L90 sound level descriptor be used to 

establish the baseline or natural ambient sound level. The Harris Miller Miller & Hanson, Inc. study 

(HMMH 2002) used instrumentation in the canyon environment that allowed a determination of the 
SOUNDSCAPES

54 

L90 value. Thus, noise levels were measured within the canyons and “confined” spaces of the Lake 

Powell environment. 

The NPS noise standard is 82 dBA at 25 meters (82 feet). Motorized recreational activities on the lake 

that are in the Recreation and Resource Utilization Zone, are compatible with the recreation area’s 

enabling legislation and the management goals for the Recreation and Resource Utilization Zone. The 

preparation of a lake management plan is now a component of each of the alternatives in the Final 

Environmental Impact Statement. Management actions to minimize impacts on the soundscape and all 

environmental impacts, including those of personal watercraft in relation to other users, will be evaluated 

during development of the lake management plan. 

Public Comment: Commenter: Affiliation: 

1245K Sierra Club, Utah Chapter Organization 

 

Issue 4: Incorrect or Inadequate Analysis of Noise Impacts

A Comment: The difference between personal watercraft noise and noise generated by conventional 

motorized watercraft was not properly considered in the analysis of noise impacts. Personal watercraft 

noise is more annoying than the noise generated by conventional boats. The National Park Service 

believes that the “impacts of personal watercraft upon soundscapes and visitor experience will be 

minimal.” 

Response: The text has been changed for the Final Environmental Impact Statement to provide a better 

description and analysis of the unique sound signature of personal watercraft. 

The analysis states that impacts on the natural soundscape would be “minor to moderate” as defined in the 

“Methodology” section in the “Environmental Consequences” chapter. The fluctuation of noise generated 

by personal watercraft is also discussed in the Final Environmental Impact Statement. This effect 

contributes to the “minor to moderate adverse” impact determination. The difference between noise 

generated by personal watercraft and motorboats is pointed out in the “Soundscapes” section of the 

“Environmental Consequences” chapter. The unique sound signature of personal watercraft noise is a 

contributing factor in the “minor to moderate” adverse impact determination. 

In addition, alternative B (the modified preferred alternative) currently provides for a three-year pilot 

study to further evaluate personal watercraft use areas. Potential restrictions of personal watercraft use in 

other locations of the recreation area would be evaluated during the pilot study. The purpose of the pilot 

study and a description of how it would be implemented are provided in appendix C. 

Regarding the characterization of sound associated with use of personal watercraft, the National Park 

Service conducted its own research, which is discussed in detail in the Draft and Final Environmental 

Impact Statements. This information is also supported by a technical report from the research consultant 

(HMMH 2002). 

Public Comment: Commenter: Affiliation: 

1002U Bluewater Network Organization 

 

Issue 5: The Effects on “Biophony” Were Not Considered in the Draft Environmental Impact Statement

A Comment: There is a lack of park-specific information on personal watercraft impacts upon Glen 

Canyon’s fish and wildlife. There is no discussion on personal watercraft noise and its impact upon entire 

biomes, specifically, the effect of noise on the biophony (defined by B. Krause in his book, Wild 

Soundscapes), or the unique manner in which creatures vocalize in a symbiotic relationship to one 

another. 
Affected Environment

55 

Response: The effect of noise on “entire biomes” is not a quantifiable impact. Although Mr. Krause has 

developed plausible theories regarding the effects of noise on wildlife and the “biophony,” peer-reviewed 

research would be required to establish parameters needed to quantify the effects of noise on this aspect of 

the environment. The adverse impacts of personal watercraft noise on wildlife are characterized as 

ranging from negligible to minor, and these impacts include potential effects to the “biophony,” although 

these effects cannot be quantified or definitively defined. Additionally, factors, such as the natural 

variability of the environment and varying degrees of tolerance by individuals within species, can act as 

mitigation to offset or minimize adverse soundscape effects. Refer to the responses to comments in the 

“Wildlife” section (specifically, the response to comment 668 D) of this volume 2 for additional 

information regarding the effects of sound on wildlife. 

A summary of the NPS rulemaking and associated personal watercraft litigation is contained under 

“Personal Watercraft Regulatory Framework” in the “Purpose of and Need for Action” chapter. The 

National Park Service believes it has complied with the court order and has assessed the impacts of 

personal watercraft on those resources specified by the judge, as well as other resources that could be 

affected. These analyses were done for every applicable impact topic with the best available data, as 

required by CEQ regulations (40 CFR 1502.22). Where data was lacking, best professional judgment 

prevailed using assumptions and extrapolations from scientific literature, other park units where personal 

watercraft are used, and personal observations of park staff. 

Public Comment: Commenter: Affiliation: 

1002W Bluewater Network Organization 

 
56 

Cumulative Effects

Issue 1: The Draft Environmental Impact Statement Does Not Adequately Analyze Cumulative Effects in the 

“Soundscapes” Section

A Comment: The cumulative analysis of soundscape effects in the Draft Environmental Impact Statement is 

inadequate because it does not include or quantify the impacts associated with other actions, particularly 

aircraft noise. 

Response: The noise measurements performed by Harris Miller Miller & Hanson (HMMH 2002) were 

made during the time periods when personal watercraft noise effects would most likely have the greatest 

impact on the natural soundscape. These measurements also included aircraft noise as part of the 

cumulative total noise level. The HMMH technical report, pages 27–30, describes the methods and results 

of a process called “source-identification logging” that was employed in the study. It indicates, by site, the 

percentage of time that all individual human-caused sound sources (types) were audible. Logging 

accounted for the audibility and duration of sound from different types of aircraft, watercraft, and other 

sources of human-caused sound. The information regarding individual source types was not presented in 

the Draft or Final Environmental Impact Statements, but it was included, and quantified, as an aggregate 

in the effects analysis in the “Environmental Consequences” chapter of both documents. The computed 

values of Leq, tables 45 and 46 are actually approximating the total ambient human-caused sound (as an 

average). This is because the measured and observed contribution of autos, aircraft, and other sources are 

minimal compared to watercraft. 

The Final Environmental Impact Statement provides a revised analysis of impacts on the soundscape to 

reflect all the relevant information collected and to better understand the personal watercraft contribution 

to those impacts. 

Public Comment: Commenter: Affiliation: 

1391D, 1391M, 1391Q Sierra Club Organization 

 
57 

Impact from Other Vessels

Issue 1: Concern That Personal Watercraft Were Singled Out for Restrictions

A Comment: Several commenters noted that personal watercraft were being singled out for restrictions 

without regard to other sources of noise, including “muscle” boats, other motorboats, loud music, parties, 

and illegal fireworks. 

Response: The plan was not designed to determine if personal watercraft caused more environmental 

damage to park resources than other boats, but rather, to determine if personal watercraft use was 

consistent with Glen Canyon National Recreation Area’s enabling legislation and management goals and 

objectives. The overall objective is to meet the terms of the settlement agreement between Bluewater 

Network and the National Park Service (see “Introduction” in the “Purpose of and Need for Action” 

chapter). An analysis was done on the management of personal watercraft in order to meet the terms of 

the settlement agreement. With completion of this Final Environmental Impact Statement, the National 

Park Service may either take action to adopt special regulations to manage personal watercraft use at Glen 

Canyon, or may choose to discontinue personal watercraft use. The alternatives listed were based upon the 

best information available. 

 

Public Comment: Commenter: Affiliation: 

1344U Personal Watercraft Industry 

Association 

Organization 

780C, 6A, 845B Individuals 

 
58 

Impacts of Personal Watercraft Use

Issue 1: Suggest Implementing a Curfew on Personal Watercraft Use

A Comment: I would recommend that if these personal watercraft are allowed, that they be under a curfew 

so that there are some times in the day when the lake is actually quiet and still. 

Response: As noted in the Draft and Final Environmental Impact Statements, Utah law limits personal 

watercraft use to daytime hours, whereas Arizona law does not include such a restriction. Under the 

modified preferred alternative (alternative B), the National Park Service would work cooperatively with 

Utah and Arizona to develop unified laws for personal watercraft operations within the recreation area. 

In addition, the modified preferred alternative (alternative B) provides for a three-year pilot study to 

further evaluate personal watercraft use areas. Potential restrictions of personal watercraft use in other 

locations of the recreation area would be evaluated during the pilot study. The purpose of the pilot study 

and a description of how it would be implemented are provided in appendix C. 

The preparation of a lake management plan is a component of each of the alternatives in the Final 

Environmental Impact Statement. All noise sources and management actions to minimize environmental 

impacts and user conflicts, including those of personal watercraft in relation to other users, will be 

evaluated during development of the lake management plan. 

Public Comment: Commenter: Affiliation: 

909A Individual 

 

Issue 2: There Is Concern Over Comparison to Residential Noise Levels

A Comment: Irrespective of the comparison with “suburbs at night” (page 204), a noise level averaging 

30 dB at 0.6 miles may be excessively audible where the ambient is only 13 dB. 

Response: The comparison to residential areas was presented only as a frame of reference so that the 

public could relate to what a particular dBA level represented. Noise levels of 30 dB are accounted for in 

the impact determinations. 

Public Comment: Commenter: Affiliation: 

1391P, 1391Q Sierra Club Organization 

 

Issue 3: What Would be the Percent Time Audible for Personal Watercraft Under Each Alternative?

A Comment: Regarding the last two sentences on page 208 of the Draft Environmental Impact Statement

(“alternative A” vs. “alternative C” comparison): What would be the percent time audible for personal 

watercraft under “alternative A”, and, correspondingly, what would be that time specifically for 

“alternative C”? 
Impacts of Personal Watercraft Use

59 

Response: The Final Environmental Impact Statement provides a modified noise analysis that better 

addresses the effects attributable to personal watercraft under alternative A. The percentage of time that 

personal watercraft would be audible is directly related to the proportion of personal watercraft operating 

at any given time. Information regarding the proportion of personal watercraft use is presented in 

tables 18 and 19. The percentage of time that personal watercraft would be audible under alternative C 

would be zero because personal watercraft would not be permitted to operate on Lake Powell under that 

alternative. The Final Environmental Impact Statement provides a modified noise analysis that examines 

audibility. 

Public Comment: Commenter: Affiliation: 

1391R Sierra Club Organization 

 

Issue 4: Fluctuations in Personal Watercraft Noise Is Not Analyzed Adequately

A Comment: Several comments expressed a concern that the Draft Environmental Impact Statement did not 

address the fluctuations of sound that personal watercraft make compared to other motorized watercraft. 

Specifically, the distinctive pitch variation may have different effects on humans and other species and is 

more annoying or irritating than the more constant sounds associated with other boats. 

Response: The pitch variations associated with personal watercraft and the noise differences between 

personal watercraft and motorboats are acknowledged under the “Soundscapes” section in the “Affected 

Environment” chapter. Personal watercraft noise does fluctuate as a result of typical operation, but the 

noise intensity levels are not typically in violation of the NPS noise standard. The suggestion that pitch 

variations may have different effects on humans and other species, and that the variation is more annoying 

or irritating, was incorporated in the analysis and contributes to the “minor to moderate” adverse impact 

determination. 

 

Public Comment: Commenter: Affiliation: 

1393X Environmental Protection Agency Public Agency 

1136C, 3C Individuals 

 
60 

Regulations, Methodologies and Assumptions

Issue 1: Personal Watercraft Exceed Noise Standards

A Comment: The text on page 104 and graph on page 105 show that “sharp turns and jumps increase the 

noise by 10 dBA bringing the noise level up to 86 dBA, 4 dBA above the legal limit of 82 dBA at 

25 meters.” The typical riding style of personal watercraft produces sound beyond the legal limit. 

Response: The text states that the typical style of personal watercraft operation results in fluctuations of 

about 5 dBA, and a 180-degree turn produced about a 10 dBA fluctuation. Fluctuations are changes, 

including both increases and decreases, and do not represent only an increase as stated in the comment. 

Thus, a 10 dBA fluctuation could be represented as +/- 5 dBA. The data presented in table 14 indicates 

that adding 5 dBA to the highest personal watercraft sound measurement at 25 meters (82 feet) would be 

81.4 dBA, which is under the NPS standard of 82 dBA at 25 meters (82 feet). 

Public Comment: Commenter: Affiliation: 

905H Individual 

 

Issue 2: The Area Where the Noise Regulations Will Be Enforced Is Presumably Far Less Than the Area 

Where the Noise Pollution Will Make the Most Significant Impact

A Comment: Alternative B states that enforcement of regulations to prevent this style of riding will be 

difficult beyond close proximity of ranger stations. Reduction of noise from regulation of aggressive 

riding style near the ranger station will be negligible due to the high volume of traffic near ranger stations, 

but what about the areas where enforcement by the National Park Service will not be feasible. The area 

where the noise regulations will be enforced is presumably far less than the area where the noise pollution 

will make the most significant impact. 

Response: The commenter is correct in stating that National Park Service (or the state enforcement 

agencies) enforcement is more difficult beyond proximity to ranger stations. The National Park Service 

does not believe that there are areas where enforcement is not feasible (as stated in the comment); rather, 

enforcement in remote locations cannot be as regular as in areas near ranger stations. However, the 

National Park Service (and state enforcement agencies) makes a great effort to enforce all regulations 

regardless of the location of a particular violation. 

Public Comment: Commenter: Affiliation: 

905H Individual 

 

Issue 3: The National Park Service Should Conduct a Soundscape Study at Glen Canyon National 

Recreation Area Comparable to the Zion National Park Study

A Comment: No Record of Decision or Final Environmental Impact Statement for the Glen Canyon 

National Recreation Area Watercraft Management Plan should be issued until a complete soundscape 

study, comparable to the Zion soundscape study (Wyle Report, WR 02-07, The Soundscape in Zion 

National Park, Contract No. 1443CX2000-98-038 [May, 2002]) has been done at Glen Canyon National 

Recreation Area, and its data considered in evaluation of all alternatives. 
Regulations, Methodologies and Assumptions

61 

Response: All alternatives in the Final Environmental Impact Statement now include plans to implement 

a soundscape management study and analysis in the future lake management plan. The soundscape 

management study would likely use methods similar to those used at Zion National Park. The National 

Park Service believes that the soundscape analysis in the Draft and Final Environmental Impact 

Statements adequately addresses the context, duration, and intensity of personal watercraft affects on the 

soundscape under each alternative. 

Public Comment: Commenter: Affiliation: 

1391C Sierra Club Organization 

 

Issue 4: Wilderness Management and Natural Zone Goals Were Not Properly Considered in the Draft 

Environmental Impact Statement

A Comment: Wilderness management in the Natural Zone is ignored in “other relevant Park planning 

methods” even though it is stated as a goal in Glen Canyon National Recreation Area’s general 

management plan. The “Impairment Analysis Method” section (page 162-163) considers general 

management plan goals as one of the elements used to evaluate the potential for impairment. Only 

alternative “C” correlates satisfactorily with the values of wilderness management. 

Response: The noise impacts on the Natural Zone were determined to be adverse and ranged from minor 

to moderate within a mile of the shoreline (refer to the noise analysis in the “Soundscapes” section of the 

“Environmental Consequences” chapter). 

