CREDA 

Colorado River Energy Distributors Association 

March 24, 2024 

ARIZONA 

Arizona Municipal Power Users Association 

Arizona Power Authority 

Arizona Power Pooling Association 

Irrigation and Electrical Districts 

Association 

Navajo Tribal Utility Authority 

(also New Mexico, Utah) 

Salt River Project 

COLORADO 

Colorado Springs Utilities 

CORE Cooperative 

Holy Cross Energy 

Platte River Power Authority 

Tri-State Generation & Transmission 

Association, Inc. 

(also Nebraska, Wyoming, New Mexico) 

Yampa Valley Electric 

Association, Inc. 

NEBRASKA 

Municipal Energy Agency of Nebraska 

(also Colorado) 

NEVADA 

Colorado River Commission 

of Nevada 

Silver State Energy Association 

NEW MEXICO 

Farmington Electric Utility System 

Los Alamos County 

UTAH 

City of Provo 

City of St. George 

South Utah Valley Electric Service District 

Utah Associated Municipal Power Systems 

Utah Municipal Power Agency 

WYOMING 

Wyoming Municipal Power Agency 

Leslie James 

Executive Director 

CREDA 

10429 S. 51st St., Suite 230 

Phoenix, Arizona 85044 

Phone: 480-477-8646 

Fax: 480-477-8647 

Cellular: 602-469-4046 

Email: creda@creda.cc 

Website: www.credanet.org 

Bureau of Reclamation 

Attn: LTEMP SEIS Project Manager 

125 South State Street, Suite 800 

Salt Lake City, UT 84138 

Via Email only – LTEMPSEIS@usbr.gov 

RE: GLEN CANYON DAM LONG-TERM EXPERIMENTAL AND MANAGEMENT PLAN 

(LTEMP) DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT (DSEIS) – 89 

FR 28, February 9, 2024 

The Colorado River Energy Distributors Association (CREDA) appreciates the 

opportunity to provide comments on the DSEIS, issued February 9, 2024. 

CREDA and CREDA Member Interests 

As a member of the Glen Canyon Dam (GCD) Adaptive Management Work 

Group (AMWG) and Adaptive Management Program (AMP), CREDA is one of the 

representatives of contractors who purchase federal hydropower and resources 

from the GCD, a primary feature of the Colorado River Storage Project (CRSP). 

CREDA is also a longstanding participant in the Upper Colorado River Endangered 

Fish Recovery Program. CREDA members serve over 4.1 million consumers in the 

states of Arizona, Colorado, Nebraska, Nevada, New Mexico, Utah, and Wyoming, 

and represents the majority of the firm electric service (FES) customers of the CRSP. 

As such, CREDA and its members have a unique interest and role in issues 

associated with Colorado River and CRSP operations, specifically GCD operations. 

CREDA members are all non-profit entities, composed of municipalities, rural 

electric cooperatives, irrigation and electrical districts, state agencies, political 

subdivisions and tribal utilities and communities. Each CREDA member is an FES 

customer with a long-term firm electric service contract with the Western Area 

Power Administration (WAPA or Western) for the purchase of CRSP resources. 

These resources are used by CREDA member utilities to meet their obligation to 

serve the electrical needs of their customers. Electric service is not discretionary or 

a convenience. This service is essential to health and human safety. 

CREDA has participated in all NEPA processes associated with the LTEMP and 

this DSEIS, and specifically incorporates by reference comment letters dated May 9, 

2016, November 14, 2016, March 10, 2023 and November 3, 2023 (attached). 

THE DSEIS IS LEGALLY INADEQUATE TO ALLOW THE DECISION MAKER AND THE 

PUBLIC TO UNDERSTAND WHAT IS PROPOSED AND WHAT THE FULL 

ENVIRONMENTAL EFFECTS OF THE PROPOSED ACTION AND ANALYZED 

ALTERNATIVES ARE EXPECTED TO BE. THE DSEIS SHOULD BE REVISED TO INCLUDE 

A HARD LOOK AT ALL NECESSARY INFORMATION AND ANALYSES AND REISSUED 

FOR PUBLIC COMMENT PRIOR TO ISSUANCE OF A FINAL SEIS, RECORD OF 

DECISION, OR IMPLEMENTATION OF ANY EXPERIMENTS. 
 

 

 

 

 

 

 

 

 

This statement and request are supported by the following discussion. The following are selected 

DSEIS section discussions. Following these discussions are specific comments on the DSEIS, referenced by 

page number. 

PURPOSE OF AND NEED FOR ACTION 

The Purpose and Need Statement in the DSEIS has been revised from what was included in 

Reclamation’s 2023 Environmental Assessment,

1 indicating what appears to be a change from a “prevention”

standard to a “disruption” standard in the overall need for the Proposed Action. DSEIS at 1-6. However, the 

Proposed Action also is described as a measure needed to “ensure the prevention of population 

establishment” of smallmouth bass and other warmwater nonnative invasive fish species (SMB). DSEIS at 1-5. 

Is it Reclamation’s desire to prevent establishment of invasive species or to disrupt establishment? How is 

disrupt defined, and how would the experiment’s results be judged a success or a failure?

The DSEIS acknowledges that Reclamation and the AMP are aware of non-flow “mid-term” actions 

which can and should be implemented in addition to flow-only actions. The Purpose and Need Statement’s 

focus on “flow options” is too narrow to achieve an objective to “limit recruitment.” Given the ongoing 

willingness of the National Park Service to consider -12 mile slough modifications and other non-native fish 

control actions in the near future, particularly since the slough is “the more heavily populated area[]”, 

consider broadening the Purpose and Need Statement to address an objective to prevent and 

management establishment of the smallmouth bass, and to incorporate any requisite compliance for such 

actions into a redrafted Purpose and Need Statement and DSEIS. CREDA’s March 10, 2023 comments 

noted that the Upper Basin State Technical Work Group representatives have stated that operational 

alternatives are not a panacea; fish exclusion should be an immediate priority. These statements appear to 

support a more comprehensive Purpose and Need Statement and Proposed Action, which would address a 

comprehensive adaptive approach to both the prevention of establishment and management of (established) 

populations of SMB. 

DESCRIPTION OF ALTERNATIVES 

The range of alternatives included in the DSEIS is impermissibly narrow. As stated in Reclamation’s 

Notice of Intent,

2 “Flow actions alone are insufficient to “prevent the establishment of smallmouth bass 

below the Glen Canyon Dam.” As rapidly as the system has been changing during the current extreme 

drought, the question of whether the SMB are already established (or not) below Glen Canyon Dam is 

secondary to the need to address the issue in a comprehensive manner, as outlined in the Strategic Plan 

(Plan). This Plan, as well as the most current available monitoring and independent science panel-informed 

information, should be considered as the best available science and should be incorporated into a broad 

range of alternatives most likely to address establishment and management of the invasive fish species 

addressed in the DSEIS. Proposed alternatives should not be limited to flow-only treatments, should include 

structural elements, and should be revised to include at a minimum all actions included in Table 1 of the 

Invasive Species Strategic Plan.

3 

With respect to any experiment undertaken under this DSEIS, in order to fully inform the analysis of 

its direct, indirect, and cumulative effects, an experiment must include a description of the proposed 

experiment, the time or frequency of implementation of the experiment, and the triggers or other conditions 

that must exist prior to implementation of the experiment. Each experiment must also include a description 

of the hypotheses that will be tested by the experiment and benchmarks or other identifiable criteria that will 

1 Glen Canyon Dam/Smallmouth Bass Flow Options Draft Environmental Assessment (EA), February 24, 2023, p. 1-5. 2 88 Fed. Reg. 68667, 68668 (Oct. 4, 2023). 3 “Fisheries Actions Within Current Compliance”, Plan approved by AMWG February 2023. 

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allow the Secretary and interested parties to assess the experiments’ success or lack thereof, and when an 

experiment or action must be terminated because of unacceptable impacts (as specifically defined) to the 

threatened humpback chub, other legally protected resources, or the electrical grid. The experiments also 

fail to describe any monitoring included in an implementation plan or experimental design, which is 

necessary to implement adaptive management as a part of the LTEMP. See “Adaptive Management – The US 

Department of the Interior Technical Guide.”4 The Description of Alternatives (Chapter 2) should be revised 

to include these elements. 

AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES/ENERGY AND POWER 

The Notice of Intent (88 Fed. Reg. 68667, 68668) issued November 4, 2023, states that the SEIS will 

be further informed and built upon by “relevant analyses” and information from the 2016 LTEMP Final EIS. 

Notwithstanding significant electric grid, environmental, and drought-related changed conditions since the 

2016 Record of Decision (ROD), and focusing in large part on Section 3.3 of the DSEIS, the DSEIS fails to 

adequately and fully analyze “Power and Energy” and the affected environment: 

• The DSEIS focuses on “economic value” as an impact indicator, along with energy 

(GWh) impacts. Based on information and discussion presented at the January 23-24, 2024, 

GCDAMP Annual Reporting meeting, it is CREDA’s understanding that the model used to develop this 

analysis has been neither peer-reviewed nor published. Further, the description of “economic value”

is inconsistent with the LTEMP analysis that this DSEIS is supplementing. LTEMP and its Appendix K 

provide analysis that is “measured in terms of changes in the value of regional power system capacity 

(the power system comprised of Western’s long-term firm (LTF) customers) and overall system-level 

electricity production costs (the entire Western Interconnection). The second analysis (presented in 

Section K.2) studied how system resources and operations under LTEMP alternatives affect the 

wholesale electricity rates paid by utility entities that receive federal preference power produced by 

Glen Canyon Dam. The third analysis (presented in Section K.3) studied the effects of alternatives on 

electricity rates paid by retail customers.”5 Section 3.3 of the DSEIS should be revised to include 

analysis undertaken by WAPA, using its GTMax and other models, consistent with the analysis and 

impacts described in the LTEMP. 

• The impact of experiments on replacement power and transmission availability 

and grid reliability during the summer months of the experiment must be assessed in the DSEIS 

analysis. Significant changes in the Western Interconnection from both a resource mix and 

hydrologic condition have occurred since the LTEMP ROD was issued that require assessment in the 

SEIS. See the NERC Summer Reliability Assessment 2022 at pp.5-6: “Drought conditions create 

heightened reliability risk for the summer. Drought exists or threatens wide areas of North America, 

resulting in unique challenges to area electricity supplies and potential impacts on demand: Energy 

output from hydro generators throughout most of the Western United States is being affected by 

widespread drought and below-normal snowpack. Dry hydrological conditions threaten the 

availability of hydroelectricity for transfers throughout the Western Interconnection. Some 

assessment areas, including WECC’s California-Mexico (CA/MX) and Southwest Reserve Sharing 

Group (SRSG), depend on substantial electricity imports to meet demand on hot summer evenings 

and other times when variable energy resource (e.g., wind, solar) output is diminishing.” In light of 

these challenging conditions, the DSEIS’s effects analysis must include analysis of the impacts on 

replacement power and transmission availability and grid reliability. 

• Impacts to CRSP customers in their capacity as electric service providers who have 

an obligation to provide reliable electricity to retail customers must be added to the DSEIS’s effects

analysis. These impacts are distinct from impacts to WAPA and the Upper Colorado River Basin 

4 See: (https://www.doi.gov/sites/doi.gov/files/migrated/ppa/upload/TechGuide.pdf) Williams, B. K., R. C. Szaro, and C. D. Shapiro. 2009. Adaptive Management: 

The U.S. Department of the Interior Technical Guide. Adaptive Management Working Group, U.S. Department of the Interior, Washington, DC. See also United 

States Department of the Interior Environmental Statement Memorandum No. ESM 13-11, January 7, 2013 (ESM13-11.pdf (doi.gov)). 5 LTEMP FEIS, Appendix K, DOI 2016a, K-4. 

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Fund, although those impacts also potentially affect CRSP customers. Depending on the nature of 

the Alternative or elements thereof, whether the action is a management action or an experiment, 

resource adequacy and availability of replacement power and transmission could result in financial 

or economic impacts that must be disclosed and avoided or, if unavoidable, mitigated. The analysis 

should include the impact on those customers that count their CRSP generation toward meeting their 

resource adequacy requirements, as well as include their CRSP generation in their greenhouse gas 

and Renewable Energy Certificates (RECs) reporting. Reduced and/or bypassed generation at Glen 

Canyon Dam/CRSP has implications and impacts to both direct contracts of those resources, as well 

as exchange agreements that rely on the output of CRSP resources. 

• Impacts to underserved and disadvantaged rural and tribal communities should be 

updated. Nearly half of Colorado River Storage Project (CRSP) power customers (including CREDA 

members) are electric service providers for areas that could be classified as disadvantaged 

communities. The DSEIS recognizes this fact in Sections 3.15 and 3.16, but the analysis should be 

expanded to include specific impacts to these environmental justice communities. 

• Financial impacts to the Upper Colorado River Basin Fund (Basin Fund) and the 

programs it funds are not assessed or disclosed. Hydropower operations are not the cause of SMB 

incursion and should not be relied on to bear the costs of mitigation. In the event WAPA must 

purchase power to replace resources that are unavailable or lost due to bypass operations for nonnative fish control or HFEs, these costs are non-reimbursable6 and should not be borne by WAPA or 

WAPA’s hydropower customers. The Basin Fund is the primary funding source for Reclamation’s and 

WAPA’s CRSP operations. In addition to funding operation and maintenance expenses of CRSP

generation and transmission infrastructure, the Basin Fund repays the federal CRSP investment (with 

interest), provides irrigation assistance, provides funding to the Upper Basin States’ Memorandum of 

Agreement projects, and supports the Colorado River Salinity Control Program. In the event federal 

non-reimbursable funding is not provided for implementation of this SEIS, the Basin Fund may be 

insufficient to continuing funding the above listed programs, including the operation and 

maintenance of Glen Canyon Dam infrastructure, and the federal government may be unable to fulfill 

its contractual obligations to the Salt Lake City Area/Integrated Projects (SLCA/IP) firm electric service 

customers. Analysis of the Basin Fund impacts should be developed in cooperation with WAPA and 

must be included in the DSEIS. 

• Rate and contractual impacts are not assessed or disclosed. The DSEIS recognizes 

this omission,7 but also notes that “a Cost Recovery Charge (CRC) cannot be implemented to cover 

non-reimbursable purchase power expenses.”8 Since issuance of the LTEMP ROD, significant SLCA/IP 

rate design changes have been implemented, which, coupled with the potentially significant 

hydropower, financial and operational impacts posed by the Proposed Action, requires that SLCA/IP 

firm electric service rate and contract impacts be developed by WAPA and included in the DSEIS. 

AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES/NON-NATIVE FISH/SMALLMOUTH BASS 

Key information in the DSEIS about SMB begins at page 3-66. The fundamental premise behind the 

proposed action is smallmouth bass data and models. Unfortunately, as the DSEIS itself states: “(s)pecific 

data on these fish have been collected but are not available or citable at this time.” DSEIS at 3-68. Given the 

relationship and hypotheses related to smallmouth bass, humpback chub and temperature, it is imperative 

that the data and tools employed to analyze impacts and make decisions be linked and the results disclosed 

in the DSEIS. Public technical review of the preliminary model and its assumptions is necessary prior to 

issuance of a final SEIS. “A detailed evaluation of model uncertainties, such as how available habitat changes 

under different alternatives, the influence of turbidity, prey resources, and the entrainment rate of 

smallmouth bass would help to characterize uncertainty of the model.” DSEIS at 3-97 (emphasis added). 

6 Grand Canyon Protection Act, PL. 102-575, Sec. 1807. 7 DSEIS, page 3-34 “Rate Impacts.” 8 DSEIS, pages 3-19, 3-223. 

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“These modeling efforts for the Colorado River ecosystem below Glen Canyon Dam are not completed; thus, 

they are not included in this evaluation.” DSEIS at 3-135. CREDA understands that an independent science 

panel has been engaged by WAPA and Reclamation as part of the SEIS process. Has the panel been tasked 

with reviewing the preliminary model work by Eppehimer and Yackulic (DSEIS at 3-97 and Appendix A)? 

CREDA strongly supports that course and reiterates its request on the February 22, 2024 public webinar that 

information produced by the panel be made available to the public and be included in in this section 

(through and including p. 3-97) and reissued for public comment prior to the issuance of a Final EIS or 

ROD. 

DETAILED COMMENTS 

CREDA offers specific comments on the DSEIS on a section-by-section basis, referenced to page 

numbers in the DSEIS. 

1) 1-5: Consider including in reference that in 2015, green sunfish were present in the upper 

slough, hence one of the considerations in the decision being made to not implement an HFE in 

that year. That year distinguishes itself from other HFE years in that the presence of a non-native 

species and lack of control thereof was important enough to not implement an HFE. 

2) 1-7/1-8: Regarding the Scope: Please ensure that the analysis includes an evaluation of whether 

the alternatives are expected to prevent spawning and/or establishment in the whole of the 

project area, not just down to 15 mile or the LCR. Ensure that the risk assessment and impacts 

analysis undertaken in the DSEIS, and any decision-making process, include the contribution of 

the western Grand Canyon humpback chub population (estimated at between 66,0009 and 

97,00010), since this population was considered and factored into the recent trigger review of this 

species.11 

3) 1-7: To be consistent with other agency authorities and obligations, consider clarifying WAPA’s 

description to the CRSP region of WAPA’s marketing of “cost-based hydropower from federal 

multiple purpose projects” as opposed to the entire 15-state region comprising all WAPA’s

marketing areas. 

4) 1-8: Given Reclamation’s recent 24-month study results and forecasts suggesting that DSEIS 

temperature triggers may not occur, if at all, until late summer or early fall, Reclamation should 

re-evaluate its Timing Considerations and project timeline, and reissue a public DSEIS following 

revision of section 3.3 as described above. Reissuance of a more complete DSEIS should result in 

a more complete disclosure and analysis of effects, including cumulative effects, as opposed to 

“the information used in this analysis,” which merely allows a limited “comparison among the 

alternatives.”

5) 1-9: Section 1.8 also should be revised to clearly state that any action taken under the SEIS to 

address SMB/non-native issues must be done in a manner consistent with the Colorado River 

Storage Project Act12 and other applicable provisions of federal law. The description of LTEMP 

releases in this section should be reviewed. Hourly, daily, and monthly are the appropriate 

descriptors given to LTEMP operational parameters. This section has added “experimental 

timescales”, which requires more explanation, and confusingly states in the last paragraph that 

“LTEMP instead controls the timing of annual releases....”

6) 1-10: Revise Table 1-1’s “Energy and Hydropower” component description when section 3.3 

Energy and Power has been revised. 

7) 2-2: Operational flexibility, as defined in LTEMP ROD page B-7, section 1.2 should be included as 

an Assumptions Common to All Action Alternatives: “Reclamation also will make specific 

adjustments to daily and monthly release volumes, in consultation with other entities as 

appropriate, for a number of reasons, including operational, resource-related, and hydropower9 Reclamation Public Webinar, February 22, 2024. 10 GCDAMP Annual Reporting Meeting, January 23-24, 2024. 11 Five Year Review of Action Triggers for Management of Humpback Chub, BOR to USFWS, December 17, 2021. 12 43 U.S.C. 620 et seq. 

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related issues. Examples of these adjustments may include, but are not limited to, the following: 

... For hydropower-related issues, adjustments may occur to address issues such as electrical grid 

reliability, actual or forecasted prices for purchased power, transmission outages, and 

experimental releases from other Colorado River Storage Project dams.” In addition, specific 

reference to the Operating Criteria should be included.13 

8) 2-4: The last bullet in the Assumptions Common to All Action Alternatives should be removed 

and replaced with a description of the GTMax, PLEXOS and other models utilized by WAPA. 

9) 2-5: During development of the proposed accounting window changes to the HFE protocol, 

CREDA did not support scenarios or alternatives that include carrying over sediment from one 

year to the next year. It is unclear from the description of the third bullet whether this was 

intended in the “General high flow implementation modeling details.” On page 2-6 (final 

paragraph of 4th bullet), revise the description to be clear that “actual borrowing month order” is 

to be determined by Reclamation and WAPA. 

10) 2-9: Hydropower Modeling Assumptions/GTMax should be rewritten by WAPA. The Power and 

Energy analysis included in the DSEIS does not appropriately disclose a full effects analysis 

required for either public comment or decision by the Secretary of the Interior. The GCMRC 

section should be removed from the DSEIS. Including competing models, competing tables and 

competing results for Power and Energy is a disservice to the public and the CRSP hydropower 

customers and prevents disclosure of clear information about each alternative’s effects on Power 

and Energy. The Power and Energy analysis should be undertaken by WAPA with its protocols 

and models, consistent with previous Reclamation CRSP NEPA processes (Flaming Gorge, 

Aspinall, LTEMP). CREDA’s participation and comments offered in the GCDAMP Annual 

Reporting, TWG, and most recently the DSEIS public webinars have underscored this request. 

