Non-native Fish Control 

Environmental Assessment

Bureau of Reclamation

Glen Canyon Dam

Adaptive Management Program 

Technical Work Group 

June 29, 2011
 2002: Some tribes first expressed concern during the 2003-2006 removal 

experiment, resulting in mitigation using fish emulsion as fertilizer in the 

Hualapai tribal gardens.

 2007-2008: Non-native fish control was added as an important conservation 

measure of several U.S. Fish and Wildlife biological opinions on operations of 

Glen Canyon Dam.

 2010-2011: Annual Work Plan of the Glen Canyon Dam Adaptive Management 

Program for FY 2010-2011 one- two river trips to remove non-native fish at 

LCR. 

 The Pueblo of Zuni sent Reclamation a letter on June 30, 2009 in which Zuni 

Governor Norman Cooeyate expressed the Zuni Tribe’s concerns with the 

“taking of life” associated with mechanical removal, and the lack of 

consultation with the Zuni Tribe. 

 In response DOI representatives attended a meeting with Zuni tribal leaders to 

hear their concerns on September 15, 2009. In response, DOI cancelled the 

two planned removal trips in March 2010, reinitiated consultation with the U.S. 

Fish and Wildlife Service on cancelling removal, and later in 2010 began work 

on the EA.

History
PURPOSE

Reduce the negative impacts of competition and predation 

by rainbow trout and brown trout on the endangered 

humpback chub (Gila cypha) and its critical habitat in the 

Grand Canyon. 

NEED

Fulfill the conservation measures and terms and conditions 

of several U.S. Fish and Wildlife Service (USFWS) 

biological opinions, to contribute to the recovery of 

humpback chub by helping to maintain high juvenile survival 

and recruitment rates resulting in a stable adult population, 

and to address concerns expressed by American Indian 

Tribes over the killing of fish in the Grand Canyon, a location 

of cultural, religious, and historical importance to a number to 

tribes.

Purpose and Need
http://pubs.usgs.gov/of/2011/1012/

http://www.usbr.gov/uc/envdocs/ea

/gc/nnfc/Appdx-A-SDMreport.pdf

Structured Decision Making Project
SDM Results

D1 – Removal curtain – includes PBR Removal to test limiting emigration of trout 

from Lees Ferry to reduce trout numbers at LCR, and LCR removal as a means

to directly address the threat of predation and competition if needed. Mitigation

of freezing fish removed for beneficial use to address tribal concerns.

NATURAL 

RESOURCES

CULTURAL 

RESOURCES

SOCIOECONOMIC 

RESOURCES

Water Resources

Water 

Quality

Air Quality

Sediment

Vegetation

Terrestrial Invertebrates 

and Herptofauna

Aquatic Food Base

Fish

• Humpback chub

• Razorback sucker

• Other native fishes

• Trout

• Other non-native 

fishes

• Fish habitat

Birds

Mammals

Historic Properties

Traditional Cultural 

Properties

Sacred Sites

Hydropower

Recreation (including 

Public Safety and 

Sport Fishing)
 Conducted Cooperating Agency review from December 21, 2010 

to January 7, 2011, comments from all 8 CAs

 In February 2011, Science Advisors have reviewed the GCRMC 

Science Plan for the EA as well as the Runge et al. 2011 SDM 

Report.

 Conducted public Review January 28 – March 18 2011

• 35 comments total 

• 11 AMWG member comments, including 3 tribes

• 13 public (non-affiliated) comments

 AMWG and TWG Meetings (Jan 28, Feb 10, Mar 8, May 18)

 Now in second CA Review June 15 – June 29

 Second three-week public review in July

 Numerous tribal consultation meetings

 NHPA 106 letters on eligibility and effect went out on June 27 

and June 28

 Meetings to resolve effects under 106 this summer

EA Reviews
Comments received during Public Comment Period 

January 28 – March 18 2011

• 35 comments total 

• 11 AMWG member comments, including 3 tribes

• 13 public (non-affiliated) comments

Major themes of comments:

• Opposed to killing trout in general 

• Actions hurt Marble Canyon business owners

• Support of Tribal concerns and need to find resolution to this issue

• Need for better integration between the two EAs

• Concern on HFE risk to HBC due to trout response and predation

• Should be more focus on the science and answering questions of trout 

movement, emigration, ultimate effect of trout predation on HBC, and role 

of mainstem versus the LCR for HBC recovery

• Flow actions not adequately considered

• Need trout and HBC triggers to determine if LCR removal should take 

place

• Postpone LCR removal to better test the effects of trout predation on 

HBC
Refined Proposed Action

1. 10-year period of proposed action, 2011-2020.

2. Little Colorado River (LCR) reach removal, up to 6 removal trips per year 

3. Paria River to Badger Creek (PBR) reach removal, up to 10 trips per year.

4. All fish removed are moved alive to other waters for use as sport fish or 

euthanized for other beneficial use

5. Research:

a. Is Lees Ferry the source? Lees Ferry rainbow trout marking with PIT tags 

(fall) and increased Marble Canyon trout monitoring (summer)

b. Can PBR removal work? Two PBR removal Trips initially (winter)

c. Is predation limiting HBC recruitment? Is mainstem important habitat?

 LCR removal ONLY IF adult humpback chub abundance drops 

below 7,000 adult fish

 Increased marking and monitoring of young HBC

e. Are other NNFC methods better? Begin 1-2 year process with 

stakeholder involvement to develop and test feasibility of GCD flow 

releases and other non-flow options to reduce rainbow trout

f. Safety Valve: In 2014 Reclamation will undertake science review 

workshop with scientists to assess first two years of non-native fish 

control
Next Steps

The EA is available on the Reclamation website at:

http://www.usbr.gov/uc/envdocs/ea/gc/nnfc/index.html 

Reclamation intends to provide the public with another draft of the 

EA for a two-week review in July.

Conclude process by Summer 2011 with a decision notice.

Cooperating Agency Comments are due by June 29, 2011:

Bureau of Reclamation, 

Environmental Resources Division

125 South State Street, room 7218

Salt Lake City, Utah 84138 

e-mail to: fishcontrol@usbr.gov

For more info call Glen Knowles at (801) 524-3781
High-Flow Experiment 

Protocol Environmental 

Assessment Update

Glen Knowles 

Bureau of Reclamation

Glen Canyon Dam 

Adaptive Management Program

Technical Work Group Meeting

June 29, 2011
HFE Protocol EA Chronology

• Announcement by Secretary: Dec 9, 2009

• Federal Register Notice: Dec 22, 2009

• Initiate Public Scoping, AMWG: Feb 3-4, 2010 

• HFE Workshop: June 17-18, 2010

• Conference Calls w/10 Coop Agencies: JulDec 2010

• Coop Agency Review Draft: Nov 23-Dec 6, 

2010

• Public Review Draft: Jan 14-Mar 18, 2011

• Cooperating Agency Review: June 15-29, 

2011
The Protocol

• A formal set of rules and procedures to be followed during 

a particular research experiment.

• Experimental in nature and to facilitate better learning of 

how to incorporate high dam releases into future operations 

in a manner that effectively conserves more sediment by 

depositing on beaches and sandbars above the stage of 

MLFF dam operations.

• Sandbar building potential is greatest by generating the 

greatest possible sand concentrations and largest possible 

areas of inundation, both of which are maximized by 

increasing flow magnitude.

• Sandbar building occurs as long as elevated sand 

concentrations are maintained and there is still space 

available to deposit sand; thus high flows should be of as 

long a duration as can be maintained with available sand.
Purpose and Need

• Purpose: (1) to develop and implement a protocol 

that determines when and under what conditions to 

conduct experimental high volume releases, and (2) 

to evaluate the parameters of high-flow releases in 

conserving sediment to benefit downstream 

resources in Glen, Marble, and Grand Canyons.