The Final Environmental Impact Statement contains modified text that reflects the following: Personal 

watercraft sound impacts wilderness values of solitude and natural quiet because sound carries beyond the 

shoreline and is heard at some distance within the Natural Zone. The sound is heard up to a maximum of 

2 miles from the source over a flat surface, but the topography surrounding Lake Powell is not flat. 

Assuming that a natural barrier to the sound would exist where there is an elevation change of 50 feet 

(approximate height of a five-story building), approximately 16,000 acres would be affected (between 

3,700 feet to 3,750 feet in elevation). This equals 2.3% of the Natural Zone (668,670 acres). Time of day 

and season of use would also reduce the level of noise in the Natural Zone because the noise would not be 

continuous, would be encountered only during daylight hours, and would be minimal between October 

and May. 

Although noise does intrude on desired wilderness and Natural Zone soundscape values, the inescapable 

juxtaposition of the Natural Zone and the Recreation and Resource Utilization Zone make it impossible to 

avoid all adverse impacts on the Natural Zone/wilderness soundscape. As shown above, only 2.3% of the 

Natural Zone’s area would be affected, and those soundscape effects would be offset even further by 

diurnal/nocturnal and seasonal reductions in watercraft noise. 

There is a potential conflict in the management objectives between the Recreation and Resource 

Utilization Zone and the Natural Zone that is extremely difficult to avoid because the zones are adjacent 

to each other. However, the percentage of the Natural Zone that is adversely affected by personal 

watercraft noise, as shown in the preceding paragraph, is small. The noise generated by watercraft in the 

Recreation and Resource Utilization Zone, including personal watercraft, is consistent with Glen Canyon 

National Recreation Area’s enabling legislation “to provide for public outdoor recreation use and 

enjoyment of Lake Powell and the lands adjacent thereto.” 
SOUNDSCAPES

62 

The modified preferred alternative (alternative B) provides for a three-year pilot study to further evaluate 

personal watercraft use areas. Potential restrictions of personal watercraft use in other locations of the 

recreation area would be evaluated during the pilot study. The purpose of the pilot study and a description 

of how it would be implemented are provided in appendix C. In addition, the preparation of a lake 

management plan, which was included in all alternatives in the Final Environmental Impact Statement, 

will provide an opportunity for the National Park Service to further evaluate impacts of all lake users on 

all resources, including the soundscape. 

 

Public Comment: Commenter: Affiliation: 

1393D, 1393R, 1393W Environmental Protection Agency Public Agency 

1391L Sierra Club Organization 

1180D Individuals 

 

Issue 5: Request for Median Quiet Intervals

A Comment: The Final Environmental Impact Statement should incorporate a supplemental metric, the 

“Median Quiet Interval “ (MQI) to analyze noise impacts. MQI is defined as the median time interval 

where there is no motorized noise-intrusion audible. This would provide a key, “user-friendly” impact 

assessment indicator of how extended or truncated is the typical opportunity of Park users to experience 

natural quiet unimpaired. 

Response: The following is an explanation of how to determine Median Quiet Interval: If one had a daylong recording, assuming standard and sensitive acoustic instrumentation were being used, one could 

identify all the intervals during the day that were free of human-caused sound. If those intervals were then 

arranged from the shortest to the longest (in hours, minutes, and seconds) and the center-most value, not 

the average value, was picked, one would have determined the median quiet interval for the period of time 

recorded - or a day in this case. 

A soundscape management study, to be implemented in conjunction with the development of a lake 

management plan, would include a sound monitoring program. Data from the monitoring program could 

be used to develop the Median Quiet Interval referred to in the comment. 

Public Comment: Commenter: Affiliation: 

1391U, 1391E, 1391R Sierra Club Organization 

 

Issue 6: The Soundscape Analysis Should Fully Assess Aircraft Noise Contribution to Soundscapes

A Comment: To provide a more complete soundscape analysis, noise data should be obtained at additional 

locations one to two miles from the shore, so that the total aircraft contribution can be fully - not just 

partially - assessed. 

Response: All alternatives in the Final Environmental Impact Statement now include plans to implement 

a soundscape management study in the future lake management plan. The sound management study 

would include a monitoring program, which would be necessary to verify model results and assumed 

impacts of the eventual decision based on this Final Environmental Impact Statement. This comment 

provides some appropriate considerations regarding how monitoring could be conducted. 

Public Comment: Commenter: Affiliation: 

1391T Sierra Club Organization 

 
Regulations, Methodologies and Assumptions

63 

Issue 7: A Soundscape Baseline Without Watercraft Noise Needs to be Developed

A Comment: Before reinstating jet skis, the National Park Service at a minimum needs to perform complete 

acoustic data collection and analysis throughout Glen Canyon National Recreation Area, sufficient for the 

National Park Service to assess the impacts of current and proposed personal watercraft and other 

watercraft usage on the natural soundscape. The baseline soundscape, without any personal 

watercraft/boat noise, must be documented. 

Response: A summary of the NPS rulemaking and associated personal watercraft litigation is contained 

under “Personal Watercraft Regulatory Framework” in the “Purpose of and Need for Action” chapter. The 

National Park Service believes it has complied with the court order and has assessed the impacts of 

personal watercraft on those resources specified by the judge, as well as other resources that could be 

affected. These analyses were done for every applicable impact topic with the best available data, as 

required by CEQ regulations (40 CFR 1502.22). Where data was lacking, best professional judgment 

prevailed using assumptions and extrapolations from scientific literature, other park units where personal 

watercraft are used, and personal observations of park staff. 

All alternatives in the Final Environmental Impact Statement now include plans to implement a 

soundscape management study and analysis in the future lake management plan. The sound management 

study would include a monitoring program, which would be necessary to verify model results and 

assumed impacts of the eventual decision based on this Final Environmental Impact Statement. 

Public Comment: Commenter: Affiliation: 

1391B Sierra Club Organization 

 

Issue 8: There Is a Need for a Soundscape Management Plan and Lake Management Plan at Glen Canyon 

National Recreation Area

A Comment: The National Park Service should complete a “Soundscape Management Plan” for Glen 

Canyon National Recreation Area (as per Director’s Order 47). It should also complete a “Lake 

Management Plan.” The status and timeline for these plans should be included in the Final Environmental 

Impact Statement. 

Response: All alternatives in the Final Environmental Impact Statement now include development of a 

lake management plan. The lake management plan would incorporate a soundscape management study. 

These park planning efforts would (1) describe the baseline natural ambient sound environment in 

qualitative and quantitative terms; (2) identify sound sources and sound levels consistent with park 

legislation and purposes; (3) identify the level, nature, and origin of internal and external noise sources; 

(4) articulate desired future soundscape conditions; and (5) recommend the approaches or actions that 

would be taken to achieve those conditions or otherwise mitigate noise impacts. 

Public Comment: Commenter: Affiliation: 

1391G Sierra Club Organization 

 

Issue 9: What Is Human Threshold of Hearing for Watercraft-Specific Frequencies?

A Comment: What is the “human threshold of hearing” assumed for the watercraft-specific frequencies (in 

relation to understanding the “audibility calculations” cited on page 200)? 

Response: Audibility, in general, may be defined as the evidence of sound detected by an average, 

attentive person. Audibility impacts, as reported in the effects analysis (refer to the “Environment 

Consequences” chapter) should be viewed within this general context. Technically, humans can hear 

sounds beginning at 0 decibel on an A-weighted scale (dBA). Humans can detect changes in sound 

pressure level that are 1-3 decibels in magnitude. Each frequency band in the spectrum emitted by a sound 
SOUNDSCAPES

64 

source is associated with a decibel level. Measured at a distance of 25 meters (82 feet) and operating in a 

“typical” fashion, a personal watercraft emits its highest maximum sound pressure level range in 

frequencies from 50 Hertz (Hz) to 1,250 Hz. The peak frequency emitted is about 130 Hz and 70 dBA. 

This is well within the range of frequencies that humans hear very well. Humans can hear frequencies 

emitted by personal watercraft below 50 Hz and above 1,250 Hz, but decibel levels decline in both 

instances. For comparison, a boat typically operates in the same frequency spectrum at the same decibel 

levels as a personal watercraft, except it maintains a higher sound pressure level at frequencies below 

about 130 Hz. People tend to hear less well at this end of the frequency spectrum. V-8 “muscle” boats 

show considerably higher sound pressure levels throughout the frequency range compared to other boats 

and personal watercraft. All of this is accounted for in the modeling of audibility (refer to the 

“Methodology” section in the “Environmental Consequences” chapter). 

Public Comment: Commenter: Affiliation: 

1391N Sierra Club Organization 

 

Issue 10: A Noise Analysis Should Be Conducted in September When Personal Watercraft Use Peaks

A Comment: Why isn’t noise analysis also provided for the personal watercraft peak month of September 

(when personal watercraft use peaks at 38% and other watercraft uses decline to 62% - tables 11 and 16). 

Please provide this data. 

Response: The Harris Miller Miller & Hanson (HMMH 2002) study was commissioned by the National 

Park Service to provide data for use in the Draft and Final Environmental Impact Statements. As shown 

in table 13, 48% of the lake was characterized as experiencing high sound levels in August; thus, August 

presented the best opportunity to measure maximum noise levels in the recreation area. 

Public Comment: Commenter: Affiliation: 

1391N Sierra Club Organization 

 

Issue 11: Aircraft Noise Is Not Considered in the Definition of Negligible Impact to Soundscapes 

A Comment: There appears a major error regarding the “Negligible” paragraph in the Impact Threshold 

Definitions on page 201, because there is no reference to the aircraft noise contribution. It is likely not 

negligible in many areas of Glen Canyon National Recreation Area. 

Response: The definition of negligible in the Final Environmental Impact Statement refers to “humancaused noise,” which includes aircraft noise. The analysis of soundscape impacts focuses on the impacts 

of personal watercraft on the soundscape, while the cumulative analysis addresses impacts on the 

soundscape from all sources, including aircraft. The cumulative soundscape impact assessment is 

characterized as a minor to moderate adverse effect under all the alternatives. As a result, there does not 

appear to be a misapplication of the negligible threshold definition. 

Public Comment: Commenter: Affiliation: 

1391O Sierra Club Organization 

 

Issue 12: Lack of Quantitative Definitions for Soundscape Impact Thresholds and Impairment Definition

A Comment: Non-quantified terms (“low levels,” “mostly,” “predominate,” “rarely,” “medium levels,” 

“infrequently,” “short durations,” “high levels,” “occasionally,” often,” “medium duration,” “almost all,” 

and “extended periods”) used in the threshold definitions are all ultimately ephemeral and only 

qualitative. Hence, they are subject to arbitrary and capricious interpretation in rulemaking and/or 

determinations as to significant impact. This applies to the impairment definition and determination as 

well. 
Regulations, Methodologies and Assumptions

65 

Response: The Final Environmental Impact Statement soundscape analysis, including the threshold 

definitions, was modified to minimize ambiguity and clarify the determinations of personal watercraft 

soundscape impacts. 

Public Comment: Commenter: Affiliation: 

1391O, 1391Q Sierra Club Organization 

 

Issue 13: A Report Entitled “Drowning in Noise” Was Not Applied in the Draft Environmental Impact 

Statement

A Comment: Nowhere in the Draft Environmental Impact Statement is there genuine application of a cited 

key Report: “Drowning in Noise: Noise Costs of Jet Skis in America” - a Report for the Noise Pollution 

Clearing house, by Charles Komanoff and Howard Shaw, (April, 2000). The Final Environmental Impact 

Statement should specifically apply the key findings of the “Drowning in Noise” Report, including 

“Robinson’s Equation” to assess perceived noise impacts from rapid noise level fluctuations. 

Response: Drowning in Noise: Noise Costs of Jet Skis in America (Komanoff and Shaw 2000) is cited in 

the Draft and Final Environmental Impact Statements in the discussion of soundscapes in the “Purpose of 

and Need for Action” chapter. Information in the Drowning in Noise report, specifically in relation to 

noise measurement, is consistent with NPS findings. However, NPS findings are appropriately based on 

actual on-site measurements rather than on the Drowning in Noise report. Other interpretations, 

discussions, or conclusions in the Drowning in Noise report are more applicable to an assessment of 

visitor experience. The Final Environmental Impact Statement contains an added discussion about the 

qualitative effect of the distinctive personal watercraft sound signature (refer to the “Visitor Use and 

Experience,” “Methodology” section of the “Environmental Consequences” chapter). 

“Robinson’s Formula,” according to the Drowning in Noise report, is a quantified approach to 

“annoyance” as a function of variability in the sound source, not just its decibel level. The Final 

Environmental Impact Statement describes the nature of the personal watercraft as a sound source, 

including fluctuations associated with its use. Thus, the phenomenon of variability is reported as part of 

the existing impact on the soundscape from personal watercraft. It is inherent in the effects analysis 

wherever an adverse impact is reported for natural sound. The major application for Robinson’s Formula, 

or at least for recognizing the concept behind it, is in the description of visitor impacts. Where personal 

watercraft are audible, the interpretation of whether or not or to what degree visitors are annoyed is 

related at least in part to sound fluctuation. There is no question that personal watercraft sound, as 

characterized, is annoying to some visitors as is conveyed in the visitor experience section. Given that 

disclosure, and the large variability in circumstances that could be modeled using Robinson’s Formula, it 

is unnecessary to actually do the arithmetic as suggested in this comment. Rather, it is helpful to look at 

the operational parameters that cause the fluctuation and the annoyance, and to develop mitigation 

measures that would reduce or eliminate them. Refer to the responses to comments in the “Visitor Use 

and Experience” section of this volume for additional information. 

 

Public Comment: Commenter: Affiliation: 

1391F, 1391P Sierra Club Organization 

1002F Bluewater Network Organization 

 

Issue 14: Additional Information Regarding Personal Watercraft Noise Abatement Technology and Design 

Needs to be Added to the Final Environmental Impact Statement

A Comment: Since 1998, the personal watercraft companies have reduced engine sound levels by up to 70% 

and have introduced design changes to not only reduce engine sound intensity, but to reduce the sound 

pitch that some claim to be annoying. 
SOUNDSCAPES

66 

Response: The National Park Service appreciates the information regarding new noise suppression 

designs being used by some personal watercraft manufacturers. The Final Environmental Impact 

Statement refers to the potential noise abatement factors and acknowledge that future designs may 

mitigate sound impacts (see the “Affected Environment” chapter). 

Public Comment: Commenter: Affiliation: 

1344L Personal Watercraft Industry 

Association 

Organization 

 
67 

THREATENED AND ENDANGERED SPECIES

Impacts of Personal Watercraft Use

Issue 1: Personal Watercraft Use May Impact Critical Habitat

A Comment: I would like to point out that the pollution from these machines is thought by some to pollute 

the shore lines in a way similar to a “bathtub ring”. The area around a body of water, from the shore line 

inland and out into the water, is a critical habitat for wildlife. 