The “constrained optimization model” as CREDA understands it, does not include capacity, rate, 

or Basin Fund analysis, which is inconsistent with the LTEMP, nor does it address electric grid 

impacts in any manner. Further, as CREDA understands the GCMRC model and results, it includes 

all 30 traces from the CRSS model, whether or not an experiment is triggered in a specific trace, 

and averages all those traces. This is an incorrect analysis and results in misinterpretation of the 

experiment’s effects. Instead, the analysis should analyze the traces IN WHICH AN EXPERIMENT 

OCCURS, and assess the effects of EACH EXPERIMENT, not an average of 30 traces, many of 

which do not include or trigger an experiment. CREDA has raised specific concerns in these 

recent meetings and is willing to make its hydropower subject matter expert members available 

to discuss further. 

11) 2-11: CREDA assumes the paragraph beginning “In practice, flow implementation....” applies to 

all bypass alternatives (and not just the Cool Mix Alternative described in section 2.6). Please 

confirm this assumption and consider including this paragraph within “Implementation” as 

opposed to in the description of only one of the bypass alternatives. If you do not confirm this 

assumption, please explain why the statement only applies to the Cold Mix Alternative. 

12) 2-11: In describing the flow alternatives, the language stating, “To align with actual 

implementation without necessitating multiple weeks of hydropower maximization (that is, the 

operation of the hydropower system to generate the maximum amount of electrical power)...”

flies in the face of the LTEMP hydropower objective, as well as express statutory requirements.

14 

As the Basin States have noted, “The U.S. District Court for the District of Arizona further clarified 

that the broadly worded provisions of the Colorado River Storage Project Act (CRSPA) and GCPA 

impose on the Secretary an obligation to balance many different interests in operating Glen 

Canyon Dam. The Secretary must continue to recognize that power production is a primary 

13 Operating Criteria for Glen Canyon Dam In accordance with the Grand Canyon Protection Act of 1992 and the Record of Decision for the Glen Canyon Dam 

Long-Term Experimental and Management Plan Final Environmental Impact Statement, December 2016, June 7, 2018 (WAPA and Reclamation). 14 CREDA raises here the issue of omission of an express statutory requirement – generation of hydroelectric power - from the bypass alternatives identified in 

this NEPA analysis and reserves the right to litigate the compliance with applicable statutory requirements. 

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purpose of the Dam that must be balanced against other purposes, statutory requirements, and 

water delivery obligations as (s)he considers actions to implement the GCPA.”15 

13) 2-17: The Non-Bypass Alternative (as well as in Table 2-1) is described as including “substantial”

river stage changes. Yet, the bypass flow alternatives also include release components that are 

extreme (or “substantial”). Consider replacing the description of the Non-Bypass Alternative 

with one provided by WAPA and the hydropower Cooperating Agencies. Please remove 

subjective descriptors, as they could reflect pre-decisional bias. 

14) 3-4: The third bullet under “Assumptions” is incorrect and should be modified or removed. See 

comment 13) above. 

15) 3-16/3-17: The description of Affected Environment associated with WAPA’s marketing area 

should be revised to reflect the CRSP region, not the entire WAPA territory. Reference to 

emergency assistance to California provided by WAPA in 2020 should be expanded to similar 

assistance in 2001, and 2022. Finally, the sentence describing authorization of power revenues 

should either remove reference to the Grand Canyon Protection Act (as it is not the only Act that 

refers to power revenues) or revise the text to state “as authorized”, as opposed to “as dictated 

by”. The GCPA does not mandate the use of CRSP power revenues for the GCDAMP. 

16) 3-17 through 3-21: These sections should be revised by WAPA to address omissions such as 

reference to the June 6, 2018 Operating Criteria between WAPA and Reclamation; correct the 

description of reserves and regulation; include analysis of impacts to Renewable Energy Credits 

(RECs); remove reference to a “subset of customers”; and remove irrelevant reference to WAPA 

sales of electric power. 

17) 3-21: As described above, reference and use of the GCMRC models should be removed from the 

DSEIS. CREDA questions the GCMRC’s model sufficiency for the effects analysis required in the 

DSEIS. CREDA understands the model has not been peer-reviewed or published, and therefore is 

not the best available science/tool available for power and energy assessment in the DSEIS, as 

described in comment 10) above. 

18) 3-24 through 3-35: This information should be withdrawn and revised by WAPA based on its 

GTMax, PLEXOS and other modeling results. As drafted, there are incorrect statements such as 

“Overall, the effects described above may be most likely for power consumers in the surrounding

counties and states”; more severe impacts in the immediate areas around Glen Canyon Dam and

less severe impacts farther away from the dam” (p. 3-31). Those statements do not reflect the 

contractual and operational reality of CRSP firm electric service marketing and are misleading as 

to power and energy effects, as well as rate impacts to CRSP firm electric service customers. 

19) 3-37: Reference to the April 2023 event should be referred to as an “action” or “flow” or some 

other descriptor; it was by its terms not an HFE. 

20) 3-48 through 3-54: The question of whether or not Glen Canyon Dam operations impact the 

abundance and diversity of aquatic insects in the Colorado River downstream of Glen Canyon 

Dam remains an open question, even after years of bug flow experiments. For purposes of this 

DSEIS, CREDA recommends removal of this information, or revise it to brief references or 

citations, as it is secondary to the specific resources and issues being analyzed. 

21) 3-129: CREDA appreciates the paragraph describing the vegetation model used and 

simplifications made regarding threatened and endangered bird analysis. Given the DSEIS is 

intended to supplement the LTEMP FEIS/ROD with relevant new information, please consider 

removing any impact analysis that is repetitive from the LTEMP documentation. 

22) 3-141: The paragraph referring to the SunZia Wind facility should be removed as it is 

inappropriate to single out one project and speculate as to its impact on the grid. It would be 

appropriate to merely state that the analysis utilized two scenarios in the emissions/air quality 

assessment. 

15 See Colorado River Basin State Representatives to LTEMP EIS Scoping, January 31, 2012. 

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23) 3-188/3-189: The discussion on impacts on boating and camping for the bypass flow alternatives 

is confusing. It is described as the same as under No Action, because these alternatives allegedly 

“operate flows within the current range of operations...” Refer to comment 11) above. 

24) 3-191: Is the conclusion that the Non-Bypass Alternative would adversely affect whitewater 

boating opportunities in Grand Canyon National Park and the Hualapai River Runners based on 

the assumption that the 2,000 cfs flow occurs between 9 p.m. and 1 a.m. on Sunday evenings? Is 

whitewater boating occurring between those hours? The analysis and conclusions for the bypass 

alternatives seem incongruous with the analysis and conclusions for the non-bypass alternative. 

These paragraphs should be clarified, and the use of “temporary” and references to “minimum

flows of 2,000 cfs” should be consistently described and applied. CREDA questions the 

cumulative effects statement that only the Non-Bypass Alternative would not result “in a 

reduction of navigation concerns”. 

25) 3-199: As discussed in a previous comment, the SEIS is intended to supplement information 

already existing in the LTEMP. Consider either a) removing the Nonuse Values subsection, as it is 

limited in its scope, or b) adding reference and description to “Estimating Non-Use Values for 

Alternative Operations of the Glen Canyon Dam: An Inclusive Value Approach, Phase 3B Project 

Research and Findings”16 as significant information directly relevant to LTEMP. Unlike previous 

non-use valuation studies (such as the 1987 Bishop study cited in the DSEIS) that were limited in 

their application to only a small subset of downstream resources, this study describes all 

resources considered in the LTEMP DEIS, including tribal communities. The study estimates the 

non-market, non-use values for an inclusive set of impacts that result from changing the 

operation (i.e., hydropower generation) of Glen Canyon Dam. To accomplish this, the research 

team developed an integrated, multi-stage protocol to identify the valued impacts and to 

estimate the balance of the negative and positive valuations of those impacts by a representative 

sample of the US public. The study found that the median household value for retaining the 

current pattern of GCD operations (i.e., hydropower generation) would be nearly $20 per year -

amounting to approximately $2.5 billion per year over all US households. 

26) 3-209: See comment 23) above regarding Non-Bypass Alternative boating impacts. 

27) 3-210: CREDA disagrees with the statement that “Additionally, individuals owning property in 

the region around Glen Canyon Dam are considerably more likely to support continuation of dam 

operations.. These people are more likely to receive the benefits of Glen Canyon Dam 

hydropower at their property....” This statement is a mischaracterization of Jones et al. 2016, as

well as technically incorrect (see comment 18), and should be removed. 

28) 3-219: The word “end-use” is incorrect and should be revised to “wholesale.” WAPA does not 

market directly to end-use customers. That obligation lies with WAPA’s firm electric service 

customers (see first bullet, page 3 hereof). The word “benefit” should be revised to “benefitcrediting” in the last paragraph on this page.

29) 3-220: The paragraph describing tribal benefit crediting arrangements should be revised by 

WAPA. Specifically, references to the types of utilities who have entered into benefit crediting 

arrangements should be corrected, “lower cost power” should be removed, and the last 

sentence attempting to describe the history of benefit crediting should be removed as 

inflammatory, or rewritten based on the public record associated with WAPA’s SLCA/IP post2004 resource pool public process.17 

30) 3-222: Remove the following sentence, as it is premature to include pending outcome of rate 

analysis: “However, the cost of additional capacity required under the action alternatives to

replace lost capacity at Glen Canyon Dam would have negligible impacts on electric bills paid by 

residential consumers. 

16 University of Oklahoma (Hank C. Jenkins-Smith, Principal Investigator; Carol L. Silva, Co-Principal Investigator; Deven Carlson, Kuhika Gupta, Benjamin Jones, 

Joseph Ripberger, Wesley Wehde); University of New Mexico (Robert Berrens); Sept. 2016. 17 See 64 Fed. Reg. No. 173 (Sept. 8, 1999). 

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31) 4-2: The third bullet should be replaced with a description of WAPA models and impact 

indicators provided by WAPA. 

32) A-1: Shouldn’t footnote a refer to all FIVE options? CREDA assumes that the Non-Bypass 

Alternative also includes the change to the sediment accounting window. Please confirm or 

revise the footnote accordingly. 

OTHER ISSUES 

The Basin Fund is the primary funding source for Reclamation and WAPA’s CRSP operations. In 

addition to funding operation and maintenance expenses of CRSP generation and transmission 

infrastructure, the Basin Fund repays the federal CRSP investment (with interest), provides irrigation 

assistance, provides funding to the Upper Basin States’ Memorandum of Agreement projects, and supports 

the Colorado River Salinity Control Program. Federal non-reimbursable funding must be provided to 

implement and mitigate the costs and impacts of the SEIS. 

Section 1.4 of the LTEMP ROD establishes a decision-making/recommendation process associated 

with experiments undertaken under LTEMP. Given the potential direct and immediate impacts of actions 

being considered by this DSEIS to CRSP electric service customers, CREDA recommends that all LTEMP 

Cooperating Agencies be afforded the opportunity to participate in any decision-making/recommendation 

process associated with actions under this DSEIS. 

CREDA appreciates Reclamation holding three public webinars following issuance of the DSEIS. 

During the February 22, 2024, webinar, the presenter noted that “Resources Analyzed in Detail – Chapter 3”

of the DSEIS are listed in order based on number of comments received by Reclamation on the 2023 

Environmental Assessment. Energy and Power was the resource category receiving the most public 

comments, which demonstrates the public’s interest in the hydropower resource. 

CREDA appreciates the opportunity to provide comments on the DSEIS and urges Reclamation to 

update and reissue a public draft SEIS as recommended herein. Should there be any questions or concerns 

regarding this letter or any aspect of CREDA’s or CREDA member interests, please contact me at your earliest 

convenience. 

Leslie James 

Leslie James 

Executive Director 

Att: Referenced letters 

Cc: CREDA Board 

WAPA Administrator Tracey LeBeau 

Wayne Pullan – Reclamation UC Region 

Rodney Bailey – WAPA CRSP Management Center 

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CREDA 

Colorado River Energy Distributors Association 

ARIZONA 

Arizona Municipal Power Users Association 

Arizona Power Authority 

Arizona Power Pooling Association 

Irrigation and Electrical Districts 

Association 

Navajo Tribal Utility Authority 

(also New Mexico, Utah) 

Salt River Project 

COLORADO 

Colorado Springs Utilities 

Holy Cross Energy 

Intermountain Rural Electric Association 

Platte River Power Authority 

Tri-State Generation & Transmission 

Association, Inc. 

(also Nebraska, Wyoming, New Mexico) 

Yampa Valley Electric 

Association, Inc. 

NEBRASKA 

Municipal Energy Agency of Nebraska 

(also Colorado) 

NEVADA 

Colorado River Commission 

of Nevada 

Silver State Energy Association 

NEW MEXICO 

Farmington Electric Utility System 

Los Alamos County 

UTAH 

City of Provo 

City of St. George 

South Utah Valley Electric Service District 

Utah Associated Municipal Power Systems 

Utah Municipal Power Agency 

WYOMING 

Wyoming Municipal Power Agency 

Leslie James 

Executive Director 

CREDA 

10429 S. 51st St., Suite 230 

Phoenix, Arizona 85044 

Phone: 480-477-8646 

Fax: 480-477-8647 

Cellular: 602-469-4046 

Email: creda@creda.cc 

Website: www.credanet.org 

March 10, 2023 

Sarah Bucklin 

Regional NEPA Coordinator 

U.S. Bureau of Reclamation, Upper Colorado Basin Region 

Via Email only – sbucklin@usbr.gov 

RE: Glen Canyon Dam/Smallmouth Bass Flow Options Draft Environmental 

Assessment (EA) 

The Colorado River Energy Distributors Association (CREDA) appreciates the 

opportunity to provide comments on the EA, issued February 24, 2023. 

CREDA and CREDA Member Interests 

As a member of the Glen Canyon Dam (GCD) Adaptive Management Work Group 

(AMWG) and Adaptive Management Program (AMP), CREDA is one of the 

representatives of contractors who purchase federal hydropower and resources 

from the GCD, a primary feature of the Colorado River Storage Project (CRSP). 

CREDA is also a longstanding participant in the Upper Colorado River Endangered 

Fish Recovery Program. CREDA members serve over 4.1 million consumers in the 

Colorado River basin states of Arizona, Colorado, Nevada, New Mexico, Utah, and 

Wyoming, and represents the majority of the firm electric service (FES) customers 

of the CRSP. As such, CREDA and its members have a unique interest and role in 

issues associated with Colorado River and CRSP operations, specifically GCD 

operations. CREDA members are all non-profit entities, composed of 

municipalities, rural electric cooperatives, irrigation and electrical districts, state 

agencies, political subdivisions and tribal utilities and communities. Each CREDA 

member is an FES customer with a long-term contract with the Western Area 

Power Administration (WAPA) for the purchase of CRSP resources. These resources 

are used in part by CREDA member utilities to meet their obligation to serve the 

electrical needs of their customers. Electric service is not discretionary or a 

convenience. This service is essential to health and human safety. 

CREDA appreciates the inclusion of our December 13, 2022 comment letter as 

part of the EA documentation. We offer the following general and specific 

comments for your consideration. 

General Comments and Conclusions 

A. The impacts of the Proposed Action (Action) to the human environment will be 

significant and cannot be supported by an Environmental Assessment (EA) and 

Finding of No Significant Impact (FONSI) for the following reasons: 

- The impact of bypassing hydropower production will cause a 

significant increase in replacement power costs for CREDA 

members with firm electric service (FES) contracts for power 

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from CRSP facilities. 

- The result of the Action will require WAPA and FES customers to purchase replacement power on the market, 

yet current projections indicate there may be little to no power availability on the market when the 

replacement power is needed. 

- The source of replacement power, should any be available, will not be carbon free; thus the Action 

will further exacerbate the impacts of a warming climate. 

B. The analysis in the EA is wholly inadequate in its identification and analysis of potential impacts from the Action. 

- There is no analysis on the availability of replacement power or on the impacts to the environment of 

purchasing replacement power (including impacts to the power grid and a warming climate). 

- The EA fails to meaningfully identify or analyze the impacts on the Upper Colorado River Basin Fund 

(Basin Fund) and the implications those impacts have on the ongoing operation of the CRSP 

facilities and programs it funds. 

- The EA fails to meaningfully identify or analyze the affordability of replacement power for FES 

customers (many of which are at risk or tribal communities). 

- The EA is solely limited to alternatives regarding variations of flows bypassing power production. 

There is no discussion of potential non-flow alternatives. 

- The EA fails to use the most current information regarding future hydrology and its impacts on 

hydropower production. Potential impacts of the Action cannot be analyzed in a vacuum. NEPA 

requires a disclosure of the cumulative impacts of the Action. In this case, Reclamation must 

analyze the impacts of the Action in light of the ongoing impacts to FES customers from the last 20 

years of limited hydropower production and the resulting increased reliance on purchased power. 

C. The EA fails to acknowledge how the impacts of this Action will be inconsistent with the “beneficiary pays”

construct that has been the cornerstone of Reclamation law and policy for 120 years. Smallmouth bass were not 

introduced into the CRSP at either the request of, or to benefit, hydropower customers, yet the costs of actions 

to limit the range and impacts of these fish on native populations are being placed wholly at the feet of WAPA 

and its FES customers. This must be disclosed. 

For these reasons, CREDA believes that the EA is legally inadequate and cannot be the basis for a FONSI. 

Specific Comments 

Chapter 1. Introduction 

1) Section 1.2, page 1-1 describes uses of Lake Powell. As this EA targets operations of GCD, please revise the 

Background section to refer specifically to GCD’s authorizing legislation and stated purposes – the 1956 Colorado 

River Storage Project Act (see also comment 3) below). 

2) Section 1.2, page 1-3 refers to the Secretary’s Designee’s charge directing Reclamation and GCMRC to work with 

the Adaptive Management Work group “to develop flow options to disrupt or prevent spawning of smallmouth 

bass.....”. Please include the additional charge in that directive, which was “to minimize impacts to other 

resources.” (May 2022 Directive). None of flow options within the Action include an attempt to minimize 

impacts to the hydropower resource, notwithstanding viable option(s) were proposed by biologists and 

hydropower experts from WAPA during the summer and fall of 2022 (WAPA November 18, 2022 and December 

15, 2022 letters). 

3) Section 1.3, page 1-5. The Purpose and Need Statement is broad enough to include “changes in flow velocity”

along with temperature-only focused hypotheses and experiments. (See also comment 9) below regarding 

alternatives.) As the EA describes an experimental action, and the Action is based solely on modeling, please 

consider reinstating the word “help” prior to “prevent the establishment of...”. As Upper Division States TWG 

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representatives have stated, operational alternatives are not a panacea; fish exclusion should be an immediate 

priority; the EA is deficient in that more than a single focus (bypass flows) alternative should have been included. 

Reclamation should prioritize and expedite installation of its preferred prevention technology, and NPS should 

take action regarding the slough at RM 12, and continue addressing nonnative invasive species as required in its 

Expanded Non-Native Aquatic Species Management Plan.1 

4) Section 1.4, page 1-5, 6. Supplementing comment 1) above, please broaden the description of the Colorado 

River Storage Project Act to refer to its authorized purposes and Section 5, and not just reference to the creation 

of the Basin Fund. In referring to the Grand Canyon Protection Act of 1992 (GCPA), please include the full 

mandate of the GCPA, which includes not only Section 1802(a) but Section 1802(b), which requires the 

protection, mitigation and improvement be done “in a manner fully consistent with and subject to the Colorado 

River Compact, the Upper Colorado River Basin Compact, the Water Treaty of 1944 with Mexico, the decree of 

the Supreme Court in Arizona v. California, and the provisions of the Colorado River Storage Project Act of 1956 

and the Colorado River Basin Project Act of 1968 that govern allocation, appropriation, development, and 

exportation of the waters of the Colorado River Basin.” Reference to the GCD AMWG should be corrected to 

refer to that body’s responsibility to “Advise GCDAMP and the Secretary of Interior or their designee.... regarding 

GCDAMP priorities and policies, proposed changes to the criteria and operating plans for Glen Canyon Dam, and 

the implementation of resource management objectives, research studies, and environmental or cultural 

commitments” (ROD, page 14). The AMWG does not have any responsibility to “organize and coordinate dam

operations.” Finally, in describing the GCD LTEMP EIS, please revise the current text to reflect language from 

p.1 of the ROD: “The LTEMP will provide a framework for adaptively managing Glen Canyon Dam operations and 

other management and experimental actions over the next 20 years, consistent with the Grand Canyon 

Protection Act (GCPA) and other provisions of applicable Federal law.” (emphasis added).

5) Section 1.7, p. 1-7: CREDA recommends including in Operational Guidelines, the text from the LTEMP ROD, page 

B-7, section 1.2: “Reclamation also will make specific adjustments to daily and monthly release volumes, in

consultation with other entities as appropriate, for a number of reasons, including operational, resource-related, 

and hydropower-related issues. Examples of these adjustments may include, but are not limited to, the 

following: ... For hydropower-related issues, adjustments may occur to address issues such as electrical grid 

reliability, actual or forecasted prices for purchased power, transmission outages, and experimental releases 

from other Colorado River Storage Project dams.”

