March 25, 2024

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

Summary:

On behalf of Utah Associated Municipal Power Systems (“UAMPS”) and the 50

municipally and community owned electric utilities that we represent, we thank the U.S. Bureau

of Reclamation (“BOR”) for the opportunity to serve as a cooperating agency for the Glen

Canyon Dam Long-term Experimental and Management Plan Draft Supplemental Environmental

Impact Statement (“LTEMP DSEIS” or “DSEIS”). In 2016, UAMPS served as a coopering

agency for BOR’s Final Environmental Impact Statement for the Glen Canyon Dam Long-Term

Experimental and Management Plan, and we hope to participate meaningfully in the process,

including by providing these comments on the LTEMP DEIS.

The information contained in the LTEMP DEIS is insufficient for UAMPS to reach a

preference for any of the alternatives presented. UAMPS is concerned about the increased rate

pressure that will result from the LTEMP DEIS, especially considering it is proposed to be in

place through operating year 2027 and does not appear to be a proven technique for reducing

small mouth bass populations. Considering the increased power costs and increase in fossil fuel

generation that will result from any of the Cool Mix Alternatives, it is unwise to proceed with a

plan that lacks sufficient scientific support. UAMPS also seeks clarification and alignment on

several items raised in the LTEMP DSEIS.

UAMPS’ Interest in the LTEMP DSEIS:

UAMPS is an interlocal agency and political subdivision of the State of Utah formed to

provide comprehensive wholesale electric energy services, on a not-for-profit basis, to

community-owned power systems throughout the Intermountain West. UAMPS membership

consists of 50 municipally and other community-owned electric utilities located in seven western
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

states. Thirty-seven UAMPS members are located in Utah. Most UAMPS members own and

operate a local electric utility system that provides integrated retail electric service to residential,

commercial, and industrial customers. UAMPS partners with its members to ensure that

electricity is affordable and reliable.

UAMPS currently manages 16 separate projects that provide power supply, transmission,

and other energy services to participating members. One of these projects is the Colorado River

Storage Project, named after the Colorado River Storage Project (“CRSP”) authorized by the

1956 Colorado River Storage Project Act, which provides power generated by the Glen Canyon

Dam (“GCD”). UAMPS serves as a single purchasing agent for our 34 members that have a firm

allocation of CRSP capacity and energy. In the aggregate, CRSP provides 642,994 MWh of

contract power to 228,253 end use customers. Additionally, UAMPS and its members regularly

purchase power off the grid and are therefore sensitive to market and regulatory forces that

impact electricity affordability and reliability.

Flows from GCD that do not generate power affect UAMPS members in two very

concrete ways: (1) They receive less power, which they must replace; and (2) the replacement

power usually nearly always costs more than power from CRSP, especially when the need for

additional power is unpredictable or at peak times. The increased costs are passed on to

customers at a time when many Americans are already struggling financially.

UAMPS Comment on LTEMP DSEIS Need, Purpose and Scope:

First, UAMPS seeks clarification from BOR on the “Purpose of and Need for Action” in

the LTEMP DSEIS. The LTEMP DSEIS states: “The need is to disrupt the establishment of the

smallmouth bass below Glen Canyon Dam.”1 This section uses the word “disrupt” rather than

“prevent,” which was the word used in the preliminary draft UAMPS received in January. It is

unclear to UAMPS whether the additional flows are designed to disrupt an already present

population or prevent the arrival of the population, and it would seem that the success criteria

would change depending on which circumstance applies. UAMPS requests BOR provide more

information on the objectives of the DSEIS with respect to smallmouth bass populations, and

how they will know if those objectives are being met.

Second, UAMPS seeks clarification from BOR on the purpose and scope of the DSEIS.

The stated purpose of the DSEIS is to “analyze additional flow options at Glen Canyon Dam in

response to nonnative, invasive smallmouth bass and other warmwater nonnative species

recently detected directly below the dam.”2 But BOR also states that the scope and the

assumptions behind the proposed alternatives “may vary depending on the specific resource

being considered.”3 Indeed, BOR states that it “would like the flexibility to implement

temperature-based flow options to target smallmouth bass, depending on where they are found in

the river.”4 BOR relies on temperature changes at river mile 15 and river mile 61. UAMPS seeks

clarification as to the exact scope of the DSEIS. Is it an area directly below the GCD or is it the

1 LTEMP DSEIS p. 1-6 (February 2024) (emphasis added). 2 LTEMP DSEIS p. 1-6 (February 2024).

3 Id. at p. 1-7 4 Id. at p. 2-3.
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

entire area below the dam and up to and including river mile 61? Is it targeting smallmouth bass

only, or all nonnative predatory fish? UAMPS believes that clarity and alignment on the purpose

and the scope of the DSEIS will ensure that the objectives of the DSEIS are met.

UAMPS Comment on LTEMP DSEIS Timing:

UAMPS disagrees with BOR’s comment that “[e]ven with a compressed schedule, the

information used in this analysis is sufficient,”5 especially given the relatively long

implementation timeline – through operating year 2027. BOR should be required to substantiate

the need for additional flows considering the adverse impact on UAMPS members from reduced

power generation. The additional flows anticipated in the proposed alternatives would occur at a

time when UAMPS members are actively seeking to develop new resources to meet load and

replace retiring resources. To lose valuable hydropower for nearly four years when UAMPS

members are facing upward rate pressure should require better supporting documentation from

BOR supporting the need and effectiveness for the additional flows. Though BOR acknowledges

that “[m]ore information may become available to evaluate particular resources as the NEPA

process develops,”6 UAMPS believes that the real and negative effects that the LTEMP DSEIS

will have on hydropower means that BOR should gather further data regarding our

understanding of smallmouth bass populations before allowing an experimental solution.