Response: The National Park Service defined the evaluation area for threatened, endangered, and specialconcern species as the 3,700-foot water surface elevation (the shoreline zone) and uplands within 500 feet 

of Lake Powell’s 3,700-foot water surface elevation or within 500 feet of river shorelines. Much of the 

shoreline inland and out to the water is subject to changes in water levels that fluctuate nearly 50 feet 

vertically and 1,000 feet horizontally during a typical year. Vegetation is generally scarce and poorly 

developed, and unstable water levels associated with reservoir operations provide limited opportunities 

for vegetation to grow. Development and long-term maintenance of sensitive vegetation communities are 

dependent on the suitable combination and distribution of adequate conditions such as soil, slope, water 

depth, and hydrology. The fluctuation of the lake, which either floods or drains shoreline areas, makes it 

difficult for sensitive vegetation and wildlife species to survive. This is particularly apparent during 

periods of prolonged low-water, where soil conditions allow many fast-growing annual and perennial 

species, such as saltcedar, to invade the exposed shoreline because they are more tolerant of the 

conditions. 

As defined in the provisions of the Endangered Species Act, critical habitat is a specific geographic area 

that is essential for the conservation of endangered or threatened species. The Draft and Final 

Environmental Impact Statements identify and delineate the geographic extent of the critical habitat 

established for four endangered fish species: razorback sucker, Colorado pikeminnow, humpback chub, 

and bonytail chub (see table 16 under the “Threatened, Endangered, and Special-Concern Species” section 

in the “Affected Environment” chapter). Critical habitat for these fish at sensitive river inlets would not 

likely be adversely affected by pollution because use in river inlets during peak season is typically less 

than 5% and does not occur over extended periods of time. Pollutants from personal watercraft and other 

motorized watercraft are more intense closer to the marinas than in river inlets where critical habitat 

(delineated by the U.S. Fish and Wildlife Service) is present (Federal Register 50 CFR part 17, March 21, 

1994). Critical habitat for Mexican spotted owl, the southwestern willow flycatcher, the California 

condor, and the Navajo sedge are also present in Glen Canyon National Recreation Area, but are not 

located within the personal watercraft use area. 

In addition, the U.S. Fish and Wildlife Service (see letter 01137 in this volume), has concurred with the 

NPS determination that the three alternatives, including alternative B in the Draft Environmental Impact 

Statement are “not likely to adversely affect” threatened and endangered species or critical habitat. The 

modified preferred alternative (alternative B) provides further mitigation measures to protect park 

resources. Under the modified preferred alternative (alternative B), restrictions on carbureted two-stroke 

engines in 2012 would result in beneficial impacts on the overall aquatic ecosystem and on endemic fish 

populations. Based on the analysis presented, the National Park Service finds that the modified preferred 

alternative (including the provision for continued personal watercraft use), if implemented, would not 

result in an impairment of threatened or endangered species or critical habitat. 

Public Comment: Commenter: Affiliation: 

1177A, 1177E Individual 

 
THREATENED AND ENDANGERED SPECIES

68 

Issue 2: Incomplete Assessment of Impacts on Wildlife and Certain Threatened and Endangered Species

A Comment: The Draft Environmental Impact Statement does not adequately assess the adverse effects that 

personal watercraft use has or may have on some threatened and endangered bird species such as 

peregrine falcons, bald eagles, and western yellow-billed cuckoos. 

Response: Information on the distribution and potential presence of peregrine falcons, bald eagles, and 

western yellow-billed cuckoos was obtained from habitat inventories, databases, and other research 

projects conducted for Glen Canyon National Recreation Area planning purposes, as well as through 

observations of qualified experts and recreation area staff. The National Park Service has consulted and 

coordinated with the U.S. Fish and Wildlife Service, the Arizona Game and Fish Department, and the 

Utah Division of Wildlife Resources (see U.S. Fish and Wildlife Service responses in appendix H.1, and 

Arizona Game and Fish Department and Utah Division of Wildlife Resources responses in appendix H.2 

and appendix H.3, respectively). 

Each of these species has been assessed in the Final Environmental Impact Statement (see the 

“Methodology” and “Wildlife and Wildlife Habitat” sections in the “Environmental Consequences” 

chapter). Factors that affect the degree of interaction (i.e., the effects of duration and intensity) with these 

species are influenced by the species’ lack of critical habitat designation in the evaluation area, transient 

or seasonal use of the recreation area by the species, and limited distribution of sensitive habitat. 

Therefore, exposure of these species during periods of potential personal watercraft use is limited. The 

National Park Service believes that the Draft and Final Environmental Impact Statements adequately 

address the potential behavioral changes of these species in proportion to the potential exposure to 

personal watercraft use under each alternative. 

In addition, the U.S. Fish and Wildlife Service has concurred with the NPS determination that the three 

alternatives (including alternative B, the preferred alternative) are “not likely to adversely affect” 

threatened and endangered species or critical habitat (see letter 01137 in this volume). The modified 

preferred alternative (alternative B) in the Final Environmental Impact Statement provides further 

mitigation measures to protect park resources. Under the modified preferred alternative, restrictions on 

carbureted two-stroke engines in 2012 would likely result in beneficial impacts on the overall aquatic 

ecosystem and on endemic fish populations. Based on the analysis presented, the National Park Service 

finds that the modified preferred alternative (alternative B) (including the provision for continued personal 

watercraft use), if implemented, would not result in an impairment of threatened or endangered species or 

critical habitat. 

Public Comment: Commenter: Affiliation: 

1168G American Canoe Association Organization 

 
69 

Regulations, Methodologies, and Assumptions

Issue 1: Lack of Site-Specific Data

A Comment: The Draft Environmental Impact Statement section on personal watercraft impacts upon 

threatened and endangered (T/E) species also lacks sufficient site specific data. Once more, it appears that 

no research was conducted to determine personal watercraft impacts upon the federally listed species 

found at Glen Canyon. However, despite the NPS’s lack of data, the Park Service concludes that its 

preferred alternative would not “adversely affect” T/E species. Again, Bluewater Network believes the 

lack of pertinent information makes it impossible for the National Park Service to support this conclusion. 

Response: A summary of the NPS rulemaking and associated personal watercraft litigation is contained 

under “Personal Watercraft Regulatory Framework” in the “Purpose of and Need for Action” chapter. The 

National Park Service believes it has complied with the court order and has assessed the impacts of 

personal watercraft on those resources specified by the judge, as well as other resources that could be 

affected. These analyses were done for every applicable impact topic with the best available data, as 

required by CEQ regulations (40 CFR 1502.22). Where data was lacking, best professional judgment 

prevailed using assumptions and extrapolations from scientific literature, other park units where personal 

watercraft are used, and personal observations of park staff. 

In addition, the U.S. Fish and Wildlife Service has concurred with the NPS determination that the three 

alternatives (including alternative B, the preferred alternative) are “not likely to adversely affect” 

threatened and endangered species or critical habitat (see letter 01137 in this volume). The modified 

preferred alternative (alternative B) in the Final Environmental Impact Statement provides further 

mitigation measures to protect park resources. Under the modified preferred alternative, restrictions on 

carbureted two-stroke engines in 2012 would likely result in beneficial impacts on the overall aquatic 

ecosystem and on endemic fish populations. Based on the analysis presented, the National Park Service 

finds that the modified preferred alternative (alternative B) presented in the Final Environmental Impact 

Statement (including the provision for continued personal watercraft use), if implemented, would not 

result in an impairment of threatened or endangered species or critical habitat. 

Public Comment: Commenter: Affiliation: 

1002X Bluewater Network Organization 

 
70 

VISITOR CONFLICTS AND SAFETY

Affected Environment

Issue 1: National Safety Data Not Adequately Assessed

A Comment: A flaw in the Draft Environmental Impact Statement is its failure to adequately assess the 

safety threat posed to park visitors by personal watercraft use. The EA does not adequately analyze 

existing accident data available from the United States Coast Guard (USCG). The information considered 

in the Draft Environmental Impact Statement with respect to safety is limited to 1997 data on accident 

numbers and injuries and the 1998 National Transportation Safety Board (NTSB) report. More diligent 

research into the USCG Boating Accident Report Database (BARD) would have also found that personal 

watercraft, which comprise only 6.5% of vessels, are involved in 55% of all vessel-on vessel collisions, 

that 70% of all personal watercraft accidents are collisions, and that personal watercraft are more than 3 

times as likely to strike a person swimming in the water as other vessels. 

Response: Incidents involving watercraft of all types, including personal watercraft, are reported to and 

logged by NPS staff. A very small proportion of incidents on the lake are estimated to go unreported. The 

accident data for the three-year period (1999 through 2001) displays a consistent pattern and differs from 

nationally reported results for all watercraft. In the “Visitor Conflicts and Visitor Safety” section of the 

“Affected Environment” chapter, it is reported that personal watercraft represent 26% of the total boat 

days and 18% of the total operating hours on the lake but represented 14% of all watercraft accidents over 

the three-year time period. While personal injury rates for personal watercraft were somewhat higher, they 

did not exceed 24% of all watercraft personal injuries, or approximately equal to their representation in 

the population of all watercraft. 

Accident information generated by the U. S. Coast Guard has been incorporated into the “Summary of 

National Information of the Effects of Personal Watercraft” section of the “Purpose of and Need for 

Action” chapter. 

Public Comment: Commenter: Affiliation: 

1168D American Canoe Association Organization 

 

B Comment: The Draft Environmental Impact Statement discloses that personal watercraft accounted for 

26% or 218,882 boat days on Lake Powell in 2001. The Draft Environmental Impact Statement also 

makes the claim that “Nationally, some data suggest that personal watercraft have higher accident rates 

that other watercraft.” While this may or may not be true, Lake Powell specific data show that personal 

watercraft are under represented in accident/death rates! Why mention what some data “suggest” when 

actual, on site data show just the opposite? 

Response: The “Issues and Impact Topics” section of the “Purpose of and Need for Action” chapter 

addresses potential issues and impact topics that were brought forth during public scoping and through the 

interdisciplinary planning process. Under NPS Director’s Order 12, issues are defined as problems that 

any of the alternatives may cause, or they may be questions, concerns, problems, or other relationships, 

including beneficial ones. Issues alert the reader as to what the environmental problems might be if an 

action is taken. The national research presented in the “Purpose of and Need for Action” chapter was used 

as part of the scoping process to help identify potential issues related to personal watercraft use. Actual 

data for Glen Canyon National Recreation Area are available and were used for the analysis and 

compared to the national data in order to address the issue. It is the obligation of the agency to respond to 

reasonable issues that fall within the scope of a federal action. 

Public Comment: Commenter: Affiliation: 

1239K Utah Shared Access Alliance Organization 

 
Affected Environment

71 

Issue 2: Draft Environmental Impact Statement Does Not Address Higher Rate of Personal Watercraft Fires 

and Explosions

A Comment: The analysis downplays the threat personal watercraft pose to the visiting public because it 

clearly lacks discussion or reference to several important studies and reports. There is no discussion 

regarding personal watercraft fire and explosion hazards. Recent USCG safety data suggest that both the 

number of fires and the injuries associated with those fires have increased more than 300% since 1995. A 

recent study by the University of Florida (UF) found that personal watercraft represent a greater threat to 

child safety than conventional boats. 

Response: According to the National Marine Manufacturers Association (NMMA 2001b), personal 

watercraft manufacturers have sold roughly 1.2 million watercraft during the last 10 years. Of the 

1.2 million personal watercraft sold, the U.S. Coast Guard had only 90 reports of fires/explosions from 

1995 through 1999. This is less than 1% of personal watercraft reporting problems associated with 

fires/explosions. As far as the recall campaigns conducted by Kawasaki and Bombardier, the problems 

that were associated with fuel tanks were fixed. Kawasaki conducted a recall for potentially defective fuel 

filler necks and fuel tank outlet gaskets on 23,579 personal watercraft between 1989 and 1990. The fuel 

tank problems were eliminated in Kawasaki’s newer models, and the 1989 and 1990 models are most 

likely not in use anymore, since the average operating life of a personal watercraft is 5 to 10 years, 

depending on the source. The Personal Watercraft Industry Association believes the typical operating life 

of a personal watercraft rental is three years and approximately five to seven years for a privately owned 

vessel (PWIA 2002a). Bombardier also did a recall for its 1993, 1994, and 1995 models to reassess 

possible fuel tank design flaws. However, the number of fuel tanks that had to be recalled was a very 

small percent of the 1993, 1994, and 1995 fleets because fuel tank sales only amounted to 2.16% of the 

total fleet during this period (USCG n.d.). The replacement fuel tanks differed from those installed in the 

watercraft subject to the recall in that the replacement tanks had revised filler neck radiuses. Also, the 

installation procedure now requires revised torque specifications, and the fuel system must successfully 

complete a pressure leak test. Bombardier found that the major factor contributing to personal watercraft 

fires/explosions was over-torquing of the gear clamp. Bombardier was legally required by the Coast 

Guard to fix 9.72% of the recalled models. Out of 125,349 recalls, the company repaired 48,370 units, 

which was approximately 38% of the total recall. 

Fuel tank and engine problems that could be associated with personal watercraft fires have been reduced 

since the National Marine Manufacturers Association set requirements for meeting manufacturing 

regulations established by the Coast Guard. Many companies even choose to participate in the more 

stringent Certification Program administered by the association. The association verifies the boat model 

lines annually, or whenever a new product is put on the market, to ensure that they satisfy not only Coast 

Guard regulations but also the more rigorous standards based on those established by the American Boat 

and Yacht Council. There is no indication in park accident records that personal watercraft represent 

higher fire or explosion hazards than other watercraft. 

Public Comment: Commenter: Affiliation: 

1002AB, 1002G Bluewater Network Organization 

 
72 

Boater Education

Issue 1: Lake Permit and Education Should be Mandatory

A Comment: I believe the basic problem is reduction of user conflicts. Perhaps a lake permit could be made 

a requirement, with a mandatory education pamphlet and a short test to make a clear message to users 

how they can use the lake without detracting too much from other use. 

Response: The states of Arizona and Utah mandate the current operational age of personal watercraft 

users. The licensing of boat or personal watercraft operators rests with the state governments and is not 

the mandate of the federal government. Currently the state of Utah provides an extensive and nationally 

recognized mandatory education program for personal watercraft users. The National Park Service will 

continue to support this existing program. In addition, under the modified preferred alternative 

(alternative B), enhanced educational materials and programs highlighting personal watercraft issues 

would be distributed to the public. 

Public Comment: Commenter: Affiliation: 

200B, 821B, 7D, 383A, 835A, 

387B, 389A, 1288B, 240B, 226A, 

112A, 1183A, 903B, 317B, 1087C 

 Individual 

 
73 

Impacts from Other Vessels

Issue 1: Flat-Wake Areas for Only One Class of Watercraft Are Unsafe

A Comment: There is no rationale that would require personal watercraft to operate at flat-wake speeds in 

areas where conventional boats could travel at unlimited speeds. personal watercraft, in fact, produce 

fewer waves as a result of their operation, and therefore create less of an erosion problem. Forcing one 

type of boat to operate at flat-wake speeds poses serious health risks for their operators. 

Response: The plan was not designed to determine if personal watercraft caused more environmental 

damage to park resources than other boats, but rather, to determine if personal watercraft use was 

consistent with Glen Canyon National Recreation Area’s enabling legislation and management goals and 

objectives. The overall objective is to meet the terms of the settlement agreement between Bluewater 

Network and the National Park Service (see “Introduction” in the “Purpose of and Need for Action” 

chapter). An analysis was done on the management of personal watercraft in order to meet the terms of 

the settlement agreement. With completion of this Final Environmental Impact Statement, the National 

Park Service may either take action to adopt special regulations to manage personal watercraft use at Glen 

Canyon, or may choose to discontinue personal watercraft use. 