6) Section 1.8, page 1-8: The EA refers to Reclamation’s close coordination with USFWS through the EA process,

which is important. However, in reviewing the USFWS letter (Appendix C), we question whether the statement in 

the EA that refers to “a potential future decline in humpback chub that would occur if smallmouth bass are 

allowed to establish” (emphasis added) accurately reflects the Service’s description of risk and threats (i.e., 

uncertainty). 

Chapter 2. Proposed Action and Alternatives 

7) The EA should be clear in its Purpose and Need Statement that the duration of the EA/Action is “up to three 

years”, which is not stated until Chapter 2, section 2.2.1. CREDA’s understanding is that since the Table 3-2 

impacts are only for 5 months in 2023, the EA only analyzed impacts over the 5 summer months of 2023, and not 

over the period of the EA, three years. For all resources analyzed, that level of analysis is insufficient. 

1 See: ParkPlanning - Expanded Non-Native Aquatic Species Management Plan/EA (nps.gov) 

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8) Section 2.2, p. 2-1: The description of the Proposed Action with Flow Options (Action) was challenging to 

understand. Assuming that the last three bullets on page 2-2 are the key drivers, we have the following 

questions: 

a. Implementation of the experiment appears to be determined by temperatures at the Little Colorado 

River (LCR). Is it a model that makes that critical determination? Is that the referenced “adapted”

model, and has that model been peer reviewed? 

b. Is it feasible, since such a significant experiment is being considered, to use actual temperature data 

as the trigger? As opposed to projections based on mean daily air temperature from Page, Arizona 

(77 miles from the LCR), and mean solar radiation from Williams, Arizona (90 miles from the LCR). 

c. Flow Option A, p. 2-4: what percentage of time does “almost always” refer to in achieving the target

temperature with all 4 bypass tubes in use? 

d. If “no smallmouth bass have been detected below RM 0, then why not target RM 45. And how is 

“effective” quantified?

e. Flow Option B, p. 2-6: this section refers to two flow spikes; yet, page 2-4 refers to “up to three 36-

hour flow spikes”. Please clarify.

f. Flow Option C, p. 2-6: is there more recent data (besides 1945, 1957 and 1963) available? And to 

what degree of certainty can the statement be made that “achieving a cold shock down to RM 0 or 

RM 15 would still be effective at disrupting spawning (emphasis added). How is “effective” defined? 

g. Flow Option D, p. 2-8: What is the science basis (or data supporting) the statement “even if it is not 

possible to achieve a temperature of 13 C, the flow would likely disrupt spawning, even though data 

from the Yampa and Green Rivers suggests that smallmouth bass can continue to spawn when 

temperatures drop to 13.9 C”.

h. An adaptively managed experiment of this significance and uncertainty must include a description of 

the proposed experiment, the time or frequency of implementation of the experiment, and the 

triggers or other conditions that must exist prior to implementation of the experiment. The 

experiment must also include a description of the hypotheses that will be tested by the experiment 

and benchmarks or other identifiable criteria that will allow the Secretary and interested parties to 

assess the success or lack thereof, when an experiment or action must be terminated because of 

unacceptable impacts (as specifically defined) to the listed humpback chub or other legally protected 

resources. Finally, any monitoring included in an implementation plan or experimental design must 

meet legal standards necessary to implement adaptive management, including monitoring of impacts 

to LTEMP resources2. 

9) Section 2.3, p. 2-9: Please describe the science basis for concluding without detailed analysis that a penstock only 

release “does not meet the project’s purpose and need.” A penstock only release could meet the purpose and 

need if the purpose had remained as it was provided to the AMWG Stakeholders, with the word “help” as a 

modifier to “prevent”. Further, it appears this option was rejected for including one of the same objectives as 

the Action options: abandoning nests v. disrupting/disturbing spawning. Disrupting/disturbing spawning may 

have the potential of “high mortality of offspring”, which is a secondary objective of disrupting/disturbing 

spawning. Page 3-7, describing the Action impacts on nonnative fish, is very clear: “All flow options are designed 

to inhibit smallmouth bass spawning, displace male smallmouth bass from guarding nests, or both”. The EA 

should clearly explain why Option E was rejected for analysis based on the same criteria that is included in all 

flow options of the Proposed Action. 

Chapter 3. Affected Environment and Environmental Consequences 

10) Section 3.2.1, page 3-1: Has the population of humpback chub observed in the western Grand Canyon been 

factored into a risk assessment of smallmouth bass impacts to the chub? From the numbers of fish reported out 

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at the recent TWG and AMWG meetings, it seems logical that although the dynamics are not fully understood, 

that sheer numbers should moderate the risk. 

11) Page 3-3: Since over 250 juvenile smallmouth bass were found throughout the Glen Canyon reach in 2022, and 

this number “suggests successful spawning”, does that translate to “establishment”, and if so, the Purpose and 

Need as drafted should be reconsidered. In addition, some less impacting actions/operations could be 

considered, assuming there is already establishment. 

12) Section 3.2.2, page 3-6: This section also states that under Options C and D, the cold temperatures would reach 

downstream to the confluence of the LCR. How does that risk to the humpback chub compare to the risk of 

smallmouth bass traveling down to the LCR? Finally, how can effects to razorback suckers be characterized as 

“minor” if flow changes “inundate or desiccate backwaters”?

13) Page 3-8: Fish dispersal is a concern inherent to all flow options and “an important consideration for 

establishment”. Flow spikes are identified with dispersal. We know from previous high-flow experiments (HFEs) 

that dispersal is a key concern. In fact, a decision was made in the fall of 2022 to not undertake an HFE due in 

large part to concern about nonnative fish dispersal. Is the statement that “green sunfish already occur 

throughout the Grand Canyon in low numbers accurate? Just because there may be “an overall lack of 

quantitative research on green sunfish movement or dispersal in response to flows”, we know that green sunfish 

is a predator/competitor of humpback chub, and actions that will disperse more of this species should be 

reconsidered. 

14) Page 3-9: The impacts of Flow Options C and D appear to be contrary to the objective of the last 3 years of the 

bug flow experiment. The flow spikes....”represent a disturbance that would scour benthic substrates and 

reduce the food-base abundance and biomass.” How is this trade-off assessed and evaluated? 

15) Section 3.3, page 3-11: CREDA submitted extensive comments during the LTEMP process regarding the cited 

1987 Bishop study. CREDA’s November 16, 2016 letter states in part: “The Fluctuation Index utilizes information

derived from a 1987 study (Bishop et al),3 which addressed recreational user preference for fluctuating flow 

levels. In that study, however, 10,000 cfs (not 8,000 cfs) was defined as “constant flows”. We recommend

reference to the 1987 study be removed, as it was mischaracterized in LTEMP, in favor of the work done in 2016 

by Bari. 

16) Section 3.4.2, page 3-20: We question whether volume of water released during flow spikes “would be within

the range analyzed in the LTEMP Final EIS”, if the analysis included “up to three years” of flow options B and D 

and the frequency of flow spikes contained therein. 

17) Section 3.6, page 3-27: Please include reference to the September 2022 emergency power supply from GCD to 

California. Please remove the incorrect reference to the Grand Canyon Protection Act in the last sentence. 

18) Page 3-30: Please remove the following sentence which is implied to be a citation from DOI 2016a, p. 3-204): 

“This type of operation creates large fluctuations in water releases, which has negative impact on environmental 

resources”. The prior three sentences of that paragraph are accurate cites from page 3-204 of DOI 2016a. This 

last sentence is not. 

2 See: TechGuide.pdf (doi.gov), p. 9; Interior Environmental Statement Memorandum No. ESM 13-11, January 7, 2013, p. 5 3 See FEIS Appendix C, P. C-27, section 4.5 

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19) Page 3-31: The Power Marketing section of the EA and Section 3.6.2 Environmental Consequences Analysis 

should disclose the impacts based on WAPA’s implementation of WAPA-199 on December 1, 2021. The EA must 

also address the Action’s impact on replacement power availability during the summer months of the 

experiment. See NERC Summer Reliability Assessment 2022 at pp.5-6: “Drought conditions create heightened 

reliability risk for the summer. Drought exists or threatens wide areas of North America, resulting in unique 

challenges to area electricity supplies and potential impacts on demand: Energy output from hydro generators 

throughout most of the Western United States is being affected by widespread drought and below-normal 

snowpack. Dry hydrological conditions threaten the availability of hydroelectricity for transfers throughout the 

Western Interconnection. Some assessment areas, including WECC’s California-Mexico (CA/MX) and Southwest 

Reserve Sharing Group (SRSG), depend on substantial electricity imports to meet demand on hot summer 

evenings and other times when variable energy resource (e.g., wind, solar) output is diminishing. In the event of 

wide-area extreme heat event, all U.S. assessment areas in the Western Interconnection are at risk of energy 

emergencies due to the limited supply of electricity available for transfer.” This is not just an issue for WAPA, 

but for the FES customers and all other utilities in the West. A significant loss of generation from GCD will have 

significant financial impacts on WAPA and economic and financial impacts on WAPA’s FES customers and their 

customers. The EA analysis does not quantify the impact of customers having to replace GCD generation with 

other resources. The analysis should include the impact on those customers that count their CRSP generation 

toward meeting their resource adequacy requirements, as well as include their CRSP generation in their 

greenhouse gas and Renewable Energy Certificates (RECs) reporting. Reduced and/or bypassed generation at 

GCD/CRSP has implications and impacts to both direct contracts of that/those resources as well as exchange 

agreements that rely on the output of that/those resources. Consideration of resource adequacy requirements, 

replacement resource availability, and contractual impacts impacting utilities’ obligation to serve customers are 

essential elements that must be addressed in the EA’s effects analysis. On September 28, 2022, CREDA 

submitted comments to Reclamation regarding potential fall experiments under LTEMP. These comments apply 

to every experiment or changed operation that may be considered for CRSP generating units. 

20) Page 3-33: Please consider revising the last sentence to the following: The replacement power purchased by 

WAPA and its customers would likely be from carbon-emitting resources and would increase GHG emissions in 

the region. The EA should assess the impact of the Action on GHG emissions. Previous analysis showed that 

without GCD, an additional 2.4 million metric tons per 1,000 GWh would be emitted by the WECC.”4 Given the 

Departments of the Interior and Energy’s commitments to maintain and expand renewable generation capacity, 

the importance of hydropower capacity to the overall power supply for the western United States, and the 

existing benefits of hydropower that avoids alternate fossil fuel greenhouse gas production5, strong 

consideration should be given to the air emission impacts resulting from the Action. Please also include a 

sentence stating that WAPA and its customers may not be able to find replacement power, whether or not the 

Basin Fund has sufficient funds available, given resource scarcity during summer months. The paragraph 

referring to additional analysis for Flow Option A is based on outdated data, as confirmed at the AMWG meeting 

on February 16, 2023. A more likely scenario, based on recent market prices, is that the values included in the EA 

on hydropower/Basin Fund impacts are understated. Finally, the discussion of transmission congestion should 

be modified to remove statements about “reverse direction of historical operations” and “reversal of power;”

these statements are confusing and inaccurate. New text should be provided by WAPA to reflect more current 

modeling by WAPA/NREL/Argonne and should state that societal effects will be felt across the Western Power 

Grid based on that analysis (emphasis added). 

4 See Scientific Certification Systems, Life Cycle Impact Assessment (LCIA) of Glen Canyon Hydropower Generation System Compared to the 

WECC Baseline; Conducted in accordance with ISO 14044 LCIA Framework and the Draft SCS-002 Life Cycle Metrics Standard, Type III LifeCycle Impact Profile Declarations for Materials, Products, Services and Systems, March 2009, p ii 

5 See New Energy Frontier. Balancing Energy Development on Federal Lands. A Joint Report to Congress on Siting Energy Development Projects 

on Federal Lands. U.S. Department of Interior and U.S. Department of Agricultural. May 2011, pp. 28-31 

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21) Section 3.7, page 3-34: CREDA disagrees that only the recreation resource should be analyzed for environmental 

justice impacts. Impacts to CRSP hydropower customers, particularly the smaller municipal, rural and tribal 

customers, should be analyzed in the context of environmental justice. The Proposed Action may 

disproportionately affect these customers as they will be paying more for an essential service that is necessary 

for human health; the GHG emissions impacts resulting from replacement power sources may also have a 

disproportionate impact on these communities. This analysis is required by the EA. The LTEMP Appendix K 

included a fair amount of impact analysis to tribal customers, in particular. As post-WAPA-199 impacts are direct 

and immediate to these (and all other) FES customers, the EA should analyze those impacts. 

22) Page 3-38: The affected environment should be revised to include the environmental justice populations 

represented by CRSP FES customers. See section D. of CREDA’s December 13, 2022 letter, which is included in 

the Appendix to this EA. 

23) Page 3-39: In a post-WAPA-199 world, direct and immediate impacts are likely borne by all WAPA FES 

customers, not just the “largest of WAPA’s customers”. The impact assessment should be based not only on the 

size of an FES customer’s CRSP allocation, but also the proportion of its CRSP allocation to its total resource mix. 

In addition, the ability of an FES customer to access market resources for replacement power is also a factor. 

As representative of the Secretary of the Interior, Reclamation has the responsibility to fulfill the Secretary’s 

obligation to meet multiple and sometimes competing statutory requirements applicable to the operation of GCD 

and the exercise of other authorities as required by the provisions of the GCPA. The United States has described the 

relationship between the objectives of the GCPA and the CRSP as being “in addition to rather than in substitution of 

the Secretary’s obligations concerning the operations of Glen Canyon Dam for hydropower and other project

purposes.”6 “The U.S. District Court for the District of Arizona further clarified that the broadly worded provisions of 

the Colorado River Storage Project Act (CRSPA) and GCPA impose on the Secretary an obligation to balance many 

different interests in operating Glen Canyon Dam. The Secretary must continue to recognize that power production is 

still a primary purpose of the Dam that must be balanced against other purposes, statutory requirements, and water 

delivery obligations as (s)he considers actions to implement the GCPA.”7 In fact, the failure to incorporate within the 

EA an experiment that provides a less impacting and more balanced approach to smallmouth bass experimentation is 

arbitrary and capricious given statutory requirements.8 As Judge David Campbell stated in the Grand Canyon Trust 

v. United States case: “The Bureau of Reclamation, as the operator of the Dam, has a complex set of interests it must 

balance in operating the Dam. Those interests include not only the endangered species below the Dam, but also 

tribes in the region, the seven Colorado River basin states, large municipalities that depend on water and power from 

Glen Canyon Dam, agricultural, Grand Canyon National Park and national energy needs at a time when clean energy 

production is becoming increasingly important.” 

Leslie James 

Leslie James 

Executive Director 

Cc: CREDA Board 

Commissioner Camille Touton 

WAPA Administrator Tracey LeBeau 

Wayne Pullan – Reclamation UC Region 

Rodney Bailey – WAPA CRSP Management Center 

6 See Grand Canyon Trust v. US Bureau of Reclamation, 623 F.Supp.2d 1015, 1036, Federal Defendants’ Reply Memorandum In Support of Cross 

Motion for Summary Judgment on Claims 6-8 at p. 26, lines 25-27, (February 20, 2009) 7 See Colorado River Basin State Representatives to LTEMP EIS Scoping, January 31, 2012 8 CREDA raises here the issue of omission of a statutory requirement from the alternatives identified in a NEPA analysis and reserves the right 

to litigate the compliance with applicable statutory requirements. 

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CREDA 

Colorado River Energy Distributors Association 

ARIZONA 

Arizona Municipal Power Users Association 

Arizona Power Authority 

Arizona Power Pooling Association 

Irrigation and Electrical Districts 

Association 

Navajo Tribal Utility Authority 

(also New Mexico, Utah) 

Salt River Project 

COLORADO 

Colorado Springs Utilities 

CORE Cooperative 

Holy Cross Energy 

Platte River Power Authority 

Tri-State Generation & Transmission 

Association, Inc. 

(also Nebraska, Wyoming, New Mexico) 

Yampa Valley Electric 

Association, Inc. 

NEBRASKA 

Municipal Energy Agency of Nebraska 

(also Colorado) 

NEVADA 

Colorado River Commission 

of Nevada 

Silver State Energy Association 

NEW MEXICO 

Farmington Electric Utility System 

Los Alamos County 

UTAH 

City of Provo 

City of St. George 

South Utah Valley Electric Service District 

Utah Associated Municipal Power Systems 

Utah Municipal Power Agency 

WYOMING 

Wyoming Municipal Power Agency 

Leslie James 

Executive Director 

CREDA 

10429 S. 51st St., Suite 230 

Phoenix, Arizona 85044 

Phone: 480-477-8646 

Fax: 480-477-8647 

Cellular: 602-469-4046 

Email: creda@creda.cc 

Website: www.credanet.org 

November 3, 2023 

Bureau of Reclamation 

Attn: LTEMP SEIS Project Manager 

125 South State Street, Suite 800 

Salt Lake City, UT 84138 

Via Email only – LTEMPSEIS@usbr.gov 

RE: NOTICE OF INTENT TO PREPARE A SUPPLEMENTAL ENVIRONMENTAL IMPACT 

STATEMENT FOR THE DECEMBER 2016 RECORD OF DECISION ENTITLED GLEN 

CANYON DAM LONG-TERM EXPERIMENTAL AND MANAGEMENT PLAN (NOI) – 88 FR 

191, October 4, 2023 

The Colorado River Energy Distributors Association (CREDA) appreciates the 

opportunity to provide comments on the NOI, issued October 4, 2023. 

CREDA and CREDA Member Interests 

As a member of the Glen Canyon Dam (GCD) Adaptive Management Work 

Group (AMWG) and Adaptive Management Program (AMP), CREDA is one of the 

representatives of contractors who purchase federal hydropower and resources 

from the GCD, a primary feature of the Colorado River Storage Project (CRSP). 

CREDA is also a longstanding participant in the Upper Colorado River Endangered 

Fish Recovery Program. CREDA members serve over 4.1 million consumers in the 

Colorado River basin states of Arizona, Colorado, Nevada, New Mexico, Utah, and 

Wyoming, and represents the majority of the firm electric service (FES) customers 

of the CRSP. As such, CREDA and its members have a unique interest and role in 

issues associated with Colorado River and CRSP operations, specifically GCD 

operations. CREDA members are all non-profit entities, composed of 

municipalities, rural electric cooperatives, irrigation and electrical districts, state 

agencies, political subdivisions and tribal utilities and communities. Each CREDA 

member is an FES customer with a long-term contract with the Western Area 

Power Administration (WAPA) for the purchase of CRSP resources. These resources 

are used in part by CREDA member utilities to meet their obligation to serve the 

electrical needs of their customers. Electric service is not discretionary or a 

convenience. This service is essential to health and human safety. 

CREDA offers the following comments on the topics contained in the NOI, 

focusing on “specific operational guidelines, strategics, and any other issues that 

should be considered on or before November 3, 2023.” These comments 

supplement CREDA’s letter of March 10, 2023 (attached with this transmittal). 

BACKGROUND 

The NOI describes the process the Glen Canyon Dam Adaptive Management 

Work Group (AMWG) undertook over the past year in its development of the 
 

 

 

 

 

 

 

 

 

 

 

 

 

Invasive Species Strategic Plan (Plan), which was approved by the AMWG at its February 2023 meeting. 

CREDA urges Reclamation to consider all three phases, rapid response (short-term), mid-term and long-term 

actions in its consideration of elements included in SEIS Alternatives, and to utilize the Plan as guidance in its 

preparation of the SEIS. As noted by the Colorado River Basin States in their March 10, 2023 letter, “We 

continue to believe that flow-related actions are only one tool to address the issue and that additional 

actions like the installation of fish exclusion device(s) are necessary and urgently needed for the long-term 

prevention of establishment of nonnative species from Lake Powell into the reach below Glen Canyon Dam.”

(emphasis added). It is CREDA’s understanding that following the April high flow release, and 

notwithstanding chemical treatment of the -12 mile slough, there is evidence of increased SMB presence and 

spawning in the system. Referring to the Colorado River Ecosystem, the Executive Summary of the Plan 

recommends: “To prevent the establishment of invasive fish species in the CRe, a combination of long-term, 

mid-term, and short-term actions will be required.“ CREDA recommends that Reclamation consider 

incorporating Appendix F from the Plan in its consideration of supplemental actions that were proposed by 

members of the Smallmouth Bass Ad Hoc Group and cooperating agencies to be considered in the 

management of invasive species. These actions, including temperature control device(s), generators on the 

bypass tubes, and modification of nursery and spawning habitat are recommended to complement 

identification and prevention actions and should be considered now. 