• Need: This action is needed to take advantage of 

future sediment-enriched conditions in the Colorado 

River with experimental high flow tests that will 

improve the understanding of the relationships 

between high dam releases of up to 45,000 cfs and 

sediment conservation.
HFE Protocol Paradigms

• Store and Release

– developed by USGS and was first introduced as the basis 

for the HFE protocol in a June 2010 modeling workshop

– relies on accumulation of sand during periods of aboveaverage sediment input from tributaries to achieve sediment 

enriched conditions called for in the development of the 

HFE protocol (74 FR 69361); decisions occur over months

• Rapid Response

– proposed in September 2010 by Western Area Power 

Administration

– requires real-time coupling of tributary sediment inputs and 

dam releases; decisions must occur in hours
Planning and Budgeting Component

HFE Protocol

Science Plan

(Research and Monitoring)

Annual Report Status of 

Resources (December)

Annual Resource Status 

Review (January)

Physical

Biological

Socio-economic

Cultural

Advise Interior on Resource 

Status
Modeling Component

0

50

100

150

200

250

300

350

400

JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUN

Average Monthly Sand Load

(thousands of metric tons)

Paria LCR

Fall Accounting Period Spring Accounting Period Fall HFE Window (Oct/Nov) Spring HFE Window (Mar/Apr)
HFE 

No.

Flow 

Magnitude 

(cfs)

Duration 

(hours)

HFE 

No.

Flow 

Magnitude 

(cfs)

Duration 

(hours)

1 45,000 96 8 45,000 1

2 45,000 72 9 41,500 1

3 45,000 60 10 39,000 1

4 45,000 48 11 36,500 1

5 45,000 36 12 34,000 1

6 45,000 24 13 31,500 1

7 45,000 12

HFE Protocol – Flow magnitude and 

duration for Model HFEs
Decision and Implementation Component

Computer Model Determination

(CRSS, Sand Storage, Flow 

Routing)

Interior Considers 

Recommendation and Resource 

Status; May Also Consider AMWG 

Input; Decision Made

If Yes to HFE, Technical Staff from 

USGS Prepare for HFE. 

If No, Wait for Next Cycle

HFE Occurs Technical Staff Analyze 

Results of HFE for Use 

in Future HFE 

Decisions

Staff Review of Model Output,

Status of Resources, and 

Consideration of HFE Effects; 

Recommendation to Interior
PHYSICAL RESOURCES CULTURAL RESOURCES

Water Resources Historic Properties

Water Quality Sacred Sites

Air Quality SOCIO-ECONOMIC RESOURCES

Sediment Hydropower

BIOLOGICAL RESOURCES Recreation (including Public Safety)

Vegetation

Terrestrial Invertebrates and 

Herptofauna (Kanab ambersnail)

Aquatic Foodbase

Fish

• Humpback Chub

• Razorback Sucker

• Non-Listed Native Fishes

• Trout

• Other Non-native Fishes

• Fish Habitat

Birds (Southwest willow flycatcher)

Mammals

 

Assessment of Effects
Numerous comments, meetings with agencies and stakeholders, 

resulted in changes to the EA ;

 Numerous Cooperating Agency Meetings

 Many Tribal Consultation meetings

 CA Review Nov 23-Dec 6 2010

 Public comment period January 14 – March 18, 2011

 January 20, 2011TWG Meeting

 February 8-9, 2011 AMWG Meeting

 March 7-8, 2011 TWG Meeting

 May 18 AMWG Meeting 

 Science Advisor Review of Science Plan

 Now in second CA review period, June 18-June 29

Comments and Input on HFE EA
Some of the Comment Received

• 77 responses (19 GCDAMP members; 5 Tribes; 9 

State; 4 Recreation; 7 Environmental; 3 Water and 

Power; 42 No identified affiliation)

• Main Recurring Issues

– Scope, T&E impacts, and EA interactions require EIS

– Must coordinate and integrate two EAs

– Underestimate negative impacts of trout and overestimate 

positive effects on native fish

– Protocol decision process is unclear; needs more detail

– Insufficient for GCPA; missing targets for measures of 

success

– Insufficient consideration of navigation risks; other safety, 

property and financial impacts from low and high flows
Some of the Revisions Made