The analysis for each alternative was based on the best information available. Under alternative B (the 

modified preferred alternative), the management actions for the San Juan, Escalante, Colorado, and Dirty 

Devil Rivers would be implemented to reduce visitor conflicts with river rafters, fishermen, and 

backcountry hikers; promote opportunities for visitor enjoyment; and ensure visitor safety. 

Under Utah State law, all boaters must operate at flat-wake speeds or idle speed within 150 feet of another 

boat, a person in or floating on the water, a waterskier (except those being towed), a shore fisherman, a 

launching ramp, a dock, or a designated swimming area. Arizona State law requires all boaters to operate 

at flat-wake speeds within 60 feet of another vessel. The modified preferred alternative (alternative B) 

addresses signing, buoys, and boater education that will encourage other watercraft operators’ observance 

of safe boating practices. 

 

Public Comment: Commenter: Affiliation: 

1175C American Watercraft Association Organization 

Form 1 Individual 

 
74 

Impacts of Personal Watercraft Use

Issue 1: Concerns with the Draft Environmental Impact Study Evaluation of Personal Watercraft Safety 

Issues

A Comment: Impact assessment for visitor conflicts and safety is inadequate. The Draft Environmental 

Impact Statement contradicts itself in the comments for alternative C. The impression left is that this is not 

an objective assessment, but rather a biased attempt to support a preselected action, not based in fact. How 

can the Draft Environmental Impact Statement acknowledge a 20% reduction in accidents (direct, 

beneficial, short-term, moderate) in one sentence and in the next sentence allege that in the long term 

accidents would be at least as high as Alt A?? This is utterly illogical. 

Response: The analysis of personal watercraft use assumed that, with a ban on personal watercraft, the 

total number of watercraft operating hours on the lake would be decreased. Because personal watercraft 

and other watercraft have similar accident rates on the lake, the number of total accidents would be 

reduced proportional to the reduction in personal watercraft operating hours. This, however, would be a 

short-term effect. Based on national park system use trends, it is assumed that total watercraft operating 

hours under alternative C would recover by 2012 to use levels similar to the range predicted under 

alternatives A and B. This would be due to either natural growth in visitation (assuming a 2% annual 

increase in use) or increased visitation by individuals who previously avoided the recreation area because 

of personal watercraft disturbance and choose to visit in their absence. 

This would result in a long-term accident rate under alternative C that would be similar to the long-term 

rate under alternative A. 

Public Comment: Commenter: Affiliation: 

3E Individual 

 
75 

VISITOR USE AND EXPERIENCE

Affected Environment

Issue 1: Survey Concerning Visitor Satisfaction Doesn’t Take Into Consideration People Who Don’t Recreate 

at Glen Canyon National Recreation Area Due to Motorized Activity

A Comment: The University of Minnesota survey does not include potential visitors who do not recreate at 

Glen Canyon National Recreation Area because of the way it is currently managed. The results of the 

survey present a skewed conclusion that there is little support for a ban on personal watercraft. 

Response: There is both documented and anecdotal evidence that a segment of the recreating public 

chooses not to visit Glen Canyon National Recreation Area because of conditions that they expect or 

perceive to be unacceptable. While existing data is not sufficient to quantitatively predict the effect of 

personal watercraft management actions on visitor behavior, the available data and the opinion of NPS 

professionals suggest that a segment of the recreating public would choose to visit the recreation area if 

there were no personal watercraft, or personal watercraft use was curtailed over portions of the lake. 

Using this professional judgment and the methodology described in the “Environmental Consequences” 

chapter of the Final Environmental Impact Statement, the environmental analysis evaluates the expected 

effect on each segment of the visiting public. 

 

Public Comment: Commenter: Affiliation: 

1002Y Bluewater Network Organization 

1180F Individual 

 

Issue 2: Concerns with Draft Environmental Impact Statement Evaluation of Personal Watercraft Safety 

Issues

A Comment: The conclusions of the Draft Environmental Impact Statement concerning motorized personal 

watercraft safety relative to other types of watercraft hinge on the percentage of personal watercraft 

accidents (14%) and personal injuries (20%) versus the estimation of personal watercraft boat days in 

2001 (26%). James et al. reports that only 22% of personal watercraft users listed personal watercraft as 

their primary watercraft. Many personal watercraft spend significant time being towed or carried by their 

primary watercraft. Simply multiplying the estimated number of personal watercraft by the average length 

of stay substantially overstates actual personal watercraft use. Given the size of Lake Powell, it is fair to 

estimate that personal watercraft belonging to the 78% of parties using other boat(s) as primary watercraft 

are being towed or carried for at least 40% of the average length of stay for personal watercraft. Adjusting 

for this factor (using the data in table 16, p.127) gives an estimate of 151,446 personal watercraft boat 

days out of 773,154 total, or 19.6% of total. The “Water Quality” section of the Draft Environmental 

Impact Statement, personal watercraft engine hours are estimated at only 18% of total (table 29, p.168). 

Response: The environmental analysis presented in the “Visitor Conflicts and Visitor Safety” section in 

the “Environmental Consequences” chapter has been changed in the Final Environmental Impact 

Statement to reflect that personal watercraft account for 18% of all watercraft operating hours and 

represent 14% of all accidents and 20% of personal injuries. 

Public Comment: Commenter: Affiliation: 

1180C Individual 

 
VISITOR USE AND EXPERIENCE

76 

Issue 3: Additional Information Needed on the Natural Zone and the Recreational and Resource Utilization 

Zone

A Comment: The Final Environmental Impact Statement should include a map that identifies the Natural 

Zone and the Recreation and Resource Utilization Zone in the analysis area, and include additional detail 

regarding the purposes and objectives for these two zones. The impact of each alternative on whether the 

Natural Zone qualifies for wilderness designation, as recommended in the last Management Plan, should 

be described in the document. 

Response: A map of Glen Canyon National Recreation Area’s management zones has been added to the 

“General Project Setting” section of the “Affected Environment” chapter in the Final Environmental 

Impact Statement, along with an additional description of the zones’ objectives. See comments and 

responses in the “Soundscapes” section of this volume 2. 

Public Comment: Commenter: Affiliation: 

1393Z Environmental Protection Agency Public Agency 

 
77 

Impacts of Personal Watercraft Use

Issue 1: Alternative B Denies the Public Use and Enjoyment of River Tributaries, and Restrictions Are Not 

Justified Based on the Level of Use

A Comment: The Draft Environmental Impact Statement ignores the fact that muscle-powered users have 

the vast bulk of the Colorado river system plus the entire Grand Canyon available for their exclusive use. 

This information would have helped decision makers and the general public evaluate alternatives. We 

point out that sharing this relative short section, which is regularly inundated to become flat water at high 

lake levels should not be too much of a burden to those who seek a “primitive” or nonmotorized 

recreational experience. The same comments apply to the affected sections of the Escalante, Dirty Devil, 

and San Juan rivers. Alternative B unfairly denies the public the use and enjoyment of these areas. The 

decision to adopt alternative B, in light of the lack of documented harm to the environment, is arbitrary 

and capricious and contrary to the management mandate contained in the enabling legislation. 

Response: Upstream river travel by personal watercraft and other vessels is already restricted through the 

Superintendent’s Compendium as specified under alternative A, which is the continuation of current 

conditions. See table 4 for specific restrictions. These areas of the rivers were restricted because of a high 

potential for visitor conflict and to protect visitor health and safety. The management actions under the 

modified preferred alternative (alternative B) for the San Juan, Escalante, Colorado, and Dirty Devil 

Rivers would additionally restrict travel downstream on the same stretches of river as under alternative A, 

and would also restrict access in both directions on 10 additional miles of the Dirty Devil River and 23 

miles on the Colorado River. Based on the best available information, the National Park Service would 

implement these restrictions on the rivers to reduce visitor conflicts with river rafters, fishermen, and 

backcountry hikers; promote opportunities for visitor enjoyment; and ensure visitor safety. 

Public Comment: Commenter: Affiliation: 

1239N Utah Shared Access Alliance Organization 

 

Issue 2: Protection of Resources Under the Recreation Area’s Enabling Legislation and General

Management Plan

A Comment: The map on page 129 and table 17 on page 128 do not provide information about the use of all 

tributaries since those tributaries are not broken out of the figures. For example, use zone 9 includes the 

Escalante River along with the reservoir above and below the river. There is no information regarding the 

level of use on the Escalante River or how much of the river is actually used. This capability to determine 

whether the restrictions under alternative B would be effective. 

Response: Figure 13 and table 19 represent the broad management zones used by Glen Canyon National 

Recreation Area for parkwide use analysis. The University of Minnesota study (James 2000) used these 

zones to capture visitor trip itineraries and was not used to analyze use or management actions proposed 

for the tributary river canyons. Table 21 provides use estimates that are specific to the areas of proposed 

action. 

Public Comment: Commenter: Affiliation: 

1245D Sierra Club, Utah Chapter Organization 

 

Issue 3: There Is Inadequate Data on Perceptions of Nonmotorized Watercraft Users

A Comment: The Draft Environmental Impact Statement does not adequately examine the adverse impacts 

of personal watercraft use to canoeist and kayakers. There is no evidence that the National Park Service 

surveyed paddler perceptions of Lake Powell, the lake’s appeal (or lack thereof) to canoeists and 

kayakers, or how personal watercraft impact their visitor experience. The Draft Environmental Impact 

Statement appears to rely on visitation data and surveys that reflect little input from paddlers. 
VISITOR USE AND EXPERIENCE

78 

Response: The University of Minnesota survey (James 2000) representatively sampled all boaters in order 

to develop the analysis presented in the report. The sample included nonmotorized watercraft users, 

including canoeists and kayakers; these users represented approximately 4% of watercraft in the survey. 

While this is a small sample, the analysis of effects on these user groups is qualitatively addressed in the 

“Visitor Experience” section of the “Environmental Consequences” chapter. The best available data and 

professional judgment were used to analyze the effects of personal watercraft on recreation area visitors. 

Public Comment: Commenter: Affiliation: 

1168E American Canoe Association Organization 

 

Issue 4: Conclusions Drawn from University of Minnesota Study Are Incorrect. It Does Not Include a 

National Sample and Underestimates Public’s Perception of Personal Watercraft Impact

A Comment: The University of Minnesota study (James 2000) states that personal watercraft do not impact 

the recreational experience of national recreation area visitors, yet their own results appear to reveal the 

opposite. On page six of the study, table four shows that three of the top four problems cited by nonpersonal watercraft users are related to personal watercraft operation (unsafe personal watercraft 

operation, personal watercraft congestion, personal watercraft conflicts). Without a complete, fair, and 

comprehensive public opinion survey which includes the beliefs of park visitors who may be forced out of 

Glen Canyon due to personal watercraft operation, the Draft Environmental Impact Statement’ sections on 

visitor use and visitor conflicts are incomplete. 

Response: The University of Minnesota study was conducted using standard social science methodologies 

and received peer review of its conclusions. The study was limited to visitors to Glen Canyon National 

Recreation Area. The results of the study were combined with other data and professional judgment that 

enabled qualitative predictions of the effects of the alternatives on the full range of recreation area visitors 

and potential visitors. 

Public Comment: Commenter: Affiliation: 

1002Y Bluewater Network Organization 

 
79 

Regulations, Methodologies, and Assumptions

Issue 1: Assumptions that Personal Watercraft Use Would be Replaced by Other Watercraft Use Is 

Unsubstantiated and Visitors Using More Than One Type of Watercraft Were Not Counted Twice 

A Comment: Table 3 states,” Visitors who did not use personal watercraft would generally perceive minor 

to moderate, short-term benefits. These benefits would decline to negligible in the long term. Other 

cumulative effects would be negligible.” There does not seem to be any rationale for this conclusion. Why 

does the National Park Service conclude there would only be a perception of “moderate, short-term 

benefits” which would decline to “negligible in the long term?” What research yielded such a result? At 

one point the National Park Service asserts that there would be approximately a 25% decrease in 

watercraft if personal watercraft are banned from the reservoir. This would be dramatic in some areas. 

The National Park Service at one point concludes that this drop in watercraft would eventually disappear 

and that former personal watercraft users would soon return with other watercraft. This requires that the 

National Park Service knows that all of the personal watercraft users wished only to recreate in the Glen 

Canyon National Recreation Area and would soon replace the personal watercraft with other watercraft 

and return. This totally discounts that some if not most personal watercraft users choose primarily the 

form of recreation and only secondarily choose where to recreate. It is entirely more likely that personal 

watercraft users will seek sites where such use is permitted. 

 The Draft Environmental Impact Statement also notes that the personal watercraft is often only one of the 

watercraft that arrives with group of users. Powerboat users and house boat users are also personal 

watercraft users. From reading the Draft Environmental Impact Statement it is not clear that users of more 

than one kind of watercraft do not get counted twice for some analyses. If half of all personal watercraft 

are part of a group of craft used by a single group of users, then the results of banning personal watercraft 

may result in fewer motorized watercraft users returning since half of the personal watercraft users were 

already using other watercraft on the reservoir. 

Response: The analysis in the Final Environmental Impact Statement carries forward the assumption from 

the Draft Environmental Impact Statement that following a ban on personal watercraft the total number of 

watercraft operating hours on the lake would be decreased in the short-term. Based on national park 

system use trends, it is assumed, however, that total watercraft operating hours under alternative C would 

recover by 2012 to use levels similar to the range predicted under alternatives A and B. This would be due 

to either natural growth in visitation (assuming a 2% annual increase in use) or increased visitation by 

individuals who previously avoided the recreation area because of personal watercraft but who would 

choose to visit if personal watercraft were absent. 

Public Comment: Commenter: Affiliation: 

1245H Sierra Club, Utah Chapter Organization 

 

Issue 2: Personal Watercraft Ban Does Not Automatically Lead to Decrease in Use

A Comment: The assumption that a personal watercraft ban at Glen Canyon will automatically result in a 

decrease in park visitation is highly questionable. NPS data shows that parks that ban personal watercraft 

may actually see increases in visitation. From the most recent visitation data (January through August), 

the National Park Service reports that at the 13 parks that banned personal watercraft on April 22, 2002, 

park visitation increased on average by 7% over 2001 counts. In fact, at Delaware Water Gap and 

Gateway, the two national recreation areas on the list, park visitation has actually increased by more than 

10% as compared to last year. By contrast, from the same visitation data cited above, at the eight parks 

where personal watercraft use has continued, park visitation is down 10%. At Glen Canyon, park 

visitation is also down 10% from last year. These numbers clearly shows that personal watercraft bans do 

not automatically lead to reduced visitation. 