PURPOSE AND NEED/PRELIMINARY PROPOSED ACTION 

As proposed, the “Need” cannot be achieved by the stated “Purpose”. Flow actions alone are 

insufficient to “prevent the establishment of smallmouth bass below the Glen Canyon Dam”. (NOI at 68668). 

In addition, the stated Purpose and Need do not align with the noted Secretary’s Designee’s guidance from 

May 2022, which directive was to “help prevent” invasive fish establishment, “while minimizing potential 

adverse effects to other resources”. The NOI is also lacking in that it makes no mention of mitigation, as 

stated in the guidance. As rapidly as the system has been changing during the current extreme drought, the 

question of whether the SMB are already established (or not) below Glen Canyon Dam is secondary to the 

need to address the issue in a comprehensive manner, as outlined in the Strategic Plan. All actions included 

in Table 1 of the Plan “Fisheries Actions Within Current Compliance”, should be considered and available to 

the Department through this SEIS to address SMB prevention and management. 

The Purpose and Need statements and Proposed Action should be broadened to address a 

comprehensive adaptive approach to both the prevention of and management of (established) 

populations of SMB. 

ALTERNATIVES TO BE CONSIDERED 

CREDA appreciates the inclusion of a “Non-Bypass” Flow Option along with Bypass-Only Options. 

CREDA also supports Reclamation’s collaboration with fisheries experts in the development of alternatives to 

be considered in the SEIS. As a general statement, CREDA recommends Reclamation develop alternatives 

that are focused on addressing all aspects of SMB management: entrainment (reservoir elevation/curtain), 

habitat (-12 mile slough/backwaters), spawning (temperature/disturbance). Pending review of proposed 

alternatives in the draft SEIS, CREDA recommends the following elements be included as Elements Common 

to All Alternatives: 

• Implementation of a spring High Flow Experiment (HFE) would require use of water from 

month(s) prior to the spring HFE (as opposed to spring/summer/fall months following the 

experiment. 

• Identification and mitigation of financial, economic, electric grid and Tribal impacts 

associated with each Alternative. 

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• Establishment of on- and off-ramps addressing both operational and financial impacts 

(which requires appropriate monitoring and criteria for decision-making). 

• Emergency operations requirements as described in WAPA’s March 10, 2023, letter, 

pages 11-12. 

• Identified funding on a non-reimbursable basis to mitigate the financial impacts of the 

experiment on the Upper Colorado River Basin Fund (Basin Fund). This funding would 

assist WAPA in meeting its contractual delivery obligations required as a result of the 

experiment. Failure to do so could also impair federal repayment obligations and 

ongoing operation and maintenance requirements of Reclamation and WAPA for the 

CRSP. 

SUMMARY OF EXPECTED IMPACTS 

The NOI states (at 68668) that the initial analysis performed for the Glen Canyon Dam/Smallmouth 

Bass Flow Options Draft Environmental Assessment (February 2023) (EA) will be further informed and built 

upon by “relevant analyses” and information from the 2016 LTEMP Final EIS. CREDA recommends that in 

addition to the “potential effects on the resources below Glen Canyon Dam, including natural and cultural 

resources, endangered species, recreation, water resource, hydropower resources” (NOI at 68668), that the 

SEIS consider: 

• The impact on replacement power availability and grid reliability during the summer 

months of the experiment. See NERC Summer Reliability Assessment 2022 at pp.5-6: “Drought 

conditions create heightened reliability risk for the summer. Drought exists or threatens wide areas 

of North America, resulting in unique challenges to area electricity supplies and potential impacts on 

demand: Energy output from hydro generators throughout most of the Western United States is 

being affected by widespread drought and below-normal snowpack. Dry hydrological conditions 

threaten the availability of hydroelectricity for transfers throughout the Western Interconnection. 

Some assessment areas, including WECC’s California-Mexico (CA/MX) and Southwest Reserve Sharing 

Group (SRSG), depend on substantial electricity imports to meet demand on hot summer evenings 

and other times when variable energy resource (e.g., wind, solar) output is diminishing.”

• Greenhouse gas emission impacts associated with each Alternative. The SEIS cannot 

rely on analysis performed for the LTEMP EIS given significantly changed conditions, due in part to 

implementation of revised WAPA rate schedules, regional electric grid resource changes, and 

regional replacement power availability. 

• Impacts to underserved and disadvantaged rural and tribal communities. Nearly half 

of Colorado River Storage Project (CRSP) power customers (including CREDA members) are electric 

service providers for areas that could be classified as disadvantaged communities. Impacts to these 

environmental justice communities should be evaluated in the SEIS. 

• Impacts to CRSP customers in their capacity as electric service providers who have 

an obligation to provide reliable electricity to retail customers. These impacts are distinct from 

impacts to WAPA and the Upper Colorado River Basin Fund, although those impacts also potentially 

affect CRSP customers. Depending on the nature of the Alternative or elements thereof, whether 

the action is a management action or an experiment, resource adequacy requirements and 

availability of replacement power, could result in financial or economic impacts that must be 

disclosed and mitigated. 

• Funding sources for mitigation. Hydropower operations are not the cause of SMB 

incursion, and should not be relied on for mitigation. In the event WAPA must purchase power to 

replace resources that are unavailable or lost due to bypass operations for non-native fish control or 

HFEs, these costs should be considered non-reimbursable and should not be borne by WAPA or 

WAPA’s hydropower customers. Potential sources of funding should be identified during the scoping 

process. 

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SCHEDULE 

CREDA acknowledges the NOI’s proposal that the “duration of the flow options would potentially run 

through 2027,” while the HFE protocol revisions “are anticipated to run through the duration of the LTEMP 

Record of Decision.” (NOI at 68668). CREDA recommends Reclamation may reconsider these differing 

timetables following review of comments received on the NOI and consideration of input from fisheries 

experts and Cooperating Agency input on Alternative development. 

COOPERATING AGENCIES 

CREDA supports Reclamation’s inclusion of LTEMP EIS co-lead and cooperating agencies in 

development of alternatives and the draft SEIS. Most, if not all, of these entities were also engaged in 

development of the AMWG Plan referenced above, and the federal and State agencies all have significant 

roles and responsibilities associated with SMB and other nonnative species issues. 

OTHER ISSUES 

Section 1.4 of the LTEMP ROD establishes a decision-making/recommendation process associated 

with experiments undertaken under LTEMP. Given the potential direct and immediate impacts of actions 

being considered by this SEIS to CRSP electric service customers, CREDA recommends that all LTEMP 

Cooperating Agencies be afforded the opportunity to participate in any decision-making/recommendation 

process associated with actions under this SEIS. 

CREDA encourages Reclamation to consider additional public webinar opportunities at appropriate 

times during the SEIS process, particularly given the extremely short timeframe currently being considered. 

CREDA appreciates the opportunity to provide comments on the NOI. Should there be any questions 

or concerns regarding this letter or any aspect of CREDA’s or CREDA member interests regarding the NOI, 

please contact me at your earliest convenience. 

Leslie James 

Leslie James 

Executive Director 

Att: 3/10/2023 Letter 

Cc: CREDA Board 

WAPA Administrator Tracey LeBeau 

Wayne Pullan – Reclamation UC Region 

Rodney Bailey – WAPA CRSP Management Center 

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CREDA 

Colorado River Energy Distributors Association 

May 6, 2016 

Glen Canyon Dam LTEMP Draft EIS 

Argonne National Laboratory 

9700 South Cass Avenue -EVS/240 

Argonne IL 60439 

VIA US MAIL/RETURN RECEIPT REQUESTED 

The Colorado River Energy Distributors Association (CREDA) submits the following 

comments on the Long-Term Experimental and Management Plan (LTEMP) Draft 

Environmental Impact Statement (DEIS), (81 FR 963, January 8, 2016). General and topical 

comments are addressed herein, including supporting documentation. Additional detailed 

questions and comments are included in redline/strike-add versions of some of the DEIS 

Chapters and Appendices which are also included in this submittal (see Table B). Given the 

restrictions associated with public comment submittal on the DEIS, CREDA materials were 

unable to be submitted on the online website and are therefore being mailed in paper copy via the 

US Mail, and a DVD containing all the documents has been sent via FedEx overnight delivery. 

Notwithstanding the comment deadline of May 9, 2016, given the magnitude and 

complexity of the documents submitted to the public for review (over 2,000 pages) and the 

relatively short review period, CREDA reserves the right to supplement these comments, and 

request that this complete set of materials be included in the administrative record for the 

LTEMP EIS. Materials cited in the footnotes are incorporated within these comments as if they 

were quoted in full. Assuming only a 30-day period between issuance of the Final EIS and the 

Record of Decision, as well as the length and complexity of the DEIS, CREDA requests that any 

revisions to the DEIS included in the final EIS be made available to the public in a track changes 

version concurrently with issuance of the Final EIS. 

CREDA Background 

CREDA’s mission is “To preserve and enhance the availability, affordability, and value 

of Colorado River Storage Project facilities while promoting responsible stewardship of the 

Colorado River System.” CREDA is a non-profit, Colorado corporation, also authorized to do 

business in Arizona, formed in 1978 as an association of non-profit entities who are long-term 

wholesale customers for resources of the Colorado River Storage Project (CRSP). CREDA 

members serve over 4.1 million consumers in six states: Arizona, New Mexico, Nevada, 

Colorado, Utah and Wyoming. CREDA members include joint action agencies, state agencies, 

political subdivisions, tribal utility authorities, municipalities, rural electric cooperatives and 

irrigation and electrical districts. 

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CRSP customers (who are non-profit entities), pay all the power costs of the CRSP, 

which includes construction (with interest), operation, maintenance and replacements, 

transmission as well as irrigation assistance costs beyond the ability of the irrigators to pay. 

CRSP power revenues also fund non-power programs such as the Salinity Control Program, Glen 

Canyon Dam Adaptive Management Program (GCDAMP) and the Upper Colorado River 

(UCRIP) and San Juan River (SJRRIP) Endangered Fish Recovery Implementation Programs. 

CREDA has represented “contractors for the purchase of Federal power produced at Glen 

Canyon Dam” pursuant to the section 1805 (c)(4) of the Grand Canyon Protection Act of 1992 

(GCPA) on the Glen Canyon Dam Adaptive Management Work Group (AMWG) and the 

Technical Work Group (TWG) since inception, and is a partner in the UCRIP. CRSP power 

revenues are currently the primary funding source of these non-power environmental programs. 

Three CREDA members are Cooperating Agencies in the LTEMP process. 

CREDA and its individual members (see Table B) are key stakeholders in this process 

and have a unique, direct and economic interest that cannot be represented by any other 

stakeholder or participant in the LTEMP process. Given these interests, CREDA requests that 

these comments and individual CREDA member comments be given serious consideration in 

this process. 

SUMMARY POINTS 

I. Of the Alternatives considered in the DEIS, CREDA recommends that the Secretary of 

the Interior select Alternative B, (Balanced Resource), in the Final EIS. Alternative B as 

analyzed outperforms all other action alternatives for nearly all resources, and is the only 

action alternative that addresses the stated hydropower objective of the LTEMP EIS. 

If the Secretary selects an alternative other than Alternative A (No Action), issues raised 

in this letter, including the following, must be addressed: 

a. Eliminate the low summer flow experiments; 

b. Revise the daily fluctuation factors to reflect those contained in Alternative E 

(Resource Targeted Condition Dependent Alternative); 

c. Do not include the 8,000 cfs cap on daily fluctuations; 

d. Reduce High Flow Experiment (HFE) frequency to a level such as is 

contained in Alternative B (no more than one HFE every other year). 

These and other requirements will be described in more detail, and are based on the 

following reasons, among others: 

A. Alternatives A (No Action) and B (Balanced Resource) are the only Alternatives that 

address the stated hydropower objective of the LTEMP EIS. Moreover, Alternative B 

increases the endangered Humpback Chub (HBC) population and represents 

significantly less air emissions than Alternative D (Preferred). 

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B. Alternative D includes elements that violate the requirements of the Endangered 

Species Act because they are not based on sound science and will cause jeopardy to 

the HBC. 

C. Alternative D increases air emissions compared to Alternatives A and B, while 

further restricting carbon-free Glen Canyon Dam hydropower generation. 

D. The DEIS analysis significantly understates the impacts to the Glen Canyon Dam 

hydropower resource. 

II. The DEIS does not meet the requirements of the National Environmental Policy Act 

(NEPA) because it is based on a systemic and positive bias in the description and 

analysis of sediment, and a systemic and negative bias in the description and analysis of 

hydropower. These biases are evident in all aspects of the DEIS process, including 

scoping, the Structured Decision Analysis (SDA) process, the assumptions and metrics 

utilized in the selection of alternatives and analysis of the environmental impacts of the 

alternatives. DEIS. This systemic bias results in a skewed and fundamentally flawed 

analysis that does not provide the “hard look” at the alternatives considered for the 

proposed action. 

III. Alternative D violates the requirements of NEPA because it contains experiments or 

other proposed actions that are not adequately defined or analyzed. The use of adaptive 

management without definite, certain, or enforceable criteria or standards for each 

experiment is arbitrary and capricious. References to “adaptive management” cannot 

substitute for a full and accurate disclosure and analysis of the environmental and other 

impacts of all of the elements of the proposed action. The DEIS is also legally 

inadequate because experiments must be defined by a description of the proposed 

experiment, the time or frequency of implementation of the experiment, and the triggers 

or other conditions that must exist prior to implementation of the experiment. In 

addition, the DEIS fails to consider the cumulative impacts of experiments or 

combinations of experiments and the relationship between experiments and reasonably 

foreseeable hydrologic conditions. Each experiment must also include a description of 

the hypotheses that will be tested by the experiment and benchmarks or other identifiable 

criteria that will allow the Secretary and interested parties to assess the results of the 

experiment or when an experiment must be terminated because of unacceptable impacts 

to the endangered HBC or other legally protected resources. Finally, any monitoring 

included in the description of Alternative D is so poorly defined that it fails to meet legal 

standards necessary to implement adaptive management as a part of the LTEMP. See 

“Adaptive Management – The US Department of the Interior Technical Guide”

(https://www.doi.gov/sites/doi.gov/files/migrated/ppa/upload/TechGuide.pdf) and United 

States Department of the Interior Environmental Statement Memorandum No. ESM 13-

11, January 7, 2013. 

IV. The “Purpose and Need” (Section 1.2) is legally flawed because it identifies objectives 

that are not defined in a quantitative manner or use metrics or other numeric criteria that 

allows decision makers and the public to understand the nature of the “conditions” that 

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are to be “improved” or to assess the success or failure of experiments or management 

measures implemented as a part of a “Long-term Experimental and Management Plan”. 

V. The Alternatives Analysis in the DEIS is legally deficient because it fails to include all 

reasonable alternatives or improperly excluded alternatives from further consideration in 

the DEIS. For example, non-flow alternatives to the objectives of the proposed actions 

are either not considered or were improperly eliminated from further consideration in the 

DEIS, including mechanical means of sediment augmentation that are used elsewhere in 

the Colorado River basin; the use of a temperature control structure to manage 

temperature as is used on a number of large dams in other locations, sediment 

augmentation on Colorado River tributaries located downstream of Glen Canyon Dam, or 

the use of stocking or other management techniques to enhance the foodbase for 

endangered HBC and rainbow trout. Moreover, the DEIS fails to include and fully 

analyze the alternative of either maximum hydropower releases or an experiment that 

would test maximum hydropower releases and provide a means to compare the impacts 

on resources from other measures included in the Preferred Alternative. 

VI. The DEIS is legally deficient because it fails to identify and analyze all direct and 

indirect effects of the Alternatives included in the DEIS. For example, while “passive 

use” valuation for recreation is included in the analysis, the LTEMP DEIS fails to include 

and analyze available information on passive use valuation for hydropower and water 

resources. 

VII. The DEIS is legally deficient because it relies on an inadequate and incomplete analysis 

of hydropower developed for the SDA process. 

Hydropower and the Hydropower Objective 

“Hydropower provides a wide range of benefits to the country. It is a clean, low-cost 

source of energy that can be relied upon for long-term, stable production of domestic energy.”1 

Over the past 25 years, electrical demand in the West rose at nearly twice the rate (140%) of the 

population growth (71%), with the population expected to increase another 54% by the year 

2030.2 “If we are to achieve any of the low-carbon goals we have set out for 2030 and beyond, 

hydropower must increase significantly....” 3 At the 2015 National Hydropower Association 

(NHA) annual conference, DOE Secretary Moniz “agreed, saying ‘hydropower can double its

contributions by the year 2030. We have to pick up the covers off of this hidden renewable 

that’s right in front of our eyes and continues to have significant potential.’”4 Hydropower has 

been labeled the “most successful form of renewable energy.”5 Now is not the time to further 

reduce or continue to unnecessarily restrict generating capacity at Glen Canyon Dam. 

1 See CREDA LTEMP EIS Scoping Comments, January 31, 2012, p. 5, citing: Memorandum of Understanding for Hydropower 

Among the Department of Energy, the Department of the Interior and the Department of the Army, March 24, 2010, 

2 See Energy Information Administration, Annual Energy Outlook 2006 with Projections to 2030, (Feb. 2006), 3 See Conca, James (contributor), Could Hydro Flood America with New Power?, Forbes, November 20, 2015, p. 1 4 Ibid, p. 2 5 See Report of the Energy Policy Development Council, May, 2001, pp. 5-19 

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However, as currently constructed, “all but one of the LTEMP EIS alternatives chosen 

for analysis result in degradation of the value of the Glen Canyon Dam as a renewable 

hydropower resource.”6 , and there is no consideration of enhancing the resource to its full 

capacity. Yet, Section 101(b) of the National Environmental Policy Act (NEPA) provides: 

(I)t is the continuing responsibility of the Federal Government to use all 

practicable means, consistent with other essential considerations of national policy, to 

improve and coordinate Federal plans, functions, programs, and resources to the end that 

the Nation may: 

6. enhance the quality of renewable resources and approach the maximum 

attainable recycling of depletable resources. (42.U.S.C. 4331(b) (6).) 

A stated objective of the DEIS is to “maintain (or/and)7 improve hydropower” stemming 

from the “generation of hydropower” contained in the Purpose and Need Statement (76 FR 129, 

July 6, 2011), which reflects the Secretary’s obligation to fulfill multiple and sometimes 

competing statutory requirements applicable to the operation of Glen Canyon Dam and the 

exercise of other authorities as required by the provisions of the Grand Canyon Protection Act 

(GCPA). The United States has described the relationship between the objectives of the GCPA 

and the Colorado River Storage Project Act (CRSPA) as being “in addition to rather than in 

substitutions of the Secretary’s obligations concerning the operations of Glen Canyon Dam for 

hydropower and other project purposes.”8 The U.S. District Court for the District of Arizona 

further clarified that the broadly worded provisions of the Colorado River Storage Project Act 

(CRSPA) and GCPA impose on the Secretary an obligation to balance many different interests in 

operating Glen Canyon Dam. The Secretary must continue to recognize that power production is 

still a primary purpose of the Dam that must be balanced against other purposes, statutory 

requirements, and water delivery obligations as (s)he considers actions to implement the GCPA.

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Sediment is Not a Legally Protected Resource 

The Department of the Interior has directed, facilitated and recognized Desired Future 

Conditions (DFCs) for managing resources, including a Power DFC, which includes 

“maintaining and increasing” (emphasis supplied) the hydropower resource.

10 A DOI objective 

stated “Phase 1 objectives will provide the objectives against which to test alternatives in the EIS

process for the LTEMP.”11 The “final Desired Future Conditions for the Glen Canyon Dam 

Adaptive Management Program (AMP) constitute the goals for the operations of Glen Canyon 

Dam, and will provide essential guidance for the AMWG as it develops recommendations for the 

6 See Sullivan, John F. (SRP) letter to Michael A. Connor, August 8, 2014, p. 3 7 “And/or” appear to be used interchangeably in the LTEMP DEIS. The Power DFC, (approved by AMWG and recognized by

Secretary Salazar in early 2012), contained “and”. 8 See Grand Canyon Trust v. US Bureau of Reclamation, 623 F.Supp.2d 1015, 1036, Federal Defendants’ Reply Memorandum In

Support of Cross Motion for Summary Judgment on Claims 6-8 at p. 26, lines 25-27, (February 20, 2009) 9 See Colorado River Basin State Representatives to LTEMP EIS Scoping, January 31, 2012 10 See LTEMP EIS, Appendix A, A-11, line 37 11 See Glen Canyon Dam Adaptive Management Work Group Agenda Item Information Form (AIF), February 3-4, 2010, p. 2 

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Secretary of the Interior.” 12 The Colorado River Basin States described the DFC process 

outcome: “The DFCs are the result of extensive stakeholder consultation and reflect both the 

ideas and wording to balance the conflicting interests represented by the AMWG.”13 

During development of the AMWG’s DFCs there was discussion about whether sediment 

should be a separate DFC, as proposed by DOI.14 The DFC Ad Hoc Group, which included 

representatives of all DOI AMWG representatives, concluded that it should not; rather, sediment 

is a “means to an end” for protecting and improving downstream resources, and sediment is one

aspect of the Colorado River Ecosystem (CRE). The “ecosystem is generally an area within the 

natural environment in which physical (abiotic) factors and processes of the environment, such 

as geology, climate, and soil development, function along with interdependent (biotic) 

organisms, such as plants and animals, in the same habitat and create a dynamic and 

interconnected system.”15 Notwithstanding this history and the lack of any legal basis for 

identifying sediment as an independent resource, the DEIS inappropriately identifies sediment as 

an independent and priority resource. 

