United States Department of the Interior

OFFICE OF THE SECRETARY

Washington, DC 20240

FEB 2 2 2010

Mr. Rick Johnson

Colorado River Science Director

Grand Canyon Trust

2601 North Fort Valley Road

Flagstaff, Arizona 8600 I

Dear Mr. Johnson:

On behalf of Secretary Salazar, I am responding to your letter dated October 23, 2009, regarding the Glen

Canyon Dam Annual Operating Plan, in which you recommended that the Bureau of Reclamation change

its monthly distribution of releases from Glen Canyon Dam (GCD). In your letter, you requested that the

nonnal ongoing operation ofGCD be modified to discharge l/121h ofthe annual volume ofwater each

month (which you refer to as "Equalized Monthly Volumes" or "EMV"), beginning in the 20 I0 water

year, which began on October 1,2009. You also suggested that such operations could be included in the

20 I0 Annual Operating Plan (AOP) for Colorado River System Reservoirs. We also recognize that the

current operation of Glen Canyon Dam is the subject of ongoing litigation brought by your organization

against the Bureau of Reclamation and the U.S. Fish and Wildlife Service.

The 2010 AOP was recently finalized, and as you are likely aware, it addresses operations for multiple

Colorado River reservoirs and addresses multiple issues, not just operations of GCD. Modifying releases

from GCD to an approach based on EMV, as your letter suggested, would be a significant modification of

GCD operations. The 2010 Annual Operating Plan does not adopt an EMV operation for GCD. We

believe that a more detailed hydrologic explanation of how your proposal would work under the

numerous operating requirements applicable to GCD would facilitate a more detailed consideration of

your suggestion. The Glen Canyon Dam Adaptive Management Program (GCDAMP) was specifically

established to address ongoing concerns over the operation of GCD and effects on downstream resources.

The GCDAMP includes a Federal Advisory Committee, the Glen Canyon Dam Adaptive Management

Work Group (AMWG). We encourage you to address this issue through the GDCAMP and the AMWG,

the appropriate fora to propose experimental and management changes to the operation of GCD for the

improvement of environmental resources in the Grand Canyon.

Your letter also suggested that the Colorado River Management Work Group (CRMWG) should be

chartered as a Federal Advisory Committee Act (FACA) group. The CRMWG is an ad hoc group of

stakeholders who the Department consults with during the development ofthe AOP. For context, the

CRMWG includes a mailing list of over 160 individuals, members ofthe general public, and

organizations that are notified and included as part ofthe AOP consultation process. The AOP

consultation process is one in which the Department ofthe Interior consults with a broad range of Federal,

tribal, state and non-governmental interests as it prepares a report on the past and projected operations of

the Colorado River each year as required by the Colorado River Basin Project Act. Meetings ofthe

CRMWG provide the opportunity for the Department and Reclamation to share important information

with the parties (including information regarding past and projected hydrologic conditions and past and

projected operations) and to discuss the specific information that will be included in the report. As you

know, this year we held three public consultation meetings on the 2010 AOP, and a representative ofthe
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Grand Canyon Trust attended the first ofthese consultation meetings. This process enables us to

involve interested parties and to consider their comments.

With respect to FACA, in order to establish an advisory committee, an agency has to provide an

explanation stating why the advisory committee's functions cannot be perfonned by the agency, another

existing committee, or other means, such as public hearings. 41 C.F.R. § 102-3.60(b)(2). As you know,

there is already an existing FACA committee designed to seek public participation in Glen Canyon Dam

management: the AMWG, on which you serve as Grand Canyon Trust's representative. As noted above,

there also have been multiple public consultation meetings with respect to development of previous

AOPs. We will hold additional public consultation meetings in the future as appropriate. Chartering the

CRMWG as a FACA committee is not only unnecessary, it would be discouraged by the FACA

regulations.

Thank you for your letter and ongoing interest in the resources ofthe Colorado River. We recognize your

concern and interest in management of Glen Canyon Dam, and we will continue to work with you on

these important issues. Ifyou have any questions or concerns, you may contact Mr. Dave Trueman,

Manager ofReclamation's Upper Colorado Region Resources Managemont Division, at 801-524-3759.

Sincerely,

Anne J astle

Assist t Secretary

for Water and Science

Identical letter sent to:

Mr. Nikolai Lash

Grand Canyon Trust

2601 North Fort Valley Road

Flagstaff, Arizona 86001