Response: The Final Environmental Impact Statement has been changed and includes an analysis of use 

trends within units of the national park system compared to use trends within Glen Canyon National 
VISITOR USE AND EXPERIENCE

80 

Recreation Area. The analysis indicates that over the past decade, use within NPS units increased on 

average by 0.3% per year. Within parks that have characteristics that allow personal watercraft nearly 

similar to Glen Canyon (e.g., water-based, seashores and lakeshores, recreation areas, western parks, or 

large popular parks), use increased on average by 1.05% annually over the past decade. Use at units that 

allow personal watercraft increased by an average 0.26% annually. While personal watercraft use at 

Delaware Water Gap National Recreation Area and Gateway National Recreation increased at the rates 

noted in the comment, it should also be noted that these two areas sustained 1.2% and 4.1% average 

annual growth, respectively, over a 10-year period, compared with an average annual decrease of 4.8% 

and 2.6%, respectively, for Big Horn Canyon National Recreation Area and Glen Canyon National 

Recreation Area. There is no evidence that these trends were strongly influenced by the presence or 

absence of personal watercraft. 

A visitor use forecast range of –2% and +2% average annual change was used in the Final Environmental 

Impact Statement to 2012. Using this range enables the impact analysis for resources, such as air and 

water quality, to be viewed in a range of use scenarios that will enhance the ability to make decisions. The 

effects of the alternatives on visitor experience and visitor safety continue to be analyzed qualitatively, so 

as not to be dependent on specific forecasts of visitor use. 

Public Comment: Commenter: Affiliation: 

1002AF Bluewater Network Organization 

 

Issue 3: Provide an Explanation of How Estimates of Personal Watercraft Use in the Tributaries Were 

Derived

A Comment: What is the source of the estimates provided in table 18 on page 131 of the Draft 

Environmental Impact Statement? These show that the estimated use in the restricted areas is very small. 

Response: The estimates are based on the observations of NPS staff who patrol the areas that are included 

within alternative B (the modified preferred alternative). 

Public Comment: Commenter: Affiliation: 

1245B Sierra Club, Utah Chapter Organization 

 

Issue 4: Need to Evaluate the Effects of Personal Watercraft on Nonmotorized Users

A Comment: The National Park Service needs to consider the balance of recreational opportunities and 

whether or not it is providing an adequate range of recreational opportunities. In terms of this particular 

environmental impact statement the National Park Service needs to determine if personal watercraft 

contribute to the lack of human centered recreation. This could be difficult to assess but it could be 

attempted. The Glen Canyon National Recreation Area could review records for any organized permitted 

kayak or canoe trips on the reservoir. Such groups could be contacted and given a survey about the 

impacts of motorized use on their experiences and the effects of personal watercraft in particular. In 

addition the National Park Service could contact user groups of kayakers and canoeists to survey attitudes 

towards encountering personal watercraft during recreational excursions. 

An additional survey of the desired experience of non-boat users and back-country users should be 

conducted to assess the perspectives of these users. 
Regulations, Methodologies, and Assumptions

81 

Response: Alternative B (the modified preferred alternative) currently provides for a three-year pilot 

study to further evaluate personal watercraft use areas. Potential restrictions of personal watercraft use in 

other locations of the recreation area would be evaluated at that time. The purpose of the pilot study and a 

description of how it would be implemented are provided in appendix C.

 

Public Comment: Commenter: Affiliation: 

1245F Sierra Club Organization 

1391K Sierra Club, Utah Chapter Organization 

 
82 

WATER QUALITY

Affected Environment

Issue 1: Add Information on MTBE (methyl tertiary butyl ether)

A Comment: Why is MTBE incorporated into the water quality methodology? Why was a high percentage 

of MTBE in gasoline used in the calculations? MTBE is being replaced by components such as ethanol. 

Response: The methodology described in the “Environmental Consequences” chapter and appendix G 

uses an MTBE concentration in gasoline of 15%. This represents a general maximum concentration of 

this additive. Inclusion of this value is consistent with the intent of the method to estimate “what could 

happen.” In the water quality analysis, an ecotoxicological benchmark for MTBE of 51,000 μg/L was 

used. The calculations, as well as the water quality testing, found only a negligible impact from MTBE at 

Glen Canyon. Use of MTBE is being reduced, and several states have implemented or are planning bans 

or dramatic reductions on the sale of gasoline containing MTBE. For an overview of current MTBE use 

and phase-out, please see the August 2002 Department of Energy publication Controversial Additive, 

MTBE, is Gradually Phased Out by States (www.bioproductsbioenergy.gov/news/displayrecentarticle.asp?idarticle=13). 

Public Comment: Commenter: Affiliation: 

1239C Utah Shared Access Alliance Organization 

 

Issue 2: Clarify Utah State Water Quality Regulations Including Designated Uses for the Lake and Drinking 

Water Intake Locations

A Comment: The Final Environmental Impact Statement should list all designated uses for the Lake. 

Response: Designated uses for Lake Powell (in Arizona and Utah) are listed in the “Water Quality” 

section of the “Affected Environment” chapter. 

Public Comment: Commenter: Affiliation: 

1393K Environmental Protection Agency Public Agency 

 

B Comment: Presence and location of drinking water intakes not addressed in the “Affected Environment” 

section. 

Response: Information on the locations of the drinking water intakes near Hite Marina and at Glen 

Canyon Dam has been added to the “Affected Environment” chapter in the “Water Quality” section. 

Public Comment: Commenter: Affiliation: 

1393K Environmental Protection Agency Public Agency 

 

C Comment: Utah’s anti-degradation policy is undergoing review, verify accuracy before the Final 

Environmental Impact Statement is complete. 
Affected Environment

83 

Response: Utah’s water quality antidegradation policy is discussed in the “Water Quality” section of the 

“Affected Environment” chapter. The Water Quality Division of Utah’s Department of Environmental 

Quality was contacted regarding the status of the current antidegradation policy. As of February 5, 2003, 

the rule was still under review. The existing regulation will be used to guide management decisions until 

any changes are published by the Utah Department of Environmental Quality. 

Public Comment: Commenter: Affiliation: 

1137F US Fish and Wildlife Service Public Agency 

 

Issue 3: Data Presentation and Analysis Incomplete for PAH (polycyclic aromatic hydrocarbons) and Other 

Fuel Components

A Comment: Regarding properties of benzo(a)pyrene: “Oysters and bluegills are susceptible to buildup, but 

mudsuckers and sculpins show no tendency toward accumulation.” This statement should have a 

reference, because it implies the results of a study. 

Response: The reference regarding benzo(a)pyrene as cited in the Final Environmental Impact Statement 

is EPA 2002. Technical Factsheet on: Polycyclic Aromatic Hydrocarbons (PAH). This reference is 

available on the Internet at http://www.epa.gov/OGWDW/dwh/t-soc/pahs.html. 

Public Comment: Commenter: Affiliation: 

1137E US Fish and Wildlife Service Public Agency 

 

B Comment: The discussion does not contain enough information to evaluate whether the design or results 

of the study are applicable to Lake Powell and its biota. Are striped bass more similar to bluegills or 

sculpins? Are catfish more similar to oysters or mudsuckers? Is benzo(a)pyrene more or less likely to 

build up in the Lake Powell ecosystem? 

Response: The Final Environmental Impact Statement acknowledge that little is known about the specific 

behaviors and environmental effects of many PAH, including benzo(a)pyrene. Toxicity data for the 

species inhabiting Lake Powell were not available for the gasoline components analyzed using the water 

quality methodology. Freshwater benchmarks, obtained from peer-reviewed literature, were used for 

calculation of both ecological and human health threshold volumes. See appendix G for details on the 

approach for evaluating surface water quality impacts. 

Public Comment: Commenter: Affiliation: 

1137 E US Fish and Wildlife Service Public Agency 

 

Issue 4: Data Collection (Water Quality Sampling) and Presentation

A Comment: Presenting average values for water quality testing samples, infers complete mixing of lake 

waters. 

Response: Inclusion of average values was not intended to infer that lake waters are mixed, but rather to 

show the reader a mean value for relative comparison to measured maximum and minimum values. The 

“average values” have been removed from table 8. 

Public Comment: Commenter: Affiliation: 

905D, 905E Individual 

 
WATER QUALITY

84 

B Comment: The need to sample Wahweap Marina is called to attention based on the results at Bullfrog 

Marina sample where benzene concentrations were elevated. 

Response: Under the modified preferred alternative (alternative B), the National Park Service would 

implement a water quality monitoring program at Lake Powell. This program will be guided by the 

Technical Advisory Committee, and is detailed in the Final Environmental Impact Statement description 

of alternative B (the modified preferred alternative) in the “Alternatives” chapter. Locations selected for 

ongoing testing will be chosen to maximize use of data in making appropriate management decisions. 

Public Comment: Commenter: Affiliation: 

905E Individual 

 

C Comment: On page 83, the National Park Service appears to make the assumption that the national 

recreation area’s water quality is good by the apparent visual clarity of the lake. However, despite the fact 

that the National Park Service stated in appendix D that it doesn’t have site-specific transparency data, 

water clarity is not a good indication of water quality. 

Response: The text referred to by the commenter discusses water quality indicators near marinas and 

fueling stations. Away from high-use areas “waters are clear and appear clean to the casual observer.” 

This statement simply provides a comparison for the reader regarding observable water quality 

parameters. 

Public Comment: Commenter: Affiliation: 

1002AC Bluewater Network Organization 

 

Issue 5: Insufficient Detail of Monitoring Plan and Marina Best Management Practices Information 

Pertaining to Persistent Hydrocarbon Constituents

A Comment: Monitoring should also be done in drinking water intakes to assure that drinking water 

standards are met for Arizona and Utah. 

Response: Water quality monitoring at the Hite drinking water intake would take place under all 

alternatives addressed in the Final Environmental Impact Statement. The water quality monitoring 

program would be directed by the Technical Advisory Committee, formed in 1996 to protect Lake 

Powell’s water quality. The plan would ensure that water quality complies with state regulations and 

criteria and is consistent with requirements of the Clean Water Act. 

The drinking water intake at Glen Canyon Dam, which serves the town of Page, AZ, is under the 

jurisdiction of the Bureau of Reclamation. The National Park Service has no authority to access this site to 

obtain water quality samples. 

Potable water obtained from Lake Powell is tested after treatment at both the Hite and Page water 

treatment plants. The localities are responsible for the final quality of the drinking water, in addition to the 

state requirements for the quality of the drinking water source. 

The “Water Quality” section in the “Affected Environment” chapter has been revised to include additional 

information regarding the drinking water intakes at Hite and Page. 

Public Comment: Commenter: Affiliation: 

1393K Environmental Protection Agency Public Agency 

 
Affected Environment

85 

Issue 6: Establish Whether Personal Watercraft Use Is Violating or Has the Potential to Violate StateAdopted Water Quality Standards, Including Impairment of Utah’s Drinking Water Source Criteria

A Comment: Page 83 includes a discussion of marina activities and notes evidence of a “rainbow sheen” at 

these sites. Utah Water Quality Standards (R317-2, Utah Administrative Code) include a narrative 

standard which establishes that “it shall be unlawful ... to discharge or otherwise place waste or other 

substance in such a way as will be or may become offensive such as unnatural deposits, floating debris, 

oil, scum, or other nuisances such as color, odor or taste.” 

Response: The Utah Department of Environmental Protection, Water Quality Division, was contacted for 

interpretation of Water Quality Standard R317-2. The term “oil scum” is not intended to equate to the 

“rainbow sheen” commonly seen on water surfaces at fueling stations and marinas. These sheens are 

generally localized and transient. The sheen itself was not tested during water quality sampling for this 

assessment. Suggestions regarding sampling locations and techniques would be incorporated into the 

water quality monitoring program proposed under alternative B (the modified preferred alternative) in the 

Final Environmental Impact Statement. Recognizing that the presence of the sheen does indicate degraded 

water quality, the text in the Final Environmental Impact Statement has been changed to acknowledge 

temporary, localized degradation of water quality. Because the sheen results from combined marina and 

fueling activities, it was not possible to determine the specific personal watercraft-related contribution to 

this transient water quality issue. 

The modified preferred alternative (alternative B) in the Final Environmental Impact Statement includes 

mitigation measures to further protect park waters. Under the modified preferred alternative, 

(alternative B) personal watercraft engines would be 100% compliant with EPA 2006 emission standards 

after 2012, further reducing petroleum-related pollution. Based on the analysis presented, the National 

Park Service finds that the modified preferred alternative (alternative B) (including the provision for 

continued personal watercraft use), if implemented, would not result in an impairment of park water 

quality. 

Public Comment: Commenter: Affiliation: 

1393F Environmental Protection Agency Public Agency 

 

B Comment: Address whether Arizona anti-degradation regulations or water quality standards would be 

violated. If the visible sheen, or numeric concentrations of individual chemicals are in violation of 

standards, the water quality effects should be designated “major” rather than “negligible to minor.” 

According to the Draft Environmental Impact Statement, a “major” impact is present where “chemical, 

physical or biological water quality standards or criteria would be locally slightly and singularly exceeded 

on a short-term and temporary basis. 

Response: Lake Powell is an Arizona Tier II water body, and existing water quality “shall be maintained 

and protected. Water quality shall not be lowered to a level that does not comply with applicable water 

quality standards” (Arizona Administrative Code R18-11-107; see the “Water Quality” section, “Affected 

Environment” chapter). The NPS water quality sampling preformed at Lake Powell did not show that any 

Arizona water quality criteria were exceeded. As shown in table 9 in the “Affected Environment” chapter, 

Arizona standards are not as stringent as those for Utah, with the exception of naphthalene. The 3.43 μg/L 

benzene concentration found at Bullfrog Marina is below the Arizona criteria of 5 μg/L for drinking water 

sources. No impairment of Arizona designated uses for the waters of Lake Powell would be anticipated 

under any of the alternatives analyzed in this assessment. The conclusions contained in the “Water 

Quality” section of the Final Environmental Impact Statement text have been changed to reflect this 

finding. 
WATER QUALITY

86 

The modified preferred alternative (alternative B) in the Final Environmental Impact Statement includes 

mitigation measures to further protect water quality in the recreation area. If implemented, the modified 

preferred alternative would provide an important step toward substantially reducing petroleum-related 

pollution by restricting the use of carbureted two-stroke engines in 2012. 

Public Comment: Commenter: Affiliation: 

1393F Environmental Protection Agency Public Agency 

 

Issue 7: Need to Discuss Impacts on Water Quality Below the Dam

A Comment: Pollutants discharged into Lake Powell can have detrimental impacts upon water quality, 

endangered species, public health, and wildlife downstream. Despite the fact that oil dumped in Lake 

Powell will impact resources and wildlife downstream from the national recreation area, the National Park 

Service makes no mention of it in the Draft Environmental Impact Statement. 

Response: The National Park Service established the project area for this analysis to coincide with the 

areas of personal watercraft use at Glen Canyon National Recreation Area. Analysis of downstream 

impacts is outside the scope and mandate of this assessment. However, uses of Lake Powell could affect 

the quality of water downstream. The water quality analysis revealed that negligible to minor adverse 

effects occur due to personal watercraft use on Glen Canyon National Recreation Area. Measured water 

quality showed that no established water quality criteria were exceeded, with the exception of benzene. As 

discussed in the “Water Resources” section in the “Environmental Consequences” chapter, only half of 

the PAH (polycyclic aromatic hydrocarbons) and other gasoline components are emitted from personal 

watercraft, which is the sole subject of this assessment. Given the volatile nature and brief half-life of 

benzene (five hours) and the method of water release through Glen Canyon Dam (from the bottom), it is 

unlikely that fuel components found in lake waters contributed by personal watercraft use on the lake 

would have detectable effects below the dam. In addition, neither the states of Utah nor Arizona have 

water quality criteria for PAH compounds relative to irrigation water (see table 9). Until such standards 

are established, there would be no enforceable regulation applicable to these constituents, and there would 

be no effect on the designated use for irrigation or the distribution of waters for agricultural purposes. 