The DEIS is Legally Inadequate because it Relies on Flawed Structured Decision Analysis 

The SDA that was performed during the LTEMP EIS process “helped inform the analysis 

of the joint-lead agencies.”16 Appendix C of the LTEMP EIS describes the SDA process 

undertaken by DOI during 2013 and 2014. CREDA participated throughout the process, 

continuing to express concern that “many or most of those alternatives would additionally 

restrict hydropower generation for the purpose of attaining sediment objectives that are not 

adequately supported by available science or required and authorized by applicable law.”17 

Specific to the hydropower Performance Metric, because of the varying degrees to 

which “swings” and “weights” are established for the various performance metrics, the 

hydropower metric is automatically given less weight than other metrics. The swing weighting is 

set up in such a way that sediment is weighted far more importantly than hydropower. 

Hydropower has a swing range of $80 million, while the differences between alternative mean 

values is $9.4 million, or 12% of the total swing range. Sand Load Index has a swing range of 

0.6, while differences between alternative mean values is .5, or 88% of the total swing range. 18 

Since swing range is multiplied by weight, the greater the swing range, the more weight a metric 

will ultimately have. The end result of this selection of swings and weights is that, if hydropower 

is valued at 100% and sediment at 50%, with all other metrics set at 0, the best option for 

hydropower, (B2), is ranked 12th out of 19 alternatives. 

12 See Glen Canyon Dam Adaptive Management Work Group Agenda Item Information Form (AIF) and attachment, August 24-

25, 2011, p. 2 

13 See Colorado River Basin State Representatives letter and attachments to Ass’t. Secretary Castle, April 15, 2013 14 Ibid, AIF, 2010 15 See, Castle, Anne memo to Salazar, February 23, 2012, p. 4, citing attached August 19, 2011 memo to AMWG, p. 2 16 See LTEMP EIS, Chapter 1, p. 18 17 See CREDA letter and attachment to LTEMP EIS Team, April 14, 2013 18 See LTEMP DEIS, Appendix C, Table 1 

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A “system of ranks and scores oversimplifies complex interactions of components 

within each alternative and does not fully account for nuances of some alternatives.”19 As 

recommended by Western Area Power Administration, “the consequence tables could be 

modified to more clearly reflect stakeholder values.20” The caveats noted on page 69 of 

Appendix C are fair, but a clear statement such as that contained on page 68: “Among the 

participating agencies, three alternatives rose to the top: Alternatives B, D, and G.” should be 

highlighted as a key result of the SDA process. This statement clearly reflects the viewpoints of 

those stakeholders participating in the SDA processes. The swings and weights attributed to 

sediment and hydropower resources and the depiction of SDA results clearly show a bias in 

favor of sediment and against hydropower; the fact that Alternative B still performed “on top”

despite the heavily favored sediment metrics shows the strength of Alternative B. 

The DEIS is legally deficient because it does not accurately characterize a study used to 

support the flow factor/fluctuation index utilized in Performance Metric 12 of swing weighting. 

The Fluctuation Index utilizes information derived from a 1987 study (Bishop et al),

21 which 

addressed recreational user preference for fluctuating flow levels. In that study, however, 10,000 

cfs (not 8,000 cfs) was defined as “constant flows”. And yet, there appears throughout the DEIS 

what CREDA believes to be misinterpretation of these data, and a reliance on this 

misinterpretation as justification for including an artificial 8,000 cfs cap on fluctuations as part of 

Alternative D, in order to benefit the sediment resource. In addition, the difference in sediment 

transport between, for instance, 8,000 cfs and 10,000 cfs is negligible and within the error of the 

model forecasting error. However, the difference in impact on hydropower between an 8,000 cfs 

cap and a 10,000 cfs cap is material. A confounding factor in determining sediment “benefit”

ascribed to the flow fluctuation factor is monthly volumes. Higher monthly volumes increase 

transport. However, “It was not possible to reconcile the relative importance of daily fluctuations 

and monthly volume allocations without additional modeling”.

22 In fact, in the Bishop study, 

“moderate daily fluctuations” of 8,000-25,000 cfs were the most preferred of four different flow 

scenarios.”23 The flow factor/fluctuation index analysis used in the DEIS is unsupported 

scientifically and results in an unnecessary restriction on hydropower operations.24 This 

restriction cannot be shown as necessary to achieve the CRE DFC to “maintain adequate sand 

bars (including camping beaches) for recreation in” GCNRA and GCNP.25 

Basing DEIS analysis on simplified models and metrics for some (but not all) of the 

resources analyzed in the DEIS renders it inadequate. Specifically for the hydropower resource, 

Appendix C “acknowledges that it was not complete.”26 Indeed, the DEIS continued to use the 

SDA analysis in some cases, which CREDA believes demonstrates the bias against hydropower 

and results in understated results for hydropower. At least for the hydropower resource, the SDA 

analysis cannot and should not supplant robust analysis that utilizes a realistic set of assumptions 

and produces a range of results. 

19 See Western Area Power Administration letter to LTEMP EIS Team, August 23, 2013, p. 5, B.2 20 Ibid, p. 5, B.5. 21 Ibid, Appendix C, P. C-27, section 4.5 22 See LTEMP DEIS, Appendix E, p. 14 23 See Bishop, et.al. (1987), Grand Canyon Recreation and Glen Canyon Dam Operations: An Economic Evaluation, p. 67 24 See SRP, Bishop Study vs. DEIS Representation, transmitted November 18, 2015 25 Ibid, AIF DFC attachment, August 24-25, 2011, p. 3 26 See CREDA letter to LTEMP EIS Team, August 23, 2013 

7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D Effects on Downstream Resources 

During development of Alternative D, information was presented to the AMWG and TWG 

in early 2015. Based on the conceptual and descriptive information provided at that time, 

CREDA provided comments, expressing concern that not only did the hydropower resource 

appear to be negatively impacted, but that Alternative D “does not appear to benefit any resource

compared to current dam operations other than resources associated with Sand Load Index.”27 

Even some resources purported to be protected and improved by greater Sand Load Index 

may not benefit from sand on beaches. The DEIS states that “there is no published research for 

the direct impact of wind transport of sediment under MLFF on archaeological sites within the 

river corridor,”28 and “Research would be needed to determine the number of days of high flow 

that would produce noticeable or extensive impacts on cultural sites,”29 Still, Sand Load Index is 

touted as a metric that is important in Aeolian or windborne sediment transport to benefit 

cultural sites. Considering this and other modeling assumption issues, and using LTEMP EIS 

data (with page references), Table A displays the relative performance among Alternatives A, B 

and D for DEIS resources. 

Table A highlights the fact that the selection of Alternative D as the Preferred Alternative 

is arbitrary and capricious. Alternative D requires trout removal in over half the years to 

achieve a very small improvement in HBC, which raises cultural issues identified by the Pueblo 

of Zuni (and other Tribes).30. Alternative D is worse than No Action for reducing both recreation 

value and number of annual rafting visitors. Alternative D increases GHG emissions four times 

more than Alternative B. 

Table A 

Key Resource Comparison – Alternatives D and B to No Action 

Orange=Worse than No Action (A) 

Green=Better than No Action (A) 

Resource/(DEIS page) Alternative A Alternative D 

(“Preferred

Alternative”)

Alternative B 

Humpback Chub (4-108) 5,000 average 

minimum adult 

population of 

humpback chub 

without need for trout 

culling 

Slightly more humpback 

chub with 5,200, but need to 

cull trout 53% of years to 

get the higher humpback 

chub population 

More humpback chub 

with 5,400, but need 

to cull trout 15% of 

years to get the higher 

humpback chub 

population 

27 See CREDA letter to LTEMP EIS Team and attachment, May 1, 2015, Appendix A 28 See LTEMP DEIS Appendix H, p. H-5 29 Ibid, p. H-9 30 See Panteah Sr., Val, letter to Glen Canyon Dam LTEMP Draft EIS (Argonne National Laboratory), May 4, 2016 

8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Resource/(DEIS page) Alternative A Alternative D 

(“Preferred

Alternative”)

Alternative B 

Other Fish (4-107-109) No change from 

current levels 

Slightly more nonnative and 

native fish 

Slightly fewer 

nonnative fish; similar 

levels of native fish 

Air Emissions (4-373, 

http://www.epa.gov/energy/ 

greenhouse-gasequivalencies-calculator) 

No change from 

current emissions 

22,908 MT per year 

increase in air emissions: 

equivalent to 24.6 million 

pounds of coal burned per 

year, or 492 million pounds 

of coal burned over the 20 

year period. 

5,900 per year 

increase in air 

emissions: equivalent 

to 6.3 million pounds 

of coal burned per 

year, or 127 million 

pounds of coal burned 

over the 20 year 

period 

Trout (4-106-4-107, 4-245, 4-

259) 

95,000 average trout 

population; 770 large 

trout; need to cull trout 

<1 out of 20 years; 

37,000 trout emigrate 

from Glen Canyon 

Slightly smaller trout 

population with 93,000 

average; slightly more large 

trout with 810; need to cull 

trout 10.5/20 years; slightly 

lower angler satisfaction; 

41,000 trout emigrate from 

Glen Canyon 

Smaller trout 

population with 

74,000 average; more 

large trout with 870; 

need to cull trout 3/20 

years; slightly lower 

angler satisfaction; 

30,000 trout emigrate 

from Glen Canyon 

Archeological Resources (4-

221-223) 

Some additional sand 

for wind transport to 

archeological 

resources; No change 

in detrimental values 

to Spencer Steamboat; 

No additional 

slumping of terraces 

on which 

archeological 

resources are located 

More additional sand for 

wind transport to 

archeological resources; 

Potentially increases risk of 

degradation of Spencer 

Steamboat; Possibility of 

destabilization of terraces 

on which archeological 

resources are located 

Some additional sand 

for wind transport to 

archeological 

resources; No change 

in detrimental values 

to Spencer Steamboat; 

No additional 

slumping of terraces 

on which 

archeological 

resources are located 

Camping Beaches (4-261) Camping beaches 

would be similar to 

how they are today; 

would continue longterm decline 

Would help expand 

camping beaches, with an 

index from .14 to .36 (no 

explanation of what the 

index means.) 

Camping beaches 

would be similar to 

how they are today; 

would continue longterm decline, but 

better than No Action 

9 
Resource/(DEIS page) 

Recreation Value (4-336, 4-

262, 4-246) 

Rafting (4-283-284, 4-260) 

Retail Rates (4-332, 4-309, 

Appendix K-175) 

Alternative A 

$14,619 Million per 

year mean annual net 

economic value 

Baseline 

No change in 

hydropower value, 

retail rates, or capacity 

expansion 

Alternative D 

(“Preferred

Alternative”)

$32.2 Million per year 

decrease in net economic 

HFEs: detriments to tribal 

facilities at Pearce Ferry 

Decreased crowding at 

beaches; increased 

disturbance from non-flow 

actions; reduce rafting 

visitors by 299 

.39% increase in average 

retail rates (4-309), with 

tribal utility rates having a 

greater increase than the 

average customer (4-332); 

Total tribal impact is a 

detriment of $609,463. Loss 

of capacity would result in 

an extra gas turbine being 

Alternative B 

$21.8 Million per year 

decrease in net 

lower Grand Canyon 

and slightly more 

on park facilities at 

Pearce Ferry from 

Similar to Alternative 

A for crowding at 

beaches; more 

encounters with other 

groups at rapids due to 

low flows; more daily 

from non-flow actions 

.27% decrease in 

average retail rates, 

with tribal utility rates 

having a greater 

decrease than the 

average customer; 

Total tribal impact is a 

benefit of $336. No 

extra gas turbine 

built, which is bad for the needs to be built, 

environment but good for 

the economy (4-332). 

which is good for the 

environment but bad 

for the economy (4-

$104 million detriment $16 million benefit 

.53 Sand Load Index; -1,480 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Hydropower Value (4-308) 

Sediment (4-69) 

Vegetation (4-159-161) 

No change 

.21 Sand Load Index; 

-1,010 Sand Mass

Balance

55.2 acre decrease in 

native plant 

community cover; 1.3 

acre decrease in 

wetland community; 

2% decrease in native 

diversity; 5% increase 

in ratio of native to 

Sand Mass Balance 

(decrease of 470 kilotons) 

39.5 acre decrease in native 

plant community cover; 0.8 

acre decrease in wetland 

community; 2% increase in 

native diversity; 5% 

decrease in ratio of native to 

nonnative vegetation; 10% 

decrease in arrowweed 

332). 

.23 Sand Load Index; 

-1,810 Sand Mass

Balance (decrease of

800 kilotons)

48.3 acre decrease in 

native plant 

community cover; 0.9 

acre decrease in 

wetland community; 

3% increase in native 

diversity; 15% 

increase in ratio of 

10 

value; From increased 

recreation - detrimental 

Grand Canyon and 

detrimental impacts on park 

sediment impacts in lower 

from increased HFEs. 

marina income. 

Negligible decrease in 

economic value; From 

slightly increased 

HFEs: detriments to 

slightly detrimental 

sediment impacts in 

detrimental impacts 

slightly increased 

HFEs. 

tribal recreation –

possibility for 

fluctuations; slightly 

increased disturbance 
Resource/(DEIS page) Alternative A Alternative D Alternative B 

(“Preferred

Alternative”)

nonnative vegetation; native to nonnative 

25% increase in 

arrowweed increase in arrowweed 

Special Status Plant Species Negative impact on Similar to Alternative 

(4-161) wetland species A 

Negligible difference 

vegetation; 19% 

Decline compared to 

Alternative A; negative 

impact on wetland species 

and potential impacts on 

active floodplain species 

from HFEs 

Foodbase (4-104) No change until 2020; 

after 2020 fewer HFEs 

may lower blackfly 

and midge production, 

and decrease drift 

Potential increase in 

blackfly and midge 

production; potential 

increase in productivity and 

diversity; Increased drift 

production; increased 

Water Quality (4-16) Baseline Increased for bacteria and 

pathogens from increased 

water temperature 

Note: water temperature 

increase is 0.4°C 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternatives A and B are the only Alternatives that currently address the stated 

hydropower objective of the LTEMP EIS. During development of Alternative D by the 

Department, CREDA repeatedly raised concerns about Alternative D performance for many 

31 resources. 

Humpback Chub and Flows 

In a 2005 USGS publication, based on research by the Grand Canyon Monitoring and 

Research Center (GCMRC), it was hypothesized that a downward trend in the HBC population 

may have coincided with initiation of interim operating criteria and ROD flows.32 However, 

since publication of that report, significant new science and information has been developed and 

which indicates the humpback chub population is “a persistent and increasing reproducing 

population...in the Grand Canyon.”33 In the most recent AMP Report to Congress, “it is 

apparent that abundance of adult chub has increased or remained stable at all aggregations since 

sampling began in the 1990s”.34 One of the likely sources consulted in developing that Report 

was USGS’ Fact Sheet35, describing the continuing upward trend of HBC. “This continuing 

upward trend should be a major factor in assessing any experimental or management action 

which could negatively impact this endangered species.”36

31 See CREDA letter to LTEMP EIS Team, Appendix B, July 8, 2014 32 See SCORE Report, USGS Circular 1282 (Oct. 2005), page 45, Figure 12 33 See LTEMP Public Scoping document “Aquatic Ecology”, November 2011; www.ltempeis/anl/gov (accessed May 5, 2016) 34 See http://www.usbr.gov/uc/envdocs/reports/GCDam/GC-Report-to-Congress2013-2014.pdf 35 See USGS Humpback Chub Status and Trends Fact Sheet, 2009/3035, http://pubs.usgs/gov/fs/2009/3035/ 36 Ibid, CREDA letter, January 31, 2012, p. 3 

11 

Slightly lower benthic 

activity; may decrease 

blackfly and midge 

drift 
 

 

 

 

 

 

Alternatives and elements of alternatives containing steady flows should be rejected, 

as they increase threats to the endangered HBC. Steady(ier) flows following HFEs and a 

proposed low summer flow experiment (LSF) contained in Alternative D fall into this category. 

These flow regimes also negatively impact the hydropower resource and air emissions. 

Potential threats to the endangered HBC must be assessed and compared to any 

demonstrated benefit from steady flows. “A summary of some of the supporting science relating 

flows and temperature to HBC habitat, food base and predation/competition (including sources) 

includes: 

• Prior to the 2008-2012 Grand Canyon Near Shore Ecology Study, it was believed that 

high flow experiments (HFEs) were necessary to create backwater habitats for HBC. The 

Near Shore study included steady flows in the fall timeframe over a 5-year period. The 

study disproved this prior scientific assumption; HBC neither need nor desire backwater 

habitat. Habitat is a necessary element for HBC success. HBC occupy eddy habitats and 

talus shorelines, but are apparently selective for backwater habitats, and there are similar 

daily movements and habitat use between flow events” (Pine). As a result of this study, it

appears efforts specifically directed at creating backwater habitat for HBC is 

unnecessary. 

• The science shows that steady flows slow the growth rates of the HBC, introducing 

additional predation risk. The Near Shore results demonstrated “juvenile HBC survival 

in the mainstem is very high; no obvious changes in survival occurring during flow 

experiment.” (Pine). Fall steady flows don’t increase HBC survival. In fact, “fish 

growth rate actually declined during fall (steady flows) from summer (fluctuating flow).”

(Pine). Steady flows slow HBC growth rate. 

• Sufficient food base is necessary for HBC success. “Sediment effects on food base

causes decreased autotrophic production.” (Yard). “Further constraining hydropeaking 

may not lead to measurable benefits to fish.” (Kennedy). Steady flows may not benefit 

fish due to impacts to the food base. 

• Appropriate water temperature is necessary for HBC success. “No significant difference 

in release water temperature has been recorded whether the releases are steady or 

fluctuating.” (Anderson and Wright). Volume, not fluctuations, is the strongest factor in 

downstream temperatures. In addition, the 2000 Low Steady Summer Flow Experiment 

resulted in high survival of young-of-year trout (Speas), which means that low steady 

flows adversely affect HBC.”37 

The risk to endangered HBC from warm water nonnative fish has long been 

acknowledged. The 2005 Knowledge Assessment found that “improvements in young-of-year 

survival rate or adult growth could be offset by an increased incidence of disease or an increase 

37 See CREDA letter to the Department, February 17, 2012, p. 1; and CREDA letter to the Department, April 9, 2014, p. 2 

12 
 

 

 

 

 

 

 

 

 

 

 

 

 

in the abundance of warm water nonnative fish which compete with and prey on humpback chub 

and other native fishes”38 . 

A recently published report using results of the AMP’s 2008-2012 Nearshore Ecology 

study, concludes “We found that juvenile humpback chub mean daily growth rates in the

Colorado River were lower during steady flows than fluctuating flows when they occurred in the 

same season”.39 It is not clear that this, and other publications stemming from the Nearshore 

Ecology study, were available and considered at the time the LSF experiment or other steady 

flow regimes were incorporated into Alternative D. Additional publications by Finch et al. from 

this study were cited by the Colorado River Basin States in materials supporting development of 

Alternative E. “Fall steady flows (2008-2012) showed reduced growth and no significant 

difference in survival of juvenile humpback chub during the FSF compared to other flows”

(Finch 2012), and “Low steady flows could benefit warmwater nonnative fish and result in a 

rapid expansion of unwanted species throughout the canyon. (Valdez and Speas 2007)”40 “The

risk to humpback chub and other native fishes viability is high if a highly predaceous or 

competitive species were to suddenly expand in abundance and range in the Colorado River 

through Grand Canyon. We strongly urge the LTEMP Team to give strong consideration to 

minimizing the possibility for such an event.”41 

During development of the NPS’ Comprehensive Fisheries Management Plan 

Environmental Assessment, CREDA objected to the inclusion of “low summer flows” for 

multiple reasons, including lack of support by peer-reviewed science and continued uncertainty 

around the relationship between ‘warmer water to enhance Humpback Chub (HBC) spawning 

rearing, and survival in the mainstem Colorado River’.”42 

A growing body of science prior to and since the 1996 Record of Decision supports 

CREDA’s concerns associated with steady (ier) flows and their impacts on endangered HBC. In 

2012, CREDA expressed similar concerns associated with the Finding of No Significant Impact 

(FONSI) issued for the High Flow Experiment (HFE) Protocol. These concerns remain 

regarding continuation and expansion of HFEs, both in terms of frequency and duration, as well 

as other proposed experiments and operations included in Alternative D. “HFEs scour and 

remove the food base and it takes one to one and one half years for it to recover to pre-HFE 

levels. This is a result of the loss of the main algal base, Cladophora, which provides the base on 

which diatoms are nurtured. The Diatoms form the food for Gammarus (scuds) which have been 

the main food source for trout and downstream HBC. If it takes one to one and one half years for 

the food base to build back up and we have recurring HFEs every year or even every six months, 

there is little opportunity for the Cladophora/ Gammarus food base to recover. Steady flows are 

also a contributor to the food base concern. Without periodic higher flows, as under steady flows, 

the Cladophora productivity rate declines as the algae can become senescent. These old growths 

38 See, 2005 Knowledge Assessment of the Effects of Glen Canyon Dam on the Colorado River Ecosystem: an experimental 

planning support document; prepared by Theodore S. Melis, Scott A. Wright, Barbara E. Ralston, Helen C. Fairley, Theodore A. 