• Clarify that the HFE Protocol will be conducted during the period 2011-

2020 as an experimental action

• Clarify that the HFE Protocol is a component of Interior’s compliance 

with the Grand Canyon Protection Act, in its entirety

• Clarify that the HFE Protocol would be carried out under the 1996 

ROD, the 1997 operating criteria, and the 2007 interim guidelines 

wherein annual release volumes are amounts of water released in a 

water year, Oct 1 – Sep 30

• Updated the literature cited to include recently released publications 

and corrected previous errors identified by cooperating agencies and 

the public

• Provided additional information on the relationships and interactions 

between the HFE Protocol EA and the Non-native Fish Control EA

• Added text to better identify how uncertainty will be addressed using 

CEQ guidelines for the inclusion of adaptive management into the 

NEPA process

• Monitoring of resources – If monitoring shows that there are 

unacceptable impacts, such as a significant decline in humpback chub 

numbers, reclamation would suspend implementation of the protocol.
Reclamation intends to provide the public with another draft of the 

EA for a two-week review in July.

Reclamation needs to complete consultation with FWS, complete 

tribal consultation and NHPA compliance, and complete NEPA 

compliance to implement the HFE Protocol.

Conclude process by early Summer 2011 with a decision notice.

The EA is available on the Reclamation website at:

http://www.usbr.gov/uc/envdocs/ea/gc/HFEProtocol/index.html

Comments are due by June 29, 2011:

Bureau of Reclamation, 

Environmental Resources Division

125 South State Street, room 7218

Salt Lake City, Utah 84138 

e-mail to: protocol@usbr.gov

For more info contact Dennis Kubly at (801) 524-3715

Next Steps
Glen Canyon Dam 

Long-Term Experimental and Management 

Plan Environmental Impact Statement

Bureau of Reclamation

Glen Canyon Dam 

Adaptive Management Program

Upper Colorado Leadership Team 

June 29, 2011
 First announced by Asst. Secretary Anne Castle at the August 

AMWG Meeting that Secretary of the Interior Ken Salazar had 

directed development of a of the Long Term Experimental and 

Management Plan.

 Will be led by the Bureau of Reclamation and the National Park 

Service as co-lead agencies.

 Will include multiple cooperating agencies, including Federal, 

Tribal, State or Local agencies or governments.

 2011 will be primarily determining and designating 

cooperating agencies and scoping.

 Effort will be on an expedited schedule to draft EIS.

Long-Term Experimental and 

Management Plan EIS
 Purpose and Need will be focused on continuing adaptive 

management through the GCDAMP to meet requirements of Grand 

Canyon Protection Act, the Law of the River, and other laws, to 

continue the adaptive management experiments that have been 

successfully completed under the GCDAMP.

 Will build on prior experiments, such as the 1996, 2004, and 2008 

HFEs, and learning gained through implementation of the High Flow 

Experimental Protocol, non-native fish control experimentation, and 

other experiments. Reclamation will utilize information developed 

during prior NEPA process, the ongoing EAs and LTEP EIS Process.

 Alternatives to be considered include dam operations and other 

actions under the authority of the Secretary of the Interior in keeping 

with the GCPA, Law of the River, other laws.

Purpose and Need, Proposed Action
 Identify and formalize Cooperating Agencies.

 Define roles and responsibilities.

 Complete scoping and scoping comment analysis 

in 2011. 

 Begin to develop alternatives with cooperating 

agencies by the end of 2011.

Goals for 2011
 Kickoff meeting with potential cooperating agencies was held 

on February 11, 2011. We have received initial input from 

potential cooperating agencies.

 Now working with NPS on NOI for publication in the Federal 

Register, NOI is now signed in the cue for publication in the 

Federal Register.

 Scoping meetings in Phoenix, Salt Lake City, possibly 

additional cities.

 More to come...

Next Steps