The modified preferred alternative (alternative B) in the Final Environmental Impact Statement includes 

mitigation measures to further protect water quality in the recreation area. If implemented, the modified 

preferred alternative (alternative B) would provide an important step toward substantially reducing 

petroleum-related pollution by restricting the use of carbureted two-stroke personal watercraft engines in 

2012. Based on the analysis presented, the National Park Service finds that the modified preferred 

alternative (alternative B) (including the provision for continued personal watercraft use) would not result 

in an impairment of park water quality. 

Public Comment: Commenter: Affiliation: 

1002AC 

905L 

Bluewater Network Individual 

 
87 

Cumulative Effects

Issue 1: Cumulative Effects of Loading Were Ignored

A Comment: Cumulative effects of the loading were ignored. The estimated emission into the lake assumed 

that on a daily basis, 100% of hydrocarbon emissions volatilized daily. The emissions from personal 

watercraft contain oil, and oil does not volatilize completely. 

Response: Although most polycyclic aromatic hydrocarbon (PAH) components there is the possibility for 

some of these pollutants to accumulate in the water column. The text has been changed and is included in 

the Final Environmental Impact Statement to provide more information on volatility and on the 

evaporation and half-life rates applicable to the waters of Lake Powell. 

Public Comment: Commenter: Affiliation: 

905F Individual 

 
88 

Impacts on Water Quality from Personal Watercraft Use

Issue 1: New References to Include in Water Quality Analysis

A Comment: In the report Water Quality Concerns related to Personal Watercraft Usage, the National Park 

Service admits that gas and combustion products are routinely found in lakes and reservoirs with personal 

watercraft use, sometimes at levels which threaten both human and ecological health. This is particularly 

troubling because PAH — even at minute levels of parts per trillion — are toxic to aquatic plants and fish. 

The research also found that concentrations of many of these pollutants remained substantially elevated in 

the test tank one full day after testing. 

Response: Recognizing that some pollutant concentrations in the water column from two-stroke 

carbureted engines are greater than those of comparable four-stroke engines, the evaluation of surface 

water quality impacts in the “Water Resource” section of the “Environmental Consequences” chapter 

addresses the combined effects of all recreational boats and personal watercraft. Under the modified 

preferred alternative (alternative B), a chemical pollutant monitoring program would be instituted 

(funding is currently being sought) in order to protect the high water quality standards for fisheries 

protection, human health, and recreation. If monitoring determines that water quality standards are being 

violated, management actions would be evaluated and implemented to reduce the effects of polluting 

activities. 

Furthermore, if implemented, the modified preferred alternative (alternative B) in the Final 

Environmental Impact Statement would provide an important step toward substantially reducing 

petroleum-related pollution by restricting the use of carbureted two-stroke personal watercraft engines in 

2012. Based on the analysis presented, the National Park Service finds that the modified preferred 

alternative (including the provision for continued personal watercraft use) would not result in an 

impairment of park water quality. 

Public Comment: Commenter: Affiliation: 

1002E, 1002K Bluewater Network Organization 

 

Issue 2: Water Quality Analysis Is Inadequate Because it Omitted Relevant Research, Used Extreme 

Assumptions, or Disregarded Significant Impacts Still Present with New Technology 

A Comment: You didn’t mention anything about the study that was completed at Lake Powell by the closing 

of Bowns and Knowles Canyons for the past two years. The samples of water and soil taken show No 

discernible difference than the rest of the lake, and certainly no difference if boats had been present or not. 

Response: The U.S. Geological Survey (USGS) recently completed two years of data collection in three 

side canyons at Glen Canyon National Recreation Area. Data were gathered during high boating-use 

periods, low-use periods, and in a control canyon with no boat traffic. Water and sediment were tested for 

a large suite of contaminants, including nutrients, components of wastewater, trace minerals, volatile 

organic compounds, and components of gasoline and grease. The data are currently undergoing analysis at 

the U.S. Geological Survey, and a contaminant database is being developed. The results of the study will 

be published when the analysis is complete. The findings of the report will be valuable in forming future 

management decisions regarding wastewater handling, motorized vessel impacts on water and sediment 

quality, and upstream contributions of metals and minerals. 

Public Comment: Commenter: Affiliation: 

1209B Individual 

 
Impacts on Water Quality from Personal Watercraft Use

89 

Issue 3: Insufficient Detail of Monitoring Plan and Marina Best Management Practices Information 

Pertaining to Persistent Hydrocarbon Constituents

A Comment: The Draft Environmental Impact Statement lacks a description of a detailed long-term 

monitoring plan to ensure evaluation of impacts on the aquatic system. 

Response: Each alternative addressed in the Final Environmental Impact Statement includes 

implementation of a water quality monitoring plan. This program would be directed by the Technical 

Advisory Committee, formed in 1996 to protect Lake Powell’s water quality. The plan would ensure that 

water quality complies with state regulations and criteria and is consistent with requirements of the Clean 

Water Act. The monitoring program would incorporate the findings of two recently completed studies on 

the chemical content of lake waters and sediment in the Colorado River inflow area and three side 

canyons. The dynamics of sediment re-suspension in the Colorado River inflow is currently underway. 

Funding is also being sought for additional studies in the San Juan and Escalante River inflow areas. The 

monitoring plan would include hydrocarbon content of sediments and polycyclic aromatic hydrocarbon 

(PAH) content of lake waters. Benthic population studies may be included, if deemed necessary by the 

Technical Advisory Committee. Findings of these various studies will be used to guide management 

decisions for polluting activities that take place on Lake Powell. 

Public Comment: Commenter: Affiliation: 

1393E Environmental Protection Agency Public Agency 

 

B Comment: This environmental impact statement should assess whether there are best management 

practices available for personal watercraft fueling that would reduce or eliminate fuel spills and minimize 

the potential for violations of applicable State water quality standards. 

Response: The NPS Hazardous Waste Management and Pollution Prevention Team has developed a Spill 

Prevention Control and Countermeasures Plan (NPS 1998d) that provides recommendations and 

requirements to prevent environmental damage resulting from spills of oil. These plans are required by the 

EPA as stated in 40 CFR, Part 112. The National Park Service and all marina operators must comply with 

these requirements to limit the environmental effects of fueling on the lake. In accordance with this 

regulation, ARAMARK, the park concessioner, has developed a Spill Prevention Control and 

Countermeasure Plan for all fueling sites within the recreation area (ARAMARK, n.d.). In addition, 

educational materials such as placards are displayed at marinas to inform boat operators about proper 

fueling of vessels and containers, to reduce the potential for fuels entering the water. 

Public Comment: Commenter: Affiliation: 

1393F Environmental Protection Agency Public Agency 

 

Issue 4: Establish Whether Personal Watercraft Use Is Violating or Has the Potential to Violate State 

Adopted Water Quality Standards, Including Impairment of Utah’s Drinking Water Source Criteria 

A Comment: The water quality section of the Final Environmental Impact Statement should clearly state 

whether activities regulated by the National Park Service are violating, or have the potential to violate, 

State-adopted, EPA-approved water quality standards under the Federal Clean Water Act. 

Response: The Utah Department of Environmental Quality, Water Quality Division, was contacted for 

clarification of the state’s assessment of Lake Powell water quality. The division reported that the state 

has no concerns with regard to the 1.7 μg/L and 3.43 μg/L benzene concentration obtained near Bullfrog 

Marina during water quality testing. The drinking water intake near Hite Marina is approximately 

0.25 mile upstream of the marina, and it is unlikely that gasoline components from the marina would 

migrate in this direction. Hite is also a smaller marina than Bullfrog, with much less boat traffic and 

fueling activities. In addition, the intake floats at approximately 12 feet below the water surface. Benzene 

is lighter than water, highly volatile, and has a half-life of approximately five hours. 
WATER QUALITY

90 

The Final Environmental Impact Statement proposes a water quality monitoring program in each of the 

alternatives considered. This plan is outlined in the “Alternatives” chapter and is discussed in the “Water 

Quality” responses to comments at comment 1393 E, above. 

The “Water Quality” section in the “Affected Environment” chapter has been changed in the Final 

Environmental Impact Statement to include new information on the drinking water intakes, and 

jurisdiction over the two sites. 

Public Comment: Commenter: Affiliation: 

1393A Environmental Protection Agency Public Agency 

 

Issue 5: Cumulative Effects of Loading Were Ignored

A Comment: The Draft Environmental Impact Statement failed to list under alternative C benefits which 

apply to all three alternatives, namely the beneficial impacts on air and water quality due to the increasing 

proportion of low emission engines which will be realized in the Lake Powell fleet over time. 

Response: The cumulative effects analysis under alternative C discusses reduction in pollutant loadings to 

water by the changeover of all carbureted two-stroke technology, not just cessation of personal watercraft 

use. Pollution contribution from other two-stroke vessels is shown to decrease after 2005, with total 

contribution of four-stroke engines increasing relative to total pollutant inputs (see table 39 and the text 

that follows it for more information). 

Public Comment: Commenter: Affiliation: 

1180G Individual 

 
91 

Regulations, Methodologies, and Assumptions

Issue 1: PAH Data Presentation and Analysis Incomplete

A Comment: The numeric criteria for benzo[a]pyrene however, is less than the reporting limit that the 

Woods Hole Laboratory could report, (appendix D.1). 

Response: The National Park Service acknowledges this inconsistency between the human health 

benchmark for benzo(a)pyrene and the reporting limit. The toxicological benchmark that is below the 

reporting limit (10 parts per trillion) is for combined consumption of fish flesh and ingestion of water 

from the source. This benchmark is established at 4.4 parts per trillion. Although the detection threshold 

was above the toxicity benchmark for human health (when both organisms and water are consumed), the 

water quality method can be used to determine if this criteria would be violated. Table 36 and the text that 

follows it, detail the water volume needed to meet the human health criteria for benzo(a)pyrene. Current 

pollutant loadings from personal watercraft alone would require 14,883 acre-feet to reach the toxicity 

threshold. For other two-stroke engines, the value is 7,432 acre-feet. This represents a small fraction of 

the volume available to dilute the pollutant, and no adverse effects to human health would be expected 

from current benzo(a)pyrene loading to Lake Powell. No text changes were necessary to address this 

comment. 

Public Comment: Commenter: Affiliation: 

905C Individual 

 

Issue 2: Data Collection (Water Quality Sampling) and Presentation

A Comment: The Draft Environmental Impact Statement assessment of water quality is based on water 

column samples taken at 0.5 and 3 meter depths. Given that most constituents from watercraft exhaust or 

spills will float on the water’s surface, it would seem logical to collect water samples at the water’s 

surface rather than 0.5 meters below to determine compliance with standards. 

Response: In a recent study by the U.S. Geological Survey (Albers 2002), PAH compounds were found to 

be 18 times higher in the surface microlayer than in the water column below. To address the transient 

water quality issues associated with this concentration of low molecular weight hydrocarbons, the 

National Park Service would implement lake-wide comprehensive water quality testing under 

alternative B (the modified preferred alternative) (see the “Alternatives” chapter). 

Public Comment: Commenter: Affiliation: 

1393H Environmental Protection Agency Public Agency 

 

Issue 3: Water Quality Analysis Is Inadequate Because it Omitted Relevant Research, Used Extreme 

Assumptions, or Disregarded Significant Impacts Still Present with New Technology

A Comment: The National Academy of Sciences (NAS) recent report Oil in the Sea III: Inputs, Fates and 

Effects addresses impacts due to oil and gas mixture used in personal watercraft. Pollutants such as PAH 

can remain suspended in the water column, or be deposited in sediment for years after initial deposition. 

Explain how it can be concluded that the oil and gas mixture dumped by personal watercraft is not 

damaging park resources. The National Park Service also seems to make mistakes when estimating the 

daily fuel load for Lake Powell. On page 168 the calculations contain the assumption that only a small 

residual concentration of the daily fuel load will carry over to the following day. The National Park 

Service is underestimating the amount of gas and oil personal watercraft dump into the lake that is carried 

over into the next day. 

Response: The protection of water quality within Glen Canyon National Recreation Area has been 

addressed in this Final Environmental Impact Statement, which contains evaluations of surface water 
WATER QUALITY

92 

quality impacts. An estimated minimum threshold volume of water in Lake Powell, below which 

concentrations of fuel constituents from personal watercraft or other outboard engines would be 

potentially toxic to aquatic organisms or humans was determined. Using the estimated threshold volumes, 

characteristics of the contaminants identified, and physical attributes of the water body, it is possible to 

identify unacceptable risks to human health or the environment. There are a limited number of EPA 

criteria for the protection of human health (via ingestion of water and aquatic organisms or ingestion of 

aquatic organisms only). Chronic ecotoxicological and human health benchmarks for contaminants were 

acquired from various sources. The evaluation presents the most restrictive thresholds, based on both 

federal and state water quality standards, for the pollutants. Table 10 shows the benchmarks used in the 

evaluation for each pollutant. 

Furthermore, if implemented the modified preferred alternative (alternative B) in the Final Environmental 

Impact Statement would provide an important step toward substantially reducing petroleum-related 

pollution by restricting the use of carbureted two-stroke personal watercraft engines at the end of 2012. 

Based on the analysis presented, the National Park Service finds that the modified preferred alternative 

(alternative B) (including the provision for continued personal watercraft use) would not result in an 

impairment of park water quality. 

Public Comment: Commenter: Affiliation: 

1002AC Bluewater Network Organization 

 

B Comment: The water quality assessment uses assumptions that result in overestimation of potential 

personal watercraft hydrocarbon emissions to the water in Lake Powell, amounting to the “most extreme 

adverse conditions.” For example, benzo(a)pyrene concentrations in gasoline range from 0.19 to 2.8 

mg/kg, and the highest value was used. Similarly, MTBE concentrations in gasoline were range from 0% 

to 15%, but only the highest figure was used. 

Response: In an effort to determine “what could happen,” a conservative methodology was constructed 

using the highest concentration of known pollutants commonly found in gasoline. The values referenced 

by the respondent were incorporated into the analysis to determine if the mixing layers of Lake Powell 

have adequate volume to mitigate the effects of carbureted two-stroke personal watercraft engines, as well 

as other watercraft. Using this conservative approach, it was determined that the water quality impacts 

generated by personal watercraft use would be negligible to minor, and that no water quality criteria for 

designated uses of the lake would be violated. The National Park Service is satisfied that incorporation of 

the given component concentration in gasoline has served this approach. Table 10 shows the benchmarks 

used in the evaluation for each pollutant. 

In addition, if implemented, the modified preferred alternative (alternative B) in the Final Environmental 

Impact Statement would provide an important step toward substantially reducing petroleum-related 

pollution by restricting the use of carbureted two-stroke personal watercraft engines at the end of 2012. 

Based on the analysis presented, the National Park Service finds that the modified preferred alternative 

(alternative B) (including the provision for continued personal watercraft use) would not result in an 

impairment of park water quality. 