Kennedy, Matthew E. Andersen and Lewis G. Coggins, Jr. (GCMRC), in cooperation with Josh Korman, Ecometric Research, 

Inc., final draft, August 30, 2006, p. 37 

39 See Finch, C., Pine III, W., and Limburg, K.E., “Do Hydropeaking Flows Alter Juvenile Fish Growth Rates? A Test with 

Juvenile Humpback Chub in the Colorado River”, pub. River Research and Applications (2013). 40 See Responses to July 8, 2013 DOI Comments on RTCD Revisions, Colorado River Basin States, September 9, 2013, p. 4 41 See Science Panel Evaluation of Performance Criteria and SDM, April 12, 2013, p. 7 42 See CREDA letter to National Park Service PEPC, re EA/Plan, June 10, 2013, p. 2; Appendix A, June 27, 2012 

13 
 

 

 

 

 

 

 

 

 

 

 

occupy space and yet grow at a slow rate. Ideally, we want young growths which are healthier 

and grow at a faster rate. Steady flows provide less drift and that, combined with the HFEs, 

means much less daily drift supplying food to downstream humpback chub.”43 Any selected 

Alternative should include no more than one HFE every other year. 

Given the legal mandate to protect endangered species, CREDA fails to understand how 

the LTEMP EIS record of decision can include experiments, operations or management actions 

that are “quite likely to come at the expense of negative impacts to an endangered species. This 

legal mandate should take precedence over the anticipated and uncertain benefits to resources 

that lack protection under the Endangered Species Act”44 (such as sediment). The DEIS also 

fails to address in detail a topic that was included during scoping, that of consideration of a 

recovery plan for the HBC. The HBC is the subject of a Species Status Assessment (SSA) 

process underway and being led by Region 6 of the USFWS. One of the potential uses for the 

SSA is the downlisting/delisting of the HBC. Several organizations that are participants in the 

AMP are also participating in various areas of the SSA, including both Regions 2 and 6 of the 

USFWS. Because any actions proposed to be undertaken through the LTEMP could have direct 

or indirect impacts to the development of and assumptions contained in the SSA, it is imperative 

there be close coordination between the SSA and the LTEMP EIS. To that end, both processes 

would be informed and improved if DOI would seek input from the expertise existing in the 

AMWG and TWG representatives on the draft Biological Assessment, as was done by 

Reclamation in 2008 for the LTEP (the predecessor to the LTEMP). This input could also 

improve and refine experimental treatments in the Preferred Alternative to clarify triggers, 

off ramps, monitoring and definitions of “success”.

Alternative D includes elements that pose an unacceptable risk to the endangered HBC. 

Low summer flow experiment(s), steady flows following HFEs, and fluctuation factors that 

are steadier than No Action should not be included in any selected Alternative. 

Air Quality Impacts and Climate Change 

Glen Canyon “(D)am operations can affect air emissions and ambient air quality over the 

11-state Western Interconnection, comprising Arizona, California, Colorado, Idaho, Montana, 

Nevada, New Mexico, Oregon, Utah, Washington, and Wyoming, because hydropower 

generation offsets generation from other non-hydropower generating facilities in the SLCA/IP 

and in the Western Interconnection”.

45 “The WECC has the lowest greenhouse gas loading per 

1,000 GWh of any NERC region in the US solely because of the large fraction of hydropower 

constituting the overall power mix (28 percent). Without Glen Canyon, an additional 2.4 million 

metric tons per 1,000 GWh would be emitted by the WECC.”46 Given the commitments of the 

Departments of the Interior and Energy to maintain and expand renewable generation capacity, 

the importance of hydropower capacity to the overall power supply for the western United 

43 Personal electronic communication, William E Davis, EcoPlan Associates, to Leslie James, March 31, 2016 44 See CREDA letter to Reclamation, May 11, 2012, p. 2 45 See LTEMP DEIS Appendix M, p. M-3 46 See Scientific Certification Systems, Life Cycle Impact Assessment (LCIA) of Glen Canyon Hydropower Generation System 

Compared to the WECC Baseline; Conducted in accordance with ISO 14044 LCIA Framework and the Draft SCS-002 Life 

Cycle Metrics Standard, Type III Life-Cycle Impact Profile Declarations for Materials, Products, Services and Systems, March 

2009, p ii 

14 
 

 

 

 

 

 

 

 

 

 

 

 

States, and the existing benefits of hydropower that avoids alternate fossil fuel greenhouse gas 

production47, strong consideration should be given to the air emission impacts resulting from 

HFEs. Hydropower is a very efficient way to produce electricity, showing emission factors 

between one and two orders of magnitude lower than the thermal alternatives.48 CREDA renews 

concerns that were expressed during Reclamation’s development of the HFE Protocol 

Environmental Assessment,

49 and previously in 2008.50 

The more frequent the number and duration of HFEs, the more greenhouse gas emissions 

are created, due to the unavailability of carbon-free Glen Canyon Dam hydropower when water 

bypasses the generators. Replacement power must be purchased, and carbon-free hydropower is 

not a resource that is available on the spot market to replace lost Glen Canyon Dam generation. 

Because HFEs are included in the DEIS baseline, all Alternatives increase greenhouse gas 

emissions. The increase ranges from 5,900 to 44,542 metric tons per year.

51 Alternative D, 

which averages more than 1 HFE per year for the 20-year DEIS period52, increases greenhouse 

gas emissions by 22,908 metric tons per year, nearly four times53 the level associated with 

Alternative A (the lowest greenhouse gas-producing Alternative due to the lowest frequency of 

HFEs). 

Given the heightened awareness and public interest in climate impacts, neither the 

LTEMP public information materials and presentation54 nor the US GHG emission metrics used 

to display results, is sufficient to fully disclose to the public or the Secretary a clear impact 

analysis. The reader and decision-maker should be able to determine, for example, whether the 

equivalent of burning an estimated 26.655 million pounds of coal is a “negligible” result, or an 

acceptable tradeoff for the number of HFEs included in Alternative D, which may or may not 

achieve the intended outcome. Analysis and disclosure of air quality results in the DEIS should 

be on the same basis as are other analyzed resources, e.g., regional or local, and not at a national 

level. Appendix M, Tables M-3 through M-8 should be summarized and included in Chapter 4 

of the Final EIS. 

LTEMP Hydropower Analysis 

As previously noted and discussed below, the treatment of hydropower in the DEIS 

demonstrates significant bias against the hydropower resource. CREDA continues to disagree 

with some of the analysis and data assumptions utilized in the hydropower analysis, as well as 

the presentation of results. From an alternative-to-alternative comparative standpoint, some of 

47 See New Energy Frontier. Balancing Energy Development on Federal Lands. A Joint Report to Congress on Siting Energy 

Development Projects on Federal Lands. U.S. Department of Interior and U.S. Department of Agricultural. May 2011, pp. 28-31, 

https://www.doi.gov/sites/doi.gov/files/migrated/whatwedo/energy/upload/NewEnergyFrontier050511.pdf 

48 See The Issue of Greenhouse Gases from Hydroelectric Reservoirs: From Boreal to Tropical Regions, Tremblay, et al., 

Abstract, p. 1; http://www.un.org/esa/sustdev/sdissues/energy/op/hydro_tremblaypaper.pdf 49 See CREDA letter to Larry Walkoviak (BOR), March 17, 2011, p. 4 50 See CREDA letter to Larry Walkoviak (BOR), February 22, 2008 51 See LTEMP DEIS, Chapter 4, Table 4.16.1 52 Ibid, Table E-9 53 Ibid, Table 4.16.1. 54 See http://ltempeis.anl.gov/documents/docs/LTEMP_DEIS_presentation.pdf (accessed April 13, 2016) 55 See Calculations from EPA: http://www.epa.gov/cleanenergy-resources/calculator.html#results 

15 
 

 

 

 

 

the data assumptions may be less impacting than others However, it is imperative that the 

public and the Secretary be fully apprised of the best available information and results so that 

informed trade-off decisions may be made in the development of a Final EIS and Record of 

Decision. 

Rather than attempting to summarize highly technical information herein, CREDA is 

attaching specific comments on various DEIS Chapters and Appendices in redline/strike-add 

format, as well as attaching previously submitted information that was developed in large part 

through CREDA utility members, who are subject matter experts in utility planning, operations, 

modeling and rate design. CREDA members Salt River Project and Utah Associated Municipal 

Power Systems are Cooperating Agencies in the LTEMP process; based on their feedback, their 

expertise and input was generally neither sought nor considered during development of 

alternatives or hydropower analysis. These utility expert cooperating agency members as well as 

other CREDA members have unique roles and customer load serving responsibilities that are not 

inherent or identical to those of federal agencies involved in LTEMP. 

Modeling Assumptions 

As stated earlier, CREDA believes that a combination of data inputs used in 

modeling, along with how and whether results of analysis are presented in the DEIS, 

demonstrate a clear bias against the hydropower resource. Examples include: 

A. Capacity Cost: DEIS assumptions utilized for capacity cost represent the 

most significant potential for impacting and disclosing hydropower impacts. Beginning 

with data used in the SDA process, the capacity cost assumptions have been significantly 

understated and not representative of what the utility subject matter experts have 

recommended be used in LTEMP. In the SDA process, “The replacement cost used was 

$50,100/MW-year based on a natural gas combustion turbine.”56 Yet, at the April 10, 

2014 SDA workshop, participants were advised that “a capacity value of $65,000/MWyear”57 would be used. At the workshop and immediately thereafter, CREDA 

recommended that “a more accurate estimate of the capacity value for a large natural gas 

combined cycle facility is in the range of $82,000/MW-year to $132,000/MW-year, based 

on utility and EPRI (industry) standards.58 CREDA has been advised that due to time and 

cost restrictions, Argonne National Labs was not directed to provide sensitivity analysis 

including the utility-recommended capacity cost information prior to issuance of the 

DEIS. CREDA has been advised this information could be developed through postmodel processing by the Western Area Power Administration and the utility 

cooperating agencies for inclusion in the final LTEMP EIS. A full range of 

hydropower impacts using at a minimum the hydropower utility experts’ capacity 

cost assumptions should be utilized in analysis and disclosed to the public and the 

Secretary prior to finalizing the LTEMP EIS. 

56 See LTEMP DEIS, Appendix C, p. C-27, Section 4.3 57 See CREDA letter to USGS and LTEMP Co-Leads, April 18, 2014, p. 2 58 Ibid, Appendix C, p. 41. 

16 
 

 

 

 

 

 

 

 

 

 

 

 

B. Other Hydropower Assumptions: Reserve/regulation level, exceedance 

level, and discount rate are all factors that are part of the wholesale power analysis. 

Individually, they may have modest impacts to the “bottom line”, but when taken 

together, they can potentially impact the ranking of Alternative performance results. The 

DEIS, unfortunately, uses as the “primary” data assumption for each category, the value 

that has the lowest impact on hydropower performance. Collectively, these choices 

continue to understate the impacts of Alternative performance on the hydropower 

resource. For example: 

i. CREDA expressed concern about the assumption and base level of ancillary 

services as described by Argonne National Labs at the February 2015 AMWG 

meeting. We appreciate that the MW level has been corrected and would not object 

to a range being displayed, if in fact the full hydropower analysis has been performed 

on both the 67 MW and 130 MW levels. 

ii. CREDA has continued to express concern about the assumptions used 

regarding exceedance level. “It seems more reasonable for a sensitivity analysis to be

based on a 50% to 99% range, so that the study can provide an upper bound economic 

impact associated with the alternative operating criteria.” Results showing 

exceedance levels ranging from 50-99% should be shown together in one place in the 

DEIS.

59 

iii. CREDA continues to believe that it is inappropriate that a federal discount rate 

be used as the “baseline” for discounting new capacity construction, since it would 

not be the federal government constructing the capacity. Alternatively, the DEIS 

could display results utilizing the federal rate alongside the results utilizing a nonfederal/utility rate for comparative purposes. This approach would be consistent with 

what Reclamation utilized in its Aspinall EIS; the DEIS approach is contrary to what 

was done in the Aspinall analysis and Final EIS.

60 

iv. Similar to the artificial 8,000 cfs cap on fluctuations, the proposal to suspend 

load following during the entire month after a fall HFE has neither sufficient 

scientific basis nor analysis to support inclusion in an alternative. “This is 

ambiguous and should be formally defined with scientific reasoning.”61 This 

restriction should be removed from any selected Alternative. 

One of the “Significant Findings” contained in a study assessing the

environmental attributes of Glen Canyon Dam hydropower on a life-cycle impact 

assessment basis finds “There is no evidence that allowing Glen Canyon power 

production to follow load would increase environmental impacts, including those to 

habitats and key species. In fact, removing generating restrictions would reduce 

WECC greenhouse gas emissions.” 62 This experiment should not be included in the 

LTEMP and the 8,000 cfs cap on fluctuations should be removed from Alternative D. 

59 See Poch and Veselka, Argonne National Laboratory, Responses to Peer Review Comments on the Hydropower Analysis 

Methodology for the Glen Canyon Dam Long-Term Environmental and Management Plan Draft Environmental Impact 

Statement, March 2016, p. 6 

60 See Reclamation, Aspinall Unit Operations FEIS, Appendix E, 2012 61 See Buckeye Water Conservation & Drainage District letter to LTEMP Draft EIS, March 30, 2016, p. 2 62 Ibid, Scientific Certification Systems, p. ii 

17 
 

 

 

 

 

 

The DEIS methodology includes no escalation of the overnight capital cost of 

replacement capacity construction, yet the total costs are discounted to net present 

value. “Discounting is to be used to convert future monetary values to present 

values”63 Further, the analysis results assume that new capacity would be needed as 

early as 2017 due to operational change anticipated by the DEIS. Escalation should 

be included in the analysis; in reality, however, the type of capacity assumed by the 

wholesale power analysis to be constructed cannot be done by 2017. The result of 

both these issues is an understatement of costs in both cases. 

Consistent with previously completed Reclamation EISs, CREDA requests that 

the full range of sensitivity analysis be disclosed for these factors, similar to what was 

done for the sediment resource (utilizing low, medium and high sediment conditions). 

Hydropower Impacts are Incomplete or Understated 

CREDA believes that the hydropower impacts reported in the DEIS are understated in all 

cases, and in some cases are incomplete or erroneous. Given that the HFE Protocol is intended 

to be part of all Alternatives, but expanded in terms of frequency and duration, CREDA would 

have expected DEIS hydropower impacts to be significantly higher. “The Department’s analysis 

completed for the HFE Protocol reported that the hydropower impact could be $8M-$122M over 

the Protocol period; yet the operational aspects of alternatives developed by the co-lead agencies 

in this DEIS contain significantly more potential negative effects to the hydropower resource. 

Previous analysis (USGS/GCMRC) associated with a prior EIS process (the LTEP) indicated the 

impact of a steady flow regime would average between $24M and $29M per year. This 

demonstrates the significant financial impact associated with steady flows and bypasses, and is in 

addition to the Argonne post-1996 ROD study finding that implementation of the 1996 Record 

of Decision has resulted in an average additional cost of $50M per year.” 64 

In addition, the DEIS must consider the impact of changed operations due to Interim 

Flows in 1991.65 Although the DEIS states that “Past and present (ongoing) actions in the 

project area have been accounted for in the baseline conditions described for each resource in 

Chapter 3”66, the cumulative effects at least for the hydropower resource are either a) not 

analyzed, b) not disclosed, c) disclosed in a manner to be unidentifiable even to hydropower 

utility cooperating agency experts, or d) some combination of the above. In any event, the DEIS 

does not sufficiently address these cumulative impacts to the hydropower resource, resulting in 

further underestimating of the DEIS impacts to the hydropower resource. 67 This is the same 

concern CREDA described in comments on the Aspinall Unit EIS. 

Additional topics contained in the DEIS associated with hydropower impacts should be 

considered and revised: 

63 See LTEMP DEIS, Appendix K, p. K-94. 64 See CREDA letter to the Department of the Interior, June 12, 2014, p. 3 65 Ibid, CREDA LTEMP EIS Scoping letter, January 31, 2012, p. 7. 66 See LTEMP DEIS, Chapter 4, p. 4-382 67 See CREDA letter to Reclamation (Reclamation), March 12, 2012, p. 1 

18 
 

 

 

 

 

 

 

 

 

 

 

 

i. Hoover power impact analysis is outside the geographic scope 68 of the DEIS and 

should be removed. If, however, there is reference retained to the relationship 

between Glen Canyon Dam releases and Lake Mead levels, there should be no 

reference or inferred relationship to Hoover hydropower impacts as an offset or 

mitigation for CRSP hydropower impacts. The projects are statutorily separate 

and the federal contracts and customers are entirely separate and distinct between 

the CRSP (Glen Canyon) and Boulder Canyon (Hoover) projects. 

ii. The DEIS must clearly state that there is no direct data relationship between the 

wholesale power analysis and the retail rate analysis. The retail rate analysis was 

completed in advance of the wholesale analysis and the data utilized in the retail 

rate analysis is not derived from or related to the wholesale power analysis. 

CREDA has continually expressed concern about the need for and inclusion of the 

retail rate analysis in this DEIS given the time, funding constraints, and lack of 

utility subject matter expertise associated with the analysis.

69 

iii. Incomplete and in process passive use valuation survey work for recreation 

resources has been included in the DEIS, but currently there is no inclusion of this 

type of valuation for the hydropower or water resources. Information prepared 

for inclusion in the AMP’s Socioeconomic Ad Hoc Group (SEAHG)’s work plan, 

which is an integral part of the Budget and Work Plan associated with the AMP, 

was presented to the TWG and AMWG during 2015.70 “With changing 

circumstances (e.g., population growth, drought, climate change) and social 

concerns, resource management confronts questions of potential re-purposing of 

river systems or operational changes of existing hydroelectric dams. Inherent 

trade-offs often exist between, say, riverine protection and renewable hydropower 

production”.71 During discussions in various forums, including the TWG, 

SEAHG and AMWG meetings, the DOI questioned applicability of the 

Paperwork Reduction Act to this project. The authors confirmed in several 

forums that it was not subject to the Paperwork Reduction Act,

72 and that the 

results have been peer reviewed and accepted for publication. This information 

is significant new information and must be considered and included in the 

DEIS. Thirty year-old, and data from projects that are not comparable to Glen 

Canyon Dam analysis contained in Appendix L should be superseded with more 

current peer-reviewed information that is directly relevant to Glen Canyon Dam. 

68 See Colorado River Basin States scoping letter, January 31, 2012, p. 6 69 Ibid, CREDA letter to USGS et al., April 18, 2014 70 See a) “Market and Non-Market Values of Water Resources and Non-Market Values of Hydropower Associated With Glen 

Canyon Dam” ; b) “Non-Market Values for Alternative Operations of the Glen Canyon Dam: Explorations in Choice and 

Valuation” http://www.usbr.gov/uc/rm/amp/twg/mtgs/15apr21/Attach_10a.pdf and 

www.usbr/gov/uc/rm/amp/twg/mtgs/15apr21/Attach_10b.pdf 

71 See Jones, Berrens, Jenkins-Smith, Silva, Carlson, Ripberger, Gupta and Carlson, Valuation in the Anthropocene: Confronting 

Multiple Value Dimensions Surrounding Complex Dam, Hydroelectric and River System Operations,, in print spring 2016 

72 See Minutes from SEAHG meeting, August 20, 2015, Q&A 10. 

19 
 

 

 

 

iv. Impacts to the Upper Colorado River Basin Fund must be assessed and 

considered. Referring back to development of this DEIS’ predecessor, the LTEP, 

CREDA wrote to then-DOI Deputy Secretary Lynn Scarlett: “Given the 

significant potential impacts to the Upper Colorado River Basin Fund as well as 

to federal budgets, we felt it important that financial/fiscal considerations be 

addressed at the outset of, and throughout, the environmental impact statement 

process for the long-term experimental program (LTEP).”73 

v. DEIS Chapter 4, page 4-425 recognizes that experiments cause an irretrievable 

loss of hydropower production. However, there is no analysis included which 

would meet the requirement of 40 CFR 1506.1, which requires that no resources 

be committed during the process that would foreclose a hard look at all the 

alternatives. This conclusion is drawn based on CREDA’s understanding that 

neither bug flow (low steady summer weekend flows) nor the LSF experiment 

impacts have been analyzed to the same degree as have HFE impacts on the 

hydropower resource. In addition, inclusion of the 8,000 cfs cap on fluctuations 

experiment in Alternative D is not identified as an irretrievable commitment of 

the hydropower resource, and should be. 