UAMPS Comment on Smallmouth Bass Data Generally:

UAMPS requests that BOR provide the smallmouth bass data that they relied upon to

inform the DSEIS. To be specific, UAMPS would like BOR to clarify what they meant when

they state that “[s]pecific data on [smallmouth bass] have been collected but are not available or

citable at this time.”7 Related to that inquiry, UAMPS would also like to understand what BOR

meant when it stated that “The smallmouth bass model does not link at this time to other

population models, such as the humpback chub integrated model.”8 It is because UAMPS takes

seriously its obligations as a stakeholder along the Colorado River, UAMPS would like to better

understand what data is not being cited to as part of this DSEIS. Further, and as it relates to the

overall need and purpose of the DSEIS, it is necessary to understand how the smallmouth bass

population impacts other native species like the humpback chub. Especially if BOR is proposing

specific additional flows that would impact hydropower production, UAMPS feels it is important

for UAMPS members and the public to understand what data is being examined, and also how

this data will be utilized to determine whether or not any of these flows will have a meaningful

impact.

UAMPS Comment on Directed Removal of Smallmouth Bass:

UAMPS seeks clarification on the results of direct removal efforts of smallmouth bass in

general. As stated in the DSEIS, “[i]n September 2022 and August 2023, the [National Park

5 LTEMP DSEIS p. 1-8 (February 2024).

6 Id. at 2-3. 7 Id. at 3-68.

8 Id.
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Service] began to deploy the EPA-approved fish piscicide rotenone to kill [smallmouth bass].”9

BOR also states that this is a practice that can take place where smallmouth bass have been

identified in the Colorado River, and UAMPS would like to know the results of these directed

removal efforts. UAMPS highly encourages BOR and the National Park Service (“NPS”) to

explore directed removal efforts that would accomplish the goals of DSEIS in a more efficient

and targeted manner than adjusting flows at GCD.

UAMPS Comment on Slough Modifications:

UAMPS finds that the discussion surrounding NPS’ ability to treat slough habitat

severely lacking especially in light of the fact that BOR states in the DSEIS that “[g]reater

number of small mouth bass have been capture in the Lee’s Ferry reach in 2022 and 2023 [...]

[m]ost of the smallmouth bass in the Les’s Ferry reach have been caught in and near the -12-mile

slough.”10UAMPS believes that treating the slough or otherwise addressing the large smallmouth

bass population at the slough appear to be an efficient and targeted way of addressing

smallmouth bass population growth in the Colorado River without reducing power generation.

Much like the directed removal efforts, UAMPS believes that BOR should exhaust these targeted

solutions first before addressing a broader and more damaging solution like additional flows

from GCD.

UAMPS Comment on Alternatives:

UAMPS would like additional details on the effectiveness of the alternatives discussed in

the DSEIS. In particular, BOR states that “[t]he effectiveness of [the Cool Mix with Flow Spike

Alternative] at achieving temperature goals, given certain river outlet works availability, would

be similar to those outlined in the Cool Mix Alternative.”11 (BOR also states that these two

would also have a similar effect as the Cold Shock with Flow Spike Alternative.) The net effect

of these three alternatives with similar outcomes would be “cooling down to river mile 15 and

the confluence of the Little Colorado River.”12 BOR concluded that the other Cold Shock

Alternative “may not be possible to reach desired target temperatures.”13 In summation, the

outcome of the one alternative that seems to be effective, is still effective at cooling down to

river mile 15. Given these alternatives, UAMPS seeks to better understand how any of the

discussed alternatives would cool the water sufficient to prevent smallmouth bass population

growth beyond river mile 15.

UAMPS Comment on Flows to Hydropower and Energy Costs:

UAMPS is deeply concerned about the impact of additional flows at GCD will have on

hydropower production and consequently energy costs. UAMPS is grateful that BOR recognized

in the DSEIS that:

9 LTEMP DSEIS p. 2-3 (February 2024).

10 Id. at 3-68. 11 Id. at 2-12. 12 Id.

13 Id. at 2-14.
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

bypassing the electrical generators at Glen Canyon Dam, the experiment will

reduce hydropower generation. Accordingly, WAPA will be required to purchase

replacement power to fulfill its contractual obligations to customers. The

experiment would markedly increase the amount of non-reimbursable costs drawn

from the Basin Fund and returned to the Treasury.

The net effect of all four cold water flows analyzed in this DSEIS will financially impact

ratepayers and the problem as BOR highlights is three-fold: (1) WAPA and UAMPS members

will have to replace the lost power; (2) the replacement power will likely be more expensive; and

(3) the replacement power will likely emit more carbon and air pollutants.14 While the Basin

Fund may off-set some costs, it must remain solvent. Moreover, the health of the Basin Fund is

critically important as it funds important environmental and salinity programs along the

Colorado River. This is all the more reason why UAMPS believes that it is crucial to get greater

clarity and alignment on what this DSEIS seeks to accomplish.

UAMPS Comment on Reliability:

UAMPS requests a detailed analysis of how increased flows and the reduced hydropower

that would result would affect reliability in the Western Interconnection. As an organization with

members in seven western states, UAMPS is acutely aware of the lack of capacity generation in

the West. Further reductions in output from GCD would be problematic to UAMPS members in

fulfilling their obligations to provide essential electric service to their communities.

Conclusion:

UAMPS values the longstanding working relationship that we have with BOR, WAPA,

NPS and other federal agencies with jurisdiction over areas of the Colorado River System. We

look forward to working together to resolve our concerns with the LTEMP DSEIS as we

collectively care for and manage such a valuable resource.

Sincerely,

Mike Squires, Esq.

Managing Director of Government Affairs

Utah Associated Municipal Power Systems

14LTEMP DSEIS p. 3-25 (February 2024).