Public Comment: Commenter: Affiliation: 

1344J Personal Watercraft Industry 

Association 

Organization 

 

C Comment: The assessment represents an outdated look at potential emissions from an overstated personal 

watercraft population of conventional two-stroke vessels, and underestimates the accelerating changeover 

to four-stroke and newer technology two-stroke models. Sales of these newer models have already 

overtaken conventional two-stroke personal watercraft. As shown in the Sierra Research analysis, the 

changeover personal watercraft engines that meet the requirements of the EPA 2006 and CARB 2008 

emission standards is occurring much more rapidly than EPA and the National Park Service have 
Regulations, Methodologies, and Assumptions

93 

estimated. The amounts of unburned fuel released at Lake Powell will decline rapidly, achieving a 

reduction from the 1998 baseline levels of more than 50% by 2006 and approximately 80% by 2012. See 

Sierra Report at 1. The Draft Environmental Impact Statement, in contrast, only estimated a 25% 

reduction in hydrocarbon emissions from personal watercraft in the Glen Canyon National Recreation 

Area by 2006, and only a 50% reduction by 2012. Draft Environmental Impact Statement at 169. 

Response: In the water quality analysis, the assumption was made that clean technology engines (any 

engine not using carbureted two-stroke technology) would be 90% cleaner than the carbureted two-stroke 

engines. This is based on two assumptions made by the commenter. The first is based on confidential, 

proprietary personal watercraft sales and forecast data prepared by personal watercraft manufacturers. No 

supporting data was supplied with the comment. The commenter states that the data indicates that the 

conversion of personal watercraft models to cleaner engines is occurring more rapidly than anticipated in 

the 1996 EPA analysis of the effects of the conversion rule. While the National Park Service has no 

reason to doubt that personal watercraft conversions are proceeding at a greater rate than forecast by the 

Environmental Protection Agency, there is no survey or similar data available at this time indicating the 

engine conversion at Glen Canyon is proceeding at a faster or slower rate than the EPA forecast. 

Therefore, use of the EPA rates is considered appropriate. The second assumption by the commenter is 

that 75% of the personal watercraft at Glen Canyon would have engines that comply with the California 

Air Resource Board (CARB) conversion rule that requires marine engine manufacturers implement the 

EPA emission targets sooner than those outlined by the federal rule. The commenter assumes that 50% of 

personal watercraft users at Glen Canyon will be from California, and will have CARB-compliant 

watercraft. And that an additional 20% will have CARB-compliant vessels. The National Park Service 

concurs that many watercraft users at Glen Canyon have California registered personal watercraft, and 

they will meet CARB standards. However, there is no data relative to personal watercraft at Glen Canyon 

to confirm the 75% figure assumed by the commenter. The NPS emissions calculations are conservative 

only in the sense that they do not specifically account for watercraft that have already been or will be 

converted to meet CARB standards. Under the modified preferred alternative (alternative B), personal 

watercraft engines at the recreation area would be 100% compliant after 2012. 

Public Comment: Commenter: Affiliation: 

1344I, 1344 J Personal Watercraft Industry 

Association 

Organization 

 

D Comment: The numbers used to predict loading on the lake for future years assume a zero growth 

condition. A zero growth assumption is not realistic for the boating industry or Glen Canyon National 

Recreation Area. Glen Canyon National Recreation Area has plans to continue to develop projects that 

support the boating industry. 

Response: New estimates for changes in boat uses at Glen Canyon have been generated for the Final 

Environmental Impact Statement based on trends for NPS units with personal watercraft usage. The 

effects of three differing growth scenarios are now described in the analysis: (1) annual increase of 2% per 

year, (2) no change (flat rate), and (3) annual decrease in use of 2% per year. For a complete explanation 

of the change in use, see the “Visitor Use and Experience” section in the “Affected Environment” chapter. 

Public Comment: Commenter: Affiliation: 

905A Personal Watercraft Industry 

Association 

Individual 

 

E Comment: The Draft Environmental Impact Statement claims that carbureted 2 cycle engines discharge 

“up to” 30% of their fuel/oil into the water (California Environmental Protection Agency, ARB, 1999). 

The analysis should note that the mean discharge is likely to be much less than the 30% figure. 

Response: The National Park Service reviewed a variety of literature prior to development of the water 

quality methodology. Thirty percent was commonly cited as a personal watercraft discharge rate for 
WATER QUALITY

94 

unburned fuel. This value was deemed reasonable and incorporated into the calculations for contaminant 

loading for the environmental analysis (NPS, G. Rosenlieb, pers. comm. 2003). 

Public Comment: Commenter: Affiliation: 

1239B 

845B 

Utah Shared Access Alliance Organization 

Individual 

 

F Comment: The water quality model should focus on the differential impacts on the side canyons from the 

uses anticipated under alternatives A and B. If data are available to measure this, the extent of personal 

watercraft use in the river channel arms should be compared to the lake main channel, and these data used 

to develop use rates and emissions loadings. 

Response: The water quality analysis was developed using the best available data. Flow rates and 

volumes in the canyons are also unavailable. Because of the variability in the elevation of the reservoir 

surface and changing seasonal flow from tributaries, the flow rates and volumes of the canyons are not 

known. Under all alternatives, the National Park Service would implement a lake-wide water quality 

monitoring program to direct future management efforts regarding water quality of Lake Powell. If water 

quality in the side canyons is affected by recreational boat use, appropriate management decisions would 

be made to reduce or limit these differential effects. If implemented, the modified preferred alternative 

(alternative B) in the Final Environmental Impact Statement would provide an important step toward 

substantially reducing petroleum-related pollution by restricting the use of carbureted two-stroke personal 

watercraft engines at the end of 2012. 

Public Comment: Commenter: Affiliation: 

1137B US Fish and Wildlife Service Public Agency 

 

Issue 4: Reference Other Water Quality Standards

A Comment: The model used to calculate allowable loadings (appendix F of the Draft Environmental 

Impact Statement) uses the most conservative water quality standards to calculate toxicity thresholds, with 

the exception of benzene. We recommend that the Utah water quality standard for Class 3B waters (warm 

water fisheries), 71 μg /L for benzene, be used in the model instead of the 130 μg/L ecotoxicological 

benchmark value (appendix F, table F.1). Because of the many assumptions of the model, there is a need 

to be conservative with each of these benchmarks. 

Response: Calculations for water volume thresholds needed to mitigate benzene have been adjusted to the 

71 μg/L warm water fishery standard for the state of Utah. The acre-feet required to meet this standard 

have, therefore, increased. The new results are shown in table 36. The threshold quantity of water for 

personal watercraft only benzene generation is 8,117 acre-feet, and for other two-stroke engines, the 

threshold is 4,054 acre-feet. Both quantities are well below the available mixing volume of Lake Powell. 

This change does not alter the finding of negligible to minor adverse effects on water quality. 

Public Comment: Commenter: Affiliation: 

1137B US Fish and Wildlife Service Public Agency 

 

B Comment: Fish in tributary areas could be significantly impacted personal watercraft usage in these side 

channels, and it is important that every effort is made to correctly estimate potential effects. 
Regulations, Methodologies, and Assumptions

95 

Response: Under the modified preferred alternative (alternative B) in the Final Environmental Impact 

Statement, water quality monitoring would include, when appropriate, testing of fish for the presence of 

PAH. If chronic or acute toxicity is found in any tested species, regulation of boat use or other PAH 

loading sources would be pursued. 

Public Comment: Commenter: Affiliation: 

1137B US Fish and Wildlife Service Public Agency 

 

Issue 5: The PAH Data Analysis is Inadequate

A Comment: More information is needed on the long -term impact of some pollutants. On page 16, the 

National Park Service states that it lacks studies on the long-term impacts of PAH on various biota. 

Response: The protection of water quality within Glen Canyon National Recreation Area has been 

addressed in this Final Environmental Impact Statement, which contains evaluations of surface water 

quality impacts. Using calculated water threshold volumes, water quality testing results, and 

characteristics of the contaminants identified, it is possible to identify unacceptable risks to human health 

or the environment. There are a limited number of EPA criteria for the protection of human health. 

Chronic ecotoxicological and human health benchmarks for contaminants were acquired from various 

sources. The evaluation presents the most restrictive thresholds, based on both federal and state water 

quality standards, for the pollutants. Table 10 shows the benchmarks used in the evaluation for each 

pollutant. 

Additionally, if implemented, the modified preferred alternative (alternative B) in the Final 

Environmental Impact Statement would provide an important step toward substantially reducing 

petroleum-related pollution by restricting the use of carbureted two-stroke personal watercraft engines t 

the end of 2012. Based on the analysis presented, the National Park Service finds that the modified 

preferred alternative (alternative B) (including the provision for continued personal watercraft use) would 

not result in an impairment of park water quality. 

Public Comment: Commenter: Affiliation: 

1002AC Bluewater Network Organization 

 

B Comment: On page 355, the National Park Service states that phototoxicity is not incorporated because if 

the site-specific water transparency of the lake is not known. This despite the fact that research at Lake 

Tahoe shows that PAH toxicity increases dramatically when exposed to sunlight. 

Response: Phototoxicity is an increase in toxic effects due to exposure to sunlight. The phototoxicity of 

PAH varies by compound, temperature of the water, available amount of ultraviolet light, and water 

column mixing. When these substances are exposed to sunlight, photodegradation (accelerated breakdown 

caused by sunlight) may occur in conjunction with biodegradation (NPS 1997). Therefore, the toxicity 

and degradation rates of each PAH compound is based on site-specific information. This level of detail is 

not currently known for the waters of Lake Powell, and presentation of such information would be 

speculative. For these reasons, potential increases in phototoxicity and/or photodegradation are not 

included in the analysis. 

Public Comment: Commenter: Affiliation: 

1002AC Bluewater Network Organization 

 

C Comment: The Draft Environmental Impact Statement acknowledges that hydrocarbon compounds 

evaporate rapidly from water and are subject to chemical breakdown, but then states that attenuating 

factors such as evaporation and photodegradation are not included in the calculations. In addition, EPA 

has confirmed that studies show most unburned gasoline and gasoline additives emitted from two-stroke 
WATER QUALITY

96 

marine engines evaporate rapidly from water (The Effects of Marine Engine Exhaust Emissions on Water 

Quality, Summary of Findings of Various Research Studies, EPA 1994). 

Response: In 1994, the Environmental Protection Agency released a public memorandum entitled “The 

Effects of Marine Engine Exhaust on Water Quality: Summary of Findings of Various Research Studies.” 

This document summarized 11 research papers and presents volatilization rates and dilution ratios for 

observable effects such as taste, odor, and generation of oil film. At temperatures commonly found in 

Lake Powell during the summer boating season, the majority of gasoline and oil components would be 

volatilized within 1.2 hours (EPA 1994). Although a portion of the gas/oil mixture may accumulate in the 

water column, water quality testing at Lake Powell did not reveal detectable levels of most PAH 

components. Given that the contaminants were largely undetectable, specific cumulative analysis of the 

personal watercraft contribution is not possible at this time. The text has been changed in the Final 

Environmental Impact Statement to include information on volatility consistent with the above-referenced 

EPA memorandum. 

Public Comment: Commenter: Affiliation: 

1344I Personal Watercraft Industry 

Association 

Organization 

 
97 

WILDLIFE AND WILDLIFE HABITAT

Affected Environment

Issue 1: Personal Watercraft Use and Human Activities Associated with Their Use May Not Be Any More 

Disturbing to Wildlife Species Than Any Other Type of Motorized or Nonmotorized Watercraft

A Comment: The National Park Service has recognized that personal watercraft cannot be singled out as a 

separate or distinct impact on wildlife. Since 1995, Dr. James Rodgers of the Florida Fish and Wildlife 

Conservation Commission has been conducting scientific studies of the effects of human disturbances on 

wildlife. Because this research is broad, and not just personal watercraft specific, Dr. Rodgers’ findings 

are particularly relevant to the NPS personal watercraft rulemakings in general, and specifically the 

proposed rule. His studies have shown that personal watercraft are no more likely to disturb wildlife than 

any other form of human interaction. Personal watercraft posed less of a disturbance than other vessel 

types. Dr. Rodgers’ research clearly shows that there is no reason to differentiate personal watercraft from 

motorized boating based on claims on wildlife disturbance. Moreover, some studies indicate that 

nonmotorized intrusions -- such as canoeists and kayakers -- can be more stressful and damaging than 

motorized activity, which provides greater advance warning to wildlife.” 

Response: The research findings of Dr. Rodgers, along with many other technical investigations of 

interactions between different wildlife species and human-induced noises, were reviewed and evaluated 

for applicability to personal watercraft use at the Glen Canyon National Recreation Area. As the 

commenter notes, the technical literature reports a range of wildlife reactions to personal watercraft and 

other watercraft uses. 

Public Comment: Commenter: Affiliation: 

1344O Personal Watercraft Industry 

Association 

Organization 

 
98 

Impacts from Other Vessels

Issue 1: Other Types of Motorized Watercraft Are Responsible for as Much or More Wildlife Habitat 

Damage as Personal Watercraft 

A Comment: “There are many two-stroke engines on other types of boats. that pollute as much as the 

personal watercraft, are far louder than personal watercraft and cause far more damage to the wildlife 

habitat with near-shore vegetation and shore erosion.” 

Response: The assessment of potential effects to wildlife populations and habitats considered two 

perspectives. First, an estimate was made of the effects of personal watercraft to wildlife populations and 

habitats for the specific conditions that prevail at the national recreation area under each alternative 

condition. Then, the effects of personal watercraft use in conjunction with all other types of two-stroke 

and other motorized watercraft were evaluated as part of the cumulative effects analysis. The incremental 

and collective effects of these other watercraft were accounted for in the analysis. 

The plan was not designed to determine if personal watercraft caused more environmental damage to park 

resources than other boats, but rather, to determine if personal watercraft use was consistent with Glen 

Canyon National Recreation Area’s enabling legislation and management goals and objectives. The 

overall objective is to meet the terms of the settlement agreement between Bluewater Network and the 

National Park Service (see “Introduction” in the “Purpose of and Need for Action” chapter). An analysis 

was done on the management of personal watercraft in order to meet the terms of the settlement 

agreement. With completion of this Final Environmental Impact Statement, the National Park Service 

may either take action to adopt special regulations to manage personal watercraft use at Glen Canyon, or 

may choose to discontinue personal watercraft use. 

Public Comment: Commenter: Affiliation: 

211A Individual 

 
99 

Impacts of Personal Watercraft Use

Issue 1: Tour Boat Uses Cause Greater Effects to Wildlife and Wildlife Habitat Than Personal Watercraft

A Comment: Personal watercraft do not present a danger to wildlife or its habitat or to the shoreline. While 

parts of the shoreline are degraded, this is primarily due to the Tour boats and outboard motors. 

Response: The impact analysis of personal watercraft effects to wildlife and wildlife habitat considered 

the effects of other types of watercraft that use Lake Powell and the national recreation area. In particular, 

a primary focus of the cumulative effects analysis was to account for other types of motorized watercraft 

that could cause effects similar to and more or less severe in magnitude to personal watercraft. The 

individual alternatives analysis also accounted for wildlife and wildlife habitat effects that are related to or 

caused by the substantial environmental changes that result from typical operations of the reservoir for 

other beneficial uses. 