Adaptive Management and Experiments 

The adoption of the Preferred Alternative, or other Alternatives that rely on similar but 

undefined elements of an experimental and management plan violates NEPA because any 

Record of Decision would be based on a flawed EIS that contained inadequate disclosure and 

analysis of the environmental and other impacts of these Alternatives. The required, but missing, 

elements of an adaptive management program are identified in Paragraph III of the Summary at 

the beginning of this letter. DOI’s proposed implementation of adaptive management as a part of 

the LTEMP does not meet the legal requirements of the National Environmental Policy Act. 

To further explain, there is insufficient detail and information included in the DEIS 

regarding experimental triggers or “adaptively managing” under LTEMP, as stated in the 

Purpose and Need Statement. In describing the experimental regime under the preferred 

alternative, the LTEMP Draft EIS proclaims that “DOI intends to retain sufficient flexibility in 

implementation of experiments to allow for response to unforeseen circumstances or events that 

involve any other resources not listed here.”74 However, NEPA requires that specific triggers and 

metrics describing initiation, completion, off ramps and success/acceptability measurement be 

included in the description of each experiment contemplated in the LTEMP EIS. 

The DEIS has also failed to properly identify the hypothesis to be tested in each 

experiment or to define appropriate triggers, baselines, and objectives for each experiment. Table 

73 See CREDA letter to Lynn Scarlett, September 18, 2007, pp.1-2 74 See LTEMP DEIS, Chapter 2, p.2-247 

20 
 

2-9 of the LTEMP DEIS (page 2-49), which purportedly contains the [i]mplementation criteria 

for condition-dependent experimental treatments, provides stark examples. For example, 

Alternative D proposes a spring HFE up to 45,000 cfs and less than 96 hours will be performed 

so long as the DOI determines, on an annual basis, that there are no 

potential unacceptable impacts on water delivery or key resources 

such as humpback chub, sediment, riparian ecosystems, historic 

properties and traditional cultural properties, Tribal concerns, 

hydropower production and the Basin Fund, the rainbow trout 

fishery, recreation and other resources; unacceptable cumulative 

effects of sequential HFEs...(emphasis supplied)

75. 

Additionally, the DEIS provides the DOI the ability to terminate treatments prior to 

completion if certain undefined “off ramp conditions” are present. Again using Sediment 

Treatments as an example, the DOI describes the potential off ramp as a determination that the 

“HFEs were not effective in building sandbars; or unacceptable adverse impacts on the trout 

fishery, humpback chub population, or other resources.” Table 2-9. The same or substantially 

similar annual considerations and off ramps are found in Table 2-9 for Proactive Spring HFEs, 

Fall HFEs, and Fall HFEs longer than 96 hours. For the “load following curtailment” Sediment 

Treatment, the potential off ramp is at least somewhat descriptive: “resulting sandbars were no 

bigger than those created without reduced fluctuation,” but also includes the same vague

“unacceptable adverse impacts” language as other Sediment Treatments. 

Other experimental designs are also insufficiently defined. One of the off ramp 

considerations for trout management flows is “Little or no reduction in trout recruitment.” One

of the annual considerations for implementing low summer flows is “potential unacceptable 

impacts on [enumerated resources] and other resources.” Chapter 2 of the LTEMP Draft EIS and, 

in particular, Table 2-9, is full of similar vague conditions regarding the DOI’s future

experimental framework for Glen Canyon Dam. 

The DOI has agreed that “[a]ll experiments would be closely monitored for adverse side 

effects on important resources.” 76 DOI proposed to engage in a “formal process of stakeholder 

engagement to ensure that decisions are made with sufficient information.” 77 And while the DOI 

will consider the consensus recommendations of the “planning group” DOI “retains sole

discretion to decide how best to accomplish operations and experiments in any given year 

pursuant to the ROD and other binding obligations.” 78 

These poorly defined experimental conditions, coupled with the unquantified discretion 

of the DOI, create tremendous uncertainty for CRSP customers as well as other resource users. 

CREDA’s member utilities and other CRSP customers are held to high standards of reliability. 

Part of meeting those reliability standards is creating short and long-term generation planning 

forecasts. The ability to forecast CRSP hydropower is made that much more difficult if the DOI, 

in its “sole discretion” can determine that there are “adverse effects” on “other resources.” These 

75 Ibid, p. 2-30 76 Ibid, p. 2-55 77 Ibid. 78 Ibid. 

21 
 

 

 

flaws also render any EIS legally inadequate because it does not contain the required “hard look”

at the environmental and other impacts of the proposed action. 

The DEIS also fails to define its “annual implementation considerations.” Nearly every 

experimental treatment will be undertaken unless there are “potential unacceptable impacts” on 

certain defined and undefined resources. The law requires greater specificity than this. 

Likewise, elements of Alternative D include overly flexible adaptive management that is 

incompatible with the ESA, in part because there are no binding obligations or criteria or 

required mitigation in Alternative D that protect the endangered HBC. 

CREDA requests acknowledgement of receipt of these comments and supporting 

documentation and that they be made part of the administrative record for the LTEMP EIS. We 

appreciate consideration by DOI of these comments and recommendations. 

Sincerely, 

Leslie James 

Leslie James 

Executive Director 

ljr 

Cc: Katrina Grantz, BOR, LTEMP Co-Lead 

Rob Billerbeck, NPS, LTEMP Co-Lead 

CREDA 

10429 S. 51st St., Suite 230 

Phoenix, Arizona 85044 

480-477-8646 

creda@creda.cc 

22 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

TABLE B 

CREDA MEMBERS 

Following is a detailed listing of the Members of the Colorado River Energy Distributors Association, Inc. 

(CREDA) and systems that are associated with or comprise such Members for purposes of participation in CREDA. 

CREDA Member Associated Systems 

Arizona Municipal Power Users 

Association 

Avra Valley Irrigation and Drainage District; Cortaro- Marana 

Irrigation District, Pima County; Eastern Arizona Preference Pooling 

Association; HoHoKam Irrigation and Drainage District, Pinal 

County; City of Page; City of Safford; Town of Marana; Town of 

Gilbert; Town of Thatcher; Town of Wickenburg; City of Williams. 

Arizona Power Authority Chandler Heights Citrus Irrigation District; Queen Creek Irrigation 

District; San Tan Irrigation District 

Arizona Power Pooling Association City of Mesa, AZ; Electric District No. 2, Pinal County; Arizona 

Electric Power Cooperative, Inc. (Members: Anza Electric 

Cooperative, Duncan Valley Electric Cooperative, Graham County 

Electric Cooperative, Mohave Electric Cooperative, Sulphur Springs 

Valley Electric Cooperative, Trico Electric Cooperative). 

Colorado River Commission of Nevada Boulder City, NV; Overton Power District No. 5; Lincoln County 

Power District No. 1; Valley Electric Association 

Colorado Springs Utilities [ Not Applicable ] 

City of Farmington, New Mexico [ Not Applicable ] 

Intermountain Rural Electric Association, [ Not Applicable ] 

Colorado 

Irrigation & Electrical Districts Association Aguila Irrigation District; Ak-Chin Energy Services; Buckeye Water 

of Arizona Conservation & Drainage District; Central Arizona Water 

Conservation District; Electrical District No. 3, Pinal County, 

Arizona; Electrical District No. 4, Pinal County, Arizona; Electrical 

District No. 5, Pinal County, Arizona; Electrical District No. 6, 

Maricopa and Pinal Counties, Arizona; Electrical District No. 7, 

Maricopa County, Arizona; Electrical District No. 8, Maricopa 

County, Arizona; Harquahala Valley Power District; Hohokam 

Irrigation & Drainage District; Maricopa County Municipal Water 

Conservation District No. 1; McMullen Valley Water Conservation 

and Drainage District; Page Electric Utility; Roosevelt Irrigation 

District; The City of Safford; Salt River Project; San Carlos Irrigation 

23 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CREDA Member Associated Systems 

Project; The Town of Thatcher; Tonopah Irrigation District; WelltonMohawk Irrigation and Drainage District; Yuma County Water Users 

Association; Yuma Irrigation District; Yuma-Mesa Irrigation and 

Drainage District 

Los Alamos County, New Mexico [ Not Applicable ] 

Municipal Energy Agency of Nebraska Aspen, Delta, Fleming, Fort Morgan, Glenwood Springs, Gunnison, 

(MEAN) Haxtun, Holyoke, Oak Creek, Wray, Yuma (Colorado); Torrington 

(Wyoming) 

Navajo Tribal Utility Authority, Arizona [ Not Applicable ] 

and New Mexico 

Platte River Power Authority, Colorado Cities of Estes Park, Ft. Collins, Longmont, Loveland 

Provo City, Utah [ Not Applicable ] 

Salt River Project Agricultural 

Improvement and Power District (Arizona) [ Not Applicable ] 

Silver State Power Association, Inc. Valley Electric Association, Inc.; Overton Power District No. 5; 

(Nevada) Lincoln County Power District No. 1; Boulder City 

St. George City (Utah) [ Not Applicable ] 

South Utah Valley Electric Service District Cities of Payson and Springville 

(Utah) 

Tri-State Generation and Transmission Big Horn Rural Electric Company; Carbon Power & Light; Central 

Association (Colorado, Nebraska, New New Mexico Electric Cooperative; Chimney Rock Public Power 

Mexico, Wyoming) District; Columbus Electric Cooperative; Continental Divide Electric 

Cooperative; Delta-Montrose Electric Association; Empire Electric 

Association; Garland Light & Power Company; Gunnison County 

Electric Association; High Plains Power; High West Energy; Highline 

Electric Association; Jemez Mountains Electric Cooperative; K.C. 

Electric Association; Kit Carson Electric Cooperative; LaPlata 

Electric Association; The Midwest Electric Cooperative Corp.; MoraSan Miguel Electric Cooperative; Morgan County Rural Electric 

Association; Mountain Parks Electric; Mountain View Electric 

Association; Niobrara Electric Association; Northern Rio Arriba 

Electric Cooperative; Northwest Rural Public Power District; Otero 

County Electric Cooperative; Panhandle Rural Electric Membership 

Association; Poudre Valley Rural Electric Association; Roosevelt 

24 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CREDA Member Associated Systems 

Public Power District; San Isabel Electric Association; San Luis 

Valley Rural Electric Cooperative; San Miguel Power Association; 

Sangre De Cristo Electric Association; Sierra Electric Cooperative; 

Socorro Electric Cooperative; Southeast Colorado Power Association; 

Southwestern Electric Cooperative; Springer Electric Cooperative; 

United Power, Inc.; Wheat Belt Public Power District; Wheatland 

Rural Electric Association; White River Electric Association; 

Wyrulec Company; Y-W Electric Association 

City of Truth or Consequences, New [ Not Applicable ] 

Mexico 

Utah Associated Municipal Power Systems Cities of Beaver, Blanding, Bountiful, Enterprise, Ephraim, Fairview, 

(UAMPS) Fillmore, Heber Light & Power, Holden, Hurricane, Hyrum, Kanosh, 

Kaysville, Lehi, Logan, Monroe, Morgan, Mt. Pleasant, Murray, Oak 

City, Paragonah, Parowan, Santa Clara, Spring City, Town of 

Meadow and Washington; Central Utah Water Conservancy District; 

Weber Basin Water Conservancy District 

Utah Municipal Power Agency (UMPA) Cities of Manti, Nephi, Salem, Spanish Fork; Town of Levan 

Yampa Valley Electric Association, [ Not Applicable ] 

Colorado 

Wyoming Municipal Power Agency Cities of Cody and Powell; Towns of Fort Laramie, Guernsey, Lingle, 

Lusk, Pine Bluffs, Wheatland 

25 
 

 

 

 

TABLE C 

ACCOMPANYING DOCUMENTS 

I. NOTEBOOK 1: Footnote documentation – Footnotes 1-27 

II. NOTEBOOK 2: Footnote documentation – Footnotes 28-73 

III. NOTEBOOK 3: LTEMP DEIS Chapters – strike/add comments 

Chapters 1, 2, 3, 4, 5, 8 

LTEMP DEIS Appendices – strike/add comments 

Appendices C, E, H, I, J, K, L, M 

26 
 

 

 

 

 

 

 

 

 

 

CREDA 

Colorado River Energy Distributors Association 

November 14, 2016 

LTEMP EIS Co-Leads 

Katrina Grantz – BOR 

Rob Billerbeck - NPS 

Via email only 

The Colorado River Energy Distributors Association (CREDA) submits the following comments on the 

Long-Term Experimental and Management Plan (LTEMP) Final Environmental Impact Statement (FEIS) 

(October 7, 2016), as requested at the October 18, 2016 Technical Work Group (TWG) meeting. CREDA 

understands that comments are due not later than November 14, 2016, so given the short period of time allowed 

for review of a nearly 2,500 page document, these initial comments will focus on key areas, and we will submit 

additional information at a later date. 

These comments focus on: a) changes made following the DEIS, b) continuing issues of concern that 

have not been adequately addressed, or c) new information that was not previously available for public review 

and comment (most significantly Appendices O and P). CREDA also incorporates by reference its May 9, 2016 

comment letter with attachments, and all prior comments, and requests that this information be included in the 

Administrative Record for the LTEMP. 

KEY POINTS 

I. PURPOSE AND NEED: As the FEIS recognizes, the “Purpose and Need” for the Proposed Action has 

changed over time (FEIS 1-6). “The purpose of the proposed action is to provide a comprehensive 

framework for adaptively managing Glen Canyon Dam over the next 20 years consistent with the GCPA 

and other provisions of applicable federal law.” (FEIS 1-5); and “The need for the proposed actions 

stems from the need to use scientific information developed since the 1996 ROD to better inform DOI 

decisions on dam operations and other management and experimental actions”. (FEIS 1-6). This 

statement of the Purpose and Need is fatally flawed because it essentially proposes a “Purpose” of 

meeting applicable federal laws, which is a purpose that is so broad as to be meaningless. Likewise, the 

identified “Need” to “better inform” future decisions is devoid of substance. The “Objectives and 

Resource Goals of the LTEMP” listed in Chapter 1.4 do not provide any meaningful definition of the

Purpose and Need because they are a laundry list of resources deemed important by the Department, but 

lack discernable objectives that can be measured for the purpose of defining an identifiable objective for 

the agency action. The Department cannot frame its Purpose and Need, or its objectives, in a manner so 

unreasonably broad that an infinite number of alternatives would accomplish its goals. Consequently, 

the adoption of this “Purpose and Need” is arbitrary and capricious and violates the requirements of 

NEPA. 

1 
 

 

 

 

 

The flawed “Purpose and Need” is at times explained as a program to implement concepts of adaptive

management. If adoption of an adaptive management plan is the objective, the alternatives are 

improperly defined and narrowed because they do not include or analyze a No Action Alternative of 

“No Adaptive Management”. If, however, the adoption of adaptive management is the objective, the

FEIS and the Preferred Alternative fail to do so because the program does not even remotely comply 

with common definitions of adaptive management, including those contained in “Adaptive Management 

– The U.S. Department of the Interior Technical Guide”, found at 

https://www.doi.gov/ppa/upload/TechGuide.pdf. While portrayed as “scientific experiments”, the lack 

of defined hypotheses that will be tested, or controls or baselines for comparison with the results of an 

experiment make it clear that the proposed adaptive management plan is fatally flawed from a scientific 

perspective. Section 2.2.2.3 attempts to justify these failures by asserting that it is difficult to control for 

specific conditions, there is a wide variability in conditions, there are risks of certain experiments, there 

are conflicting multiple use values and objectives, and that there is a low expected value of information. 

None of these justifications provide a rational explanation of why the proposed experiments lack defined 

hypotheses that can be tested with meaningful criteria. 

Moreover, in describing the experimental regime under the Preferred Alternative, the FEIS proclaims 

that “DOI intends to retain sufficient flexibility in implementation of experiments to allow for response

to unforeseen circumstances or events that involve any other resources not listed here.” (FEIS ES-37 and 

elsewhere). This reservation of undefined discretion, when combined with the lack of specific criteria to 

define “Experiment Triggers and Primary Objective[s],” conditions for replication of the experiment, 

“Annual Implementation Considerations,” “Long Term Off-Ramp Conditions,” and “Action if 

Successful” for each of the alternatives, (Table 2-9, FEIS 2-50-54), confirms that the Proposed Action 

and the FEIS fail to provide the disclosure and analysis required by NEPA. Likewise, the failure to 

identify a quantitative standard or qualitative analysis that will be used to measure and respond to the 

results of experiments or to define success, failure, or to decide to replicate or to terminate an 

experiment constitutes a Proposed Action that will be arbitrary and capricious. 

Table 2-9 is replete with undefined terms that make it impossible for the Department and the public to 

understand what experiments or management actions will be implemented and when, or to assess the 

impacts of and risks associated with the preferred action. Examples of undefined terms in Table 2-9 that 

render the FEIS disclosure and analysis invalid include “achieve a positive sand balance,” “rebuild 

sandbars,” “protect sand,” “dependent on resource condition and response,” “potential short-term 

unacceptable impacts,” “unacceptable cumulative effects,” “could be shorter depending on results of 

first tests,” “HFEs are not effective in building sandbars,” “long–term unacceptable adverse impacts on 

the resources listed in Section 2.2.4.3 are observed,” “implement ... when triggered and existing

resource conditions allow,” “little or no effect,” “long-term unacceptable adverse impacts,” “determined 

ineffective,” “increase humpback chub growth,” “improve food base,” and “improve vegetation 

conditions.” Footnote “a” to Table 2-9 confirms the lack of criteria, stating that “Triggers will be 

modified as needed during the 20-year LTEMP period in an adaptive manner through processes 

including ESA consultation and based on the best available science utilizing the experimental 

framework for each alternative”. References to implementation conditions found elsewhere in Chapter 2 

do not provide meaningful definition of these terms. Many of these terms are also rendered meaningless 

because the FEIS and the Proposed Action do not sufficiently describe the monitoring of specific data 

that could be used to determine the success or failure of an experiment. Vague commitments to 

monitoring as contained in the science plan described at the August 2016 AMWG meeting are not 

legally sufficient. 

2 
 

 

 

 

 

 

 

 

Taken as a whole, it is impossible to conclude that the FEIS takes the required “hard look” at the

alternatives because they are not defined, the success or failure of the experiments is not defined, the 

“off-ramps” for experiments are not defined, and the response to additional information provided by an 

experiment is not defined. No amount of modeling can cure the failure to define the Proposed Action 

with sufficient specificity to allow the decision maker and the public to understand what is proposed or 

to make a reasoned choice among alternatives. 

In sum, the FEIS is legally inadequate because experiments must include a description of the proposed 

experiment, the time or frequency of implementation of the experiment, and the triggers or other 

conditions that must exist prior to implementation of the experiment. Each experiment must also include 

a description of the hypotheses that will be tested by the experiment and benchmarks or other 

identifiable criteria that will allow the Secretary and interested parties to assess the success or lack 

thereof, when an experiment or action must be terminated because of unacceptable impacts (as 

specifically defined) to the endangered HBC or other legally protected resources. Finally, any 

monitoring included in an implementation plan or experimental design must meet legal standards 

necessary to implement adaptive management as a part of the LTEMP. See “Adaptive Management –

The US Department of the Interior Technical Guide”1 

The ROD should state that prior to implementation of any experiment or management action 

under the LTEMP, the elements highlighted in the above paragraph will be included in an 

implementation plan. 

As indicated in Table 2-9 and elsewhere in the FEIS, some of the proposed actions already meet these 

criteria, while others are unduly vague and unquantifiable and require additional definition. CREDA 

will continue to be an active participant in the AMP committees and processes to support this important 

requirement. CREDA is encouraged by recent discussions at the TWG meeting and with the Science 

Advisors regarding an upcoming Knowledge Assessment process and believe it could inform and 

expedite completion of this requirement. 

A stated objective of the DEIS is to “maintain (or/and)2 improve hydropower” stemming from the 

“generation of hydropower” contained in the Purpose and Need Statement (76 FR 129, July 6, 2011),

which reflects the Secretary’s obligation to fulfill multiple and sometimes competing statutory

requirements applicable to the operation of Glen Canyon Dam and the exercise of other authorities as 

required by the provisions of the Grand Canyon Protection Act (GCPA). The United States has 

described the relationship between the objectives of the GCPA and the Colorado River Storage Project 

Act (CRSPA) as being “in addition to rather than in substitution of the Secretary’s obligations 

concerning the operations of Glen Canyon Dam for hydropower and other project purposes.”3 The U.S. 

District Court for the District of Arizona further clarified that the broadly worded provisions of the 

Colorado River Storage Project Act (CRSPA) and GCPA impose on the Secretary an obligation to 

balance many different interests in operating Glen Canyon Dam. The Secretary must continue to 

recognize that power production is still a primary purpose of the Dam that must be balanced against 

other purposes, statutory requirements, and water delivery obligations as (s)he considers actions to 

implement the GCPA.4 In fact, the failure to incorporate within the Preferred Alternative an experiment 

1 See: (https://www.doi.gov/sites/doi.gov/files/migrated/ppa/upload/TechGuide.pdf) and United States Department of the Interior Environmental 

Statement Memorandum No. ESM 13-11, January 7, 2013. 

2 “And/or” appear to be used interchangeably in the LTEMP DEIS. The Power DFC, (approved by AMWG and recognized by Secretary Salazar in early 

2012), contained “and”. 

3 See Grand Canyon Trust v. US Bureau of Reclamation, 623 F.Supp.2d 1015, 1036, Federal Defendants’ Reply Memorandum In Support of Cross

Motion for Summary Judgment on Claims 6-8 at p. 26, lines 25-27, (February 20, 2009) 4 See Colorado River Basin State Representatives to LTEMP EIS Scoping, January 31, 2012 

3 
 

 

 

 

 

 

 

 

 

 

that tests the impact of hydropower improvement flows is arbitrary and capricious given statutory 

requirements.5 There is no rational basis for a refusal to test such flows, particularly when the Preferred 

Alternative includes experiments that are designed to provide information on management of resources, 

such as sediment, which are not the subject of express statutory requirements. 

II. LTEMP and BIOLOGICAL ASSESSMENT (BA): Appendix O is legally and scientifically flawed 

and cannot be the basis for any decision. If incorporated into the ROD as drafted, Appendix O violates 

the requirements of NEPA because it contains experiments or other proposed actions that are not 

adequately defined or analyzed, and that may be likely to adversely impact the endangered HBC. 

Appendix O includes conclusory statements6 with regard to flows that are at best, premature and not 

fully supportable, and at worst, incorrect.7 A key example of a broad conclusory statement is on O-96: 

“In summary, under base operations, continued hydropeaking flows with increased downramp rates 

compared to the existing condition under coldwater conditions will continue to degrade nearshore 

rearing habitats, prevent the establishment of aquatic invertebrates (food base), and increase the risk of 

stranding juvenile humpback chub.” Contradictory statements include: “The potential for, and the effect 

of, stranding on individual humpback chub survival has not been directly investigated,” (FEIS O-94), “it 

is unclear how important backwater or embayment habitats are to humpback chub throughout other 

reaches of the Grand Canyon...their overall abundance in the Little Colorado River reach was higher in 

talus” (FEIS O-98), and “no current published research is available to show what factors may have 

correlated to the decline in invertebrate drift at the Little Colorado River in 2014 and 2015.” (FEIS O100). Kennedy et al (2016) cannot be the basis for repeated definitive statements about the effects 

of fluctuating (or “hydropeaking”) flows or ramp rates and the BO should describe it as an initial

investigation which merits additional observation and flow tests as described in Attachment B. 

Throughout LTEMP Alternative analyses as well as under MLFF operations, a consistent observation is 

the likely positive linkage between the fluctuating flow operations and experiments contained in 

Alternatives B and E and the endangered HBC8

. Appendix D of Appendix O describes the approach to 

developing BA/BO action triggers was to manage HBC as opposed to managing predators (FEIS O176). Testing flow regimes that have been demonstrated or hypothesized (and not yet tested) to be 

positive to HBC is consistent with that approach. The science associated with foodbase effects is less 

mature and needs additional research and testing,9 as do issues associated with the growing emergence 

of brown trout and green sunfish in the Lee Ferry reach. In order to establish accurate resource 

relationships within the CRE associated with various treatments contained in Appendix O, and to further 

learning associated with the impacts ascribed to temperature versus flow, it is necessary to test a wider 

range of flow conditions than are described in the Preferred Alternative. These flow levels have already 

been analyzed under NEPA in the LTEMP EIS. 

5 CREDA raises here the issue of omission of a statutory requirement from the alternatives identified in a NEPA analysis, and reserves the right to 

litigate the compliance with applicable statutory requirements. 

6 See esp. FEIS O-96, summary statement, and multiple cites to Kennedy (2016). 7 See Attachment A, initial comments of W.E. Davis, EcoPlan Associates, Inc., Nov. 7, 2016 8 See Finch, et al (2013) 9 See HFE Environmental Assessment, Ch. 2, p. 48: “• Research Question #9: What is the relationship of high-release magnitude and duration on the 

extent of foodbase scouring in the Lees Ferry reach? Summary: High-flow releases of 41,000 to 45,000 cfs were shown to scour about 90 percent of 

the foodbase on sediments and much of the foodbase on rock substrates in the Lees Ferry reach. The relationship of the extent of scouring and 

flow magnitude is important information as a potential management tool for stimulating production. Hence, flow magnitude of less than 41,000 cfs 

should be evaluated to determine the scouring effect on the foodbase.” (emphasis added). Also, (same cite): “Impacts of a consecutive fall and

spring event could be severe on the foodbase and trout population”

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Any LTEMP implementation plan must include flow tests10 along with a technical team evaluation 

to develop refined hypotheses, triggers and off-ramps associated with the experimental treatments 

contained in Appendix O and any successor BO. 

Including these tests in the ROD provides necessary flexibility, compliance and robustness to undertake 

flow-related experimental actions and treatments associated with HBC. It is also meets a necessary 

requirement under Section 1.2.4.3 in assessing the efficacy of a temperature control device “in both 

high-and low-flow discharge scenarios”. Equally important, inclusion of these flows comports with 

“science and modeling methods to further consider the impacts of a variety of dam operations on power 

generation and capacity, and considers operations that can maintain or increase hydropower 

generation” (emphasis added) (FEIS 1-9). 

III. BASING SELECTION OF A PREFERRED ALTERNATIVE ON MISCHARACTERIZED 

INFORMATION IS ARBITRARY AND CAPRICIOUS. The DEIS, and now the FEIS, continue to 

inaccurately characterize data from a study used to support the flow factor/fluctuation index initially 

utilized in Performance Metric 12 of swing weighting in the SDA process. The Fluctuation Index 

utilizes information derived from a 1987 study (Bishop et al),11 which addressed recreational user 

preference for fluctuating flow levels. In that study, however, 10,000 cfs (not 8,000 cfs) was defined as 

“constant flows”. And yet, there appears throughout the DEIS, with additional references added to the 

FEIS, what CREDA believes to be misinterpretation of these data, and a reliance on this 

misinterpretation as justification for including an arbitrary 8,000 cfs cap on fluctuations as part of 

Alternative D, in order to benefit the sediment resource. In addition, the difference in sediment transport 

between, for instance, 8,000 cfs and 10,000 cfs is negligible and within the error of the model 

forecasting error. However, the difference in impact on hydropower between an 8,000 cfs cap and a 

10,000 cfs cap is material. A confounding factor in determining sediment “benefit” ascribed to the flow 

fluctuation factor is monthly volumes. Higher monthly volumes increase transport. However, “It was 

not possible to reconcile the relative importance of daily fluctuations and monthly volume allocations 

without additional modeling”.12 In fact, in the Bishop study, “moderate daily fluctuations” of 8,000-

25,000 cfs were the most preferred of four different flow scenarios.”13 The flow factor/fluctuation index 

analysis used in the DEIS is unsupported scientifically and results in an unnecessary restriction on 

hydropower operations. Use of 8,000 cfs as a reference point for angler preference in the FEIS is also 

an incorrect inference to the most recent study by Bair et al14. Just as the HFE Protocol initially used a 

“cap” of 96 hours, and now the “cap” is being extended to 250 hours in the FEIS, the 8,000 cfs “cap” is 

merely a number that has been used in previous environmental processes, with no prior or subsequent 

science that definitively supports its continued use as an absolute requirement. LTEMP 

documentation should not construe the use of the arbitrary 8,000 cfs as being science based. 

IV. SIGNIFICANT NEW INFORMATION: “Estimating Non-Use Values for Alternative Operations 

of the Glen Canyon Dam: An Inclusive Value Approach, Phase 3B Project Research and 

Findings”15 . A significant new study, funded and led by the University of Oklahoma Center for 

Energy, Security and Society and including other experts, has direct relevance to the LTEMP EIS and 

10 See Attachment B, developed by LTEMP utility cooperating agencies and CREDA, Aug. 31, 2016 11 See FEIS Appendix C, P. C-27, section 4.5 12 See LTEMP DEIS, Appendix E, p. 14 13 See Bishop, et.al. (1987), Grand Canyon Recreation and Glen Canyon Dam Operations: An Economic Evaluation, p. 67 14 See Lucas S. Bair, David L. Rogowski & Chris Neher (2016) Economic Value of Angling on the Colorado River at Lees Ferry: Using Secondary Data to 

Estimate the Influence of Seasonality, North American Journal of Fisheries Management,36:6,1229-1239,DOI:10.1080/02755947.2016.1204388; 

http://dx.doi.org/10.1080/02755947.2016.1204388 15See University of Oklahoma (Hank C. Jenkins-Smith, Principal Investigator; Carol L. Silva, Co-Principal Investigator; Deven Carlson, Kuhika Gupta, 

Benjamin Jones, Joseph Ripberger, Wesley Wehde); University of New Mexico (Robert Berrens); Sept. 2016 

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the Secretary’s decisions in the ROD. Unlike previous non-use valuation studies16 that were limited in their 

application to only a small subset of downstream resources, this study describes all resources considered in the 

LTEMP DEIS, including tribal communities. The study estimates the non-market, non-use values for an 

inclusive set of impacts that result from changing the operation of Glen Canyon Dam. To accomplish this, the 

research team developed an integrated, multi-stage protocol to identify the valued impacts and to estimate the 

balance of the negative and positive valuations of those impacts by a representative sample of the US public. 

The study found that the median household value for retaining the current pattern of GCD operations would be 

nearly $20 per year - amounting to approximately $2.5 billion per year over all US households. This study is 

the best available science on the topic, and it is arbitrary and capricious for the FEIS and any ROD to 

rely on a less current and far more superficial study.17 

Sincerely, 

Leslie James 

Leslie James 

Executive Director 

ljr 

Cc: Thomas Iseman, DOI 

Camille Calimlim-Touton, DOI 

Commissioner Estevan Lopez, BOR 

Brent Rhees, BOR 

CREDA Board 

10429 S 51st St. 

Suite 230 

Phoenix, AZ 85044 

480-477-8646 

www.creda.org 

16 Ibid, Bishop, et.al. 17 See Nehr, et al (2016) at FEIS 4-378; Appendix L. 

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--------------------------------------------------------------------------------------------------------------------

ATTACHMENT A 

INITIAL COMMENTS 

LTEMP FEIS-APPENDIX O 

BIOLOGICAL ASSESSMENT 

These comments reflect CREDA’s initial comments on five topics that are included in FEIS Appendix O: 

1. Stranding of humpback chub or razorback sucker 

2. Desiccation of benthic invertebrates 

3. Backwater habitat use and need 

4. Impact of steady flows on drift and nonnative fish reproduction 

5. Impact of high flow experiments on aquatic food base 

1. Stranding of young humpback chub or razorback sucker during daily hydropower operations at Glen Canyon 

Dam (GCD) is not proven, and unlikely because: 

 Grand Canyon is essentially like a pipe transmitting water from Lake Powell to Lake Mead. As a narrow canyon, it 

naturally has few backwaters or shallow areas and the vast majority of backwaters drain completely as flows 

decrease. Of the few backwaters, there are even fewer that form isolated ponds after flows ebb to trap fish. 

 Downramp rates since implementation of MLFF have been no greater than 1,500 cfs/hour which is about 6-8 

inches drop in stage elevation over an hour, depending on location. Proposed new downramp rates of 2,500 

cfs/hour would mean about 12 inches drop over an hour. Both these drops in stage elevation are sufficiently 

slow to allow any fish within the vast majority of backwaters to return to the river’s mainstem.

 Previous stranding work below GCD Dam has demonstrated negligible stranding of fish under current fluctuating 

flows. Minor trout mortalities were shown only in a couple isolated pools during summer high temperatures but 

none during winter conditions. 

 Trout management flows would artificially encourage small fish to reside in shallow, near shore areas and then 

suddenly reduce the flow in an attempt to strand fish. This is not a pattern consistent with daily hydropower 

operations. 

 Five years of work by Pine et al. in the Near Shore Ecology (NSE) studies on the Colorado River below the Little 

Colorado River confluence determined that “flow type did not affect habitat selection or daily movements (of

young humpback)” and “survival (of young humpback) was similar between flow treatments.”

 The Nagrodski work cited in the BA as the basis for predicting stranding of humpback chub and razorback 

suckers inventoried a variety of hydropower facilities. This reference is not appropriate for assessing what could 

happen at GCD because Colorado River fish are uniquely adapted to survive in highly variable flow conditions. As 

the work in the NSE study has shown, these fish are quite capable of managing to grow and prosper under the 

meagre stage changes seen each day under current fluctuating flows. 

2. Desiccation of benthic invertebrates during daily GCD operations is not proven; these operations are likely not 

the reason for the absence of invertebrates below GCD because: 

 Six other tailwaters on the Colorado River (Navajo, Libby, Ennis, Kerr, Flaming Gorge and Fontenelle) studied for 

impacts showed 25-40% EPT richness; however, GCD’s tailwaters showed 0% richness (BLM/USU National

Aquatic Monitoring Center (BugLab). 

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 The other tailwaters studied had similar EPT richness as Grand Canyon tributaries (i.e. Havasu, Shinumo, Bright 

Angel) and Cataract Canyon on the Colorado (20-55%). 

 Recent and ongoing research on the river bottom below GCD by Dr. Larry Stevens indicates anoxic conditions, in 

the narrow water boundary layer between bottom muds, gravels and rocks, may be a cause for a lack of insect 

production. 

 Preliminary work on tributary inflows by Dr. Larry Stevens looking at what he terms the Hofknecht transition at 

Tapeats Creek in Grand Canyon noted that aquatic insect diversity and abundance declined in Grand Canyon 

tributaries as they transition to areas influenced by the mainstem. Hofknecht found there is still a decline in 

diversity and abundance in the transition from the tributary to the mainstem which indicates there is something 

else going on with foodbase in Grand Canyon besides flow fluctuations and egg desiccation. 

 Some insects lay eggs over open water while others lay eggs near shore; yet, none of the open water forms that 

would be unaffected by fluctuating flows are successfully reproducing below GCD. 

 During fluctuating flows, eggs lain when flows are low, even if in smaller numbers than eggs lain during high 

flows, would not become desiccated; yet, despite this opportunity, no successful reproduction is occurring. 

 It is too early to conclude that the reason we do not see insect production below Glen Canyon Dam is due to 

desiccation under fluctuating flows. The Ted Kennedy work has prompted additional research and this is raising 

many new and interesting questions about causes-and-effects and should delay any decision to alter flow 

regimes, i.e. instituting “bug flows.”

3. The effect of daily GCD hydropower operations on backwater habitat used by humpback chub and razorback 

sucker is not critical to their growth, reproduction and survival because: 

 Backwater habitats are rare in Grand Canyon as would be expected in this deep, narrow canyon environment, as 

describe in the NSE research. 

 According to the NSE research, juvenile humpback abundance was highest in talus and lowest in backwaters. 

 Although young humpback positively selected backwaters, due to the lack of these habitats the fish survive and 

rear without requiring them. Obviously, if humpback were dependent on backwaters to rear their young, the 

chub would likely have been extirpated long ago due to lack of these habitats in Grand Canyon. 

4. The effect of steady flows on drift and nonnative fish reproduction would be detrimental to humpback chub 

and razorback sucker because: 

 The Lees Ferry reach is the only consistently clear section of the river below GCD. As a result, this section is 

capable of producing an autochthonous (in stream) food source to supply the entire river whereas increasing 

turbidity downstream reduces the possibility of food production. 

 Fluctuating flows are known to produce more drifting food than what occurs under steady flows, as each change 

in flows dislodges some invertebrates and algae from the Lees Ferry reach that move downstream with the flow 

downstream. 

 Both humpback and razorback downstream utilize the drift as a primary source of food. 

 A reduction in drift would jeopardize humpback and razorback growth, reproduction and, ultimately, their 

survival. 

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 Steady flows and low summer flows are both intended to enhance temperatures and the production of 

invertebrates; yet, any benefits to humpback chub and razorback sucker from these flows would likely be more 

than offset by a decline in drift, a critical food supply. 

 In addition to a reduction in drift, low summer flows could lead to a proliferation of warm water nonnative 

reproduction. For example, green sunfish reproduction on shallow shorelines could increase and occur 

throughout the canyon if low summer flows are instituted in lieu of fluctuating flows. 

5. High flow experiments (HFEs) scour the river bottom and remove large quantities of the food base. This has 

lasting effects on food supplies for trout and humpback chub because: 

 Critical components of the foodbase, including primary producers, like the alga Cladophora and scud Gammarus, 

take many months to return to pre-HFE levels. 

 During the extensive period after an HFE until the food base recovers from scouring, competition for food 

among fish intensifies resulting in a loss of body condition and possible death. 

W.E. Davis, EcoPlan Associates, Inc. 

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ATTACHMENT B 

LTEMP EIS – UTILITY COOPERATING AGENCY PROPOSAL – 8/31/16 

As currently described, the Preferred Alternative further restricts the Glen Canyon Dam hydropower resource beyond the 

No Action Alternative. This was a further reduction in usable capacity of approximately one-third as a result of the 1996 Record of 

Decision. These losses of hydropower are not mitigation requirements of the Endangered Species Act. 

This new proposed loss of hydropower capacity is not consistent with the Administration’s initiatives related to climate

change, climate resilience, and the deployment of renewable energy, such as the President’s Climate Action Plan, the recent 

Presidential Memorandum entitled Building National Capabilities for Long-Term Drought Resilience, and the accompanying federal 

action plan on drought, and the August 2 Council on Environmental Quality NEPA climate change guidance18. Glen Canyon 

hydropower also provides critical redundancies for the Western power grid. These losses of additional hydropower capacity reduce 

the availability and benefit of this critical redundancy. 

The UCAs request that Interior include in the EIS, Science Plan, and/or ROD, additional experiments that could help ensure 

that generation at the Glen Canyon Dam is “maintain[ed] (or/and) improve[d],” as required by the Purpose and Need Statement of 

the LTEMP EIS (76 FR 129, July 6, 2011). 

Test Hydropower Improvement Flows as Described in Alternative B19 in the First 5 Years of the Plan, during low volume years 

(8.23MAF and below): Maximum daily flow: 25,000 cfs (Dec.– Feb., Jun.–Aug.); 20,000 cfs (Sep.–Nov.); 15,000 cfs (Mar.–May). 

Minimum daily flow all months: 5,000 cfs. Ramp rate up and down: 5,000 cfs/hr. 

This experiment is required and will provide data regarding the relationship between hydropower operations and other 

resources. 

Test the Daily Fluctuation Range as Described in Alternative E20 in the First 5 Years of the Plan: Equal to 12 × monthly volume (in 

kaf) in Jun.–Aug., and 10 x monthly volume (in kaf) in other months. 

This experiment tests hypotheses related to the benefit of slightly greater fluctuations to the endangered humpback chub 

and other native fish. 

Considering Frequency and Duration, the Total Number of HFEs in a 12-Month Period Not to Increase Air Emissions Above 25,000 

Metric Tons. Produce Written Evaluation of Resource Impacts after 10 Years. This is consistent with climate change and carbon 

reduction policies, while still including HFEs to benefit sediment. This is a compromise among Alternatives A, B, C, E and the 

evaluation is consistent with the HFE Protocol. 

This experiment and evaluation are necessary to study resource impacts and test the hypotheses that the biological impacts 

of consecutive HFEs are negative (e.g. to food base, scouring, HBC), and that a lower frequency and duration will result in 

less air emissions and less impact to recreation, fishing, tribal and hydropower resources. 

The UCAs’ proposed experiments have already been modeled for the EIS and will not require additional NEPA analysis. 

18 Available at: https://www.whitehouse.gov/the-press-office/2013/06/25/fact-sheet-president-obama-s-climateaction-plan 

https://www.whitehouse.gov/the-press-office/2016/03/21/presidential-memorandum-buildingnational-capabilities-long-term-drought 

https://www.whitehouse.gov/sites/default/files/docs/drought_resilience_action_plan_2016_final.pdf 

https://www.whitehouse.gov/sites/whitehouse.gov/files/documents/nepa_final_ghg_guidance.pdf 

19 Source key: http://ltempeis.anl.gov/documents/docs/LTEMP_Alternatives_Matrix_Feb2016.pdf 20 Ibid. 

10