Public Comment: Commenter: Affiliation: 

576A Individual 

 

Issue 2: The Draft Environmental Impact Statement Should Acknowledge Research Findings That Detected 

Levels of Some PAH Compounds in Lake Powell Fish Tissue Samples

A Comment: Polynuclear aromatic hydrocarbons (PAH) are primary contaminants of concern for aquatic 

ecosystems exposed to hydrocarbon emissions. Because of the level of motor vehicle use on Lake Powell, 

and the possible presence of other PAH sources on the San Juan River arm, the National Park Service and 

FWS cooperated on a preliminary study of PAH uptake in fish in the main channel, marinas, and San Juan 

arm. This study, conducted between 1991 and 1994, evaluated PAH concentrations detected in bile from 

fish collected at these three locations on the lake. Initial sample results had been available to the National 

Park Service. The reasons for including the data are twofold. First, PAH metabolites in bile are a reliable 

and sensitive indicator of recent exposure to these constituents in the foodchain. Assuming that the origin 

of the PAH can be traced to the use of combustion engines in the environment in question, PAH exposure 

in fish can then be linked to the use of these engines. Secondly, this data can serve as a baseline for future 

monitoring that should be conducted as part of the resource management plan adopted for Lake Powell 

following the choice of alternatives under the environmental impact statement. 

 With proper study design, we believe that monitoring for this endpoint can provide a cost-effective, direct 

way of evaluating exposure and potential adverse impacts on aquatic wildlife species and other trust 

resources within the Lake Powell ecosystem 

Response: The discussion of potential effects of PAH compounds has been changed in the Final 

Environmental Impact Statement to acknowledge the findings of the referenced U.S. Fish and Wildlife 

Service monitoring investigation (see the “Wildlife and Wildlife Habitat” section of the “Environmental 

Consequences” chapter). The study was conducted between 1991 and 1994 in which fish bile was tested 

for concentrations of polycyclic aromatic hydrocarbons (PAH). Polycyclic hydrocarbons can be taken up 

from the environment through ingestion and/or absorption and are linked to adverse health effects such as 

liver and skin lesions and tumors. The fish used in the study were collected from the main channel, 

marinas, and the San Juan River arm of the recreation area. Polycyclic hydrocarbons were detected in the 

bile of fish at concentrations consistent with values indicating exposure to sediments that are considered 

to be low to moderately contaminated. However, no indication of adverse health effects, lesions or 

tumors, were found in any of the fish collected (U.S. Fish and Wildlife Service 2002). 

Public Comment: Commenter: Affiliation: 

1137C US Fish and Wildlife Service Public Agency 

 
WILDLIFE AND WILDLIFE HABITAT

100 

Issue 3: Predicted Impacts of Personal Watercraft Use to Wildlife And Wildlife Habitats Described in the 

Draft Environmental Impact Statement Does Not Justify Restricting Personal Watercraft Use

A Comment: “Concerning wildlife and wildlife habitat, the Draft Environmental Impact Statement states on 

page 17: “Few studies have examined personal watercraft effects on wildlife”. And: “However, the extent, 

duration, and magnitude of biological impacts because of personal watercraft operations versus other 

motorboats remain unknown”. On page 120: “Under current condition there are no documented reports of 

known conflicts of federally endangered fish or other species with watercraft or personal watercraft 

users.” On page 232: “Conclusion. alternative A would not adversely affect any ecological, biological, or 

physical processes associated with endangered fish critical habitats.” So, restricting personal watercraft 

use relating to the issue of wildlife and wildlife habitat is unjustified. 

Response: Potential personal watercraft effects to wildlife and wildlife habitat conditions that prevail at 

the recreation area were estimated using the best available information and technical research findings. 

The estimated effects to wildlife and wildlife habitat were considered together with the impact predictions 

for other natural, visitor use, socioeconomic, and cultural resources in arriving at a decision on how to 

best manage future personal watercraft use in the recreation area. 

Public Comment: Commenter: Affiliation: 

1184C Individual 

 

Issue 4: Boats Powered by Outboard Motors Created Greater Effects on Wildlife Than Personal Watercraft in 

Comparison Tests

A Comment: The Florida FWCC have conducted extensive studies on wildlife impacts and found that the 

outboard motors on boats used by the testers created more wildlife reactions at farther distances than the 

personal watercraft in the tests. 

Response: The assessment of potential effects of personal watercraft to birds and other types of wildlife 

for the different use alternatives considered the circumstances and findings of the referenced Florida Fish 

and Wildlife Conservation Commission investigations. Some of the findings from these studies were used 

to the extent they were considered applicable to Glen Canyon National Recreation Area wildlife and other 

environmental conditions. See the “Wildlife and Wildlife Habitat” section in the “Environmental 

Consequences” chapter of the Final Environmental Impact Statement. 

Public Comment: Commenter: Affiliation: 

151C Individual 

 

Issue 5: Wildlife Abundance Would Increase With Elimination of Personal Watercraft Noise and Human 

Disturbance

A Comment: The environment will benefit from the ban of personal watercraft by a decrease in the amount 

of toxic compounds released into the aquatic ecosystem and a reduction in noise pollution. 

Response: Determining the effect of noise on wildlife is a complicated and uncertain process because 

responses vary between species and between individuals of a single population. These variable responses 

are due to the characteristics of the noise and its duration, the life history characteristics of the species, 

habitat type, season, activity at the time of exposure, sex and age of the individual, level of previous 

exposure, and whether other physical stresses such as drought are occurring around the time of exposure 

(Busnel 1978). 

These complications apply equally to situations that may be presumed to either benefit or adversely affect 

wildlife species of interest. Several studies have discussed the very difficult (if not impossible) task of 
Impacts of Personal Watercraft Use

101 

separating noise effects from other environmental factors influencing the behavior and physiology of an 

animal. 

The National Park Service is well aware of the body of scientific literature and studies that have attempted 

to define noise effects on wildlife, and it has strived to provide a balanced description of the factors and 

conditions that may affect wildlife reactions and welfare under different noise conditions. See responses 

to comments in the “Soundscape” section of this volume 2 for further information of the impacts of 

personal watercraft-generated noise. 

Public Comment: Commenter: Affiliation: 

668D Individual 

 

Issue 6: Characterization of Impact Duration Should be Changed

A Comment: The commenter disagrees with the conclusion stated in the summary table of impacts that 

beneficial effects to wildlife would decrease with time as other motorized watercraft replaced personal 

watercraft. 

Response: The Final Environmental Impact Statement states that following a ban on personal watercraft 

use, conditions would return to pre-ban levels by 2012 due to either growth in natural visitation or 

increases in visitation by individuals who would now choose to visit the recreation area but avoided the 

recreation area because of personal watercraft disturbance. This would result in the referenced impact 

conclusion. 

Public Comment: Commenter: Affiliation: 

1180L Individual 

 

Issue 7: The Draft Environmental Impact Statement Does Not Adequately Disclose the Potential Effects of 

Personal Watercraft Use on Selected Bird and Mammal Species

A Comment: The Draft Environmental Impact Statement assessment of personal watercraft impacts on 

wildlife is incomplete and flawed. The Draft Environmental Impact Statement does not adequately assess 

the adverse effects personal watercraft use has, or may have, on Peregrine Falcons, Great Horned Owls, 

Bald Eagles, Golden Eagles and Western Yellow-Billed Cuckoos. Studies have shown that personal 

watercraft use adversely impacts a wide variety of bird species including osprey, the Common Loon, 

Common Tern, Brown Pelican and Trumpeter Swan. 

 The Draft Environmental Impact Statement also does not adequately assess the adverse effects of personal 

watercraft use has, or may have, on Desert Bighorn Sheep or on river otters. National Park Service should 

not automatically assume that personal watercraft impacts are negligible or acceptable to nesting birds and 

breeding mammals. Implementing a 1,000-foot shoreline buffer from high-speed personal watercraft 

operation would provide much better protection to wildlife from personal watercraft impacts. 

Response: The Final Environmental Impact Statement (see “Wildlife and Wildlife Habitat” section in the 

“Environmental Consequences” chapter) acknowledge that personal watercraft use can affect individual 

animals. The significance of such effects is certainly open to many differences of opinion. There are 

technical literature research reports that have identified adverse effects from personal watercraft 

operations to individuals of some species under certain circumstances. Other studies point to the lack of 

adverse effects under other circumstances. 

For the Draft and Final Environmental Impact Statements, the National Park Service reviewed these 

technical investigations and applied the findings within the physical, recreational, and ecological 

conditions that prevail at Glen Canyon National Recreation Area. Each of the species identified by the 
WILDLIFE AND WILDLIFE HABITAT

102 

commenter was considered for potential effects and interpretations regarding the significance of these 

effects were made. 

Special impact assessment attention was focused on aspects of species life history periods (such as raptor 

nesting times) and habitat use or special requirements areas that are considered by wildlife professionals 

as being particularly vulnerable to personal watercraft uses. The initial results of these assessments were 

then reviewed by park natural resource specialists with knowledge of specific park conditions to confirm 

the reasonableness of the assessment findings. 

For many of the cited species, reasons for concern were not appropriate for the Lake Powell environment 

because the types of species reported by the literature as being affected by personal watercraft use or the 

habitat conditions reported as being adversely affected (such as a shoreline nesting colony of plovers or 

terns) did not exist in the national recreation area. Conclusions regarding wildlife impacts were based on 

this process and are believed to be accurate and complete. 

In addition, the modified preferred alternative (alternative B) provides for further protection of wildlife in 

the recreation area. Phasing in of new personal watercraft technology under the modified preferred 

alternative (alternative B) would reduce impacts on aquatic and shoreline species by reducing the 

discharge of fuel components into the water. A lake management plan will provide the tools necessary to 

analyze activities that take place on the lake and determine if unacceptable impacts are occurring using 

information gained from a three-year pilot program. Enhanced education programs would instruct 

personal watercraft users on ways to avoid adversely affecting recreation area resources, including 

wildlife. 

Public Comment: Commenter: Affiliation: 

1168G American Canoe Association Organization 

 

Issue 8: Use of New Personal Watercraft Engine Technology Will Not Reduce Adverse Impacts on Wildlife

A Comment: Scientists and researchers are finding that personal watercraft, even with the prototype 

technology, still cause significant damage to the environment and wildlife. Researchers from the 

University of Reno, Miami University and Michigan State University have found that personal watercraft 

engines produce pollutants such as PAH which are toxic to plants and animals even at the minute levels of 

parts per trillion. The prototype technology is unlikely to improve the craft’s horrific safety record or 

reduce its impact upon wildlife. 

Response: It is anticipated that more combustion-efficient engines in personal watercraft would reduce 

pollutant emissions to air and water in the same manner as increased efficiencies in automobile engines, 

combined with catalytic converters and other technologies, decreased the amount and types of automobile 

exhaust emissions. EPA-sponsored evaluations of different personal watercraft engine designs and 

emissions concluded that emission reductions would result with implementation of the EPA 2006 

emission standards for marine engines. The modified preferred alternative (alternative B) provides for 

further protection of wildlife in the recreation area. Phasing in of new personal watercraft technology 

under the modified preferred alternative (alternative B) would reduce impacts on aquatic and shoreline 

species by reducing the discharge of fuel components into the water. These reductions should indirectly 

benefit wildlife by reducing some of the contaminant loading of surface waters. 
Impacts of Personal Watercraft Use

103 

PAH toxicity to fish and wildlife species is a complicated topic because PAH consist of dozens of 

different chemical compounds, each of which has substantially different toxicity characteristics in water, 

sediment, and soils, and toxicity varies dramatically among different fish and wildlife species. The 

ecotoxicological analysis for PAH reported in the Final Environmental Impact Statement explains the 

chemical, physical, and biological conditions that were used to conduct the assessment of PAH effects to 

fish species. 

Public Comment: Commenter: Affiliation: 

1127B Individual 

 

Issue 9: Personal Watercraft Disproportionately Impact Wildlife

A Comment: Wildlife studies indicate that personal watercraft disproportionately impact wildlife, such as 

birds and marine mammals. 

Response: The wildlife impact analysis completed for the Glen Canyon National Recreation Area 

considered a large body of technical information that addressed observed and tested effects of personal 

watercraft and other motorized watercraft use on various fish and wildlife species and to wildlife in 

general. Some of the available literature discussed effects to some wildlife species and not to other 

groups. Some of the available literature noted that personal watercraft use was less or no more disruptive 

than other types of motorized or muscle-powered watercraft. A common theme in many of the research 

findings was that much of the wildlife effect depended on a complex of other environmental variables 

than just the type of watercraft. The National Park Service considered all these findings in conducting an 

objective and balanced impact analysis. The literature results were used as appropriate within the physical 

and ecological conditions that prevail at the national recreation area. 

For example, disturbances and impacts reported for marine mammals were not used in the analysis 

because the national recreation area is a freshwater lake, not a coastal marine or estuarine environment. 

Potential impacts and conflicts of personal watercraft with ground-nesting bird colonies were considered 

as a potential effect early in the planning process, investigated and determined to be not applicable 

because there are no known nesting colonies of shorebirds or other bird species present at Lake Powell 

that might be susceptible to personal watercraft operations in shallow-water areas or along shorelines. 

Lake Powell does not support either a salmon fishery or migrating humpback whales, so these types of 

potential impacts were considered not applicable for the Lake Powell environmental setting. 

Public Comment: Commenter: Affiliation: 

1002H, 1002J Bluewater Network Organization 

 

Issue 10: Personal Watercraft Use Disturbs Wildlife Activity in the Immediate Vicinity of Lake Powell 

A Comment: Personal watercraft disturb wildlife such as shorebirds and bighorn sheep within the vicinity of 

Lake Powell. 

Response: The Draft and Final Environmental Impact Statements considered, analyzed, and reported on 

the potential effects of personal watercraft operation to desert bighorn sheep (see the “Wildlife and 

Wildlife Habitat” section in the “Environmental Consequences” chapter). That analysis concluded that 

desert bighorn sheep occur sporadically near the lake’s water interface during the winter months, because 

the lake is considered the lower limits of their historical winter range. The winter months are typically the 

lowest-use months of the year. The frequency and intensity of personal watercraft / bighorn sheep 

interactions were considered by the National Park Service wildlife biologist as quite low. The bighorn 

sheep also tended to be observed in close proximity to human dwellings, which suggested a level of 

tolerance of human activities. All these circumstances and reports were considered in the impact analysis. 
WILDLIFE AND WILDLIFE HABITAT

104 

In addition, the modified preferred alternative (alternative B) provides for further protection of wildlife in 

the recreation area. Phasing in of new personal watercraft technology under the modified preferred 

alternative (alternative B) would reduce impacts on aquatic and shoreline species by reducing the 

discharge of fuel components into the water. A lake management plan will provide the tools necessary to 

analyze activities that take place on the lake and determine if unacceptable impacts are occurring using 

information gained from a three-year pilot program. Enhanced education programs would instruct 

personal watercraft users on ways to avoid adversely affecting recreation area resources, including 

wildlife. 

Public Comment: Commenter: Affiliation: 

139A Individual 

 
Index of Comment Letters by Category of Author 

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Public Agency Comment Letters 
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Form Letters 
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