General Core Monitoring Plan 

TWG COMMENTS/GCMRC RESPONSE TABLE 

September 21, 2010 

DOCUMENT: General Core Monitoring Plan for the Glen Canyon Dam Adaptive Management P(October 26, 2009) 

Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

1 General Capron Western Summary: components of the plan that I feel would make the 

plan more robust and useful to the AMP: 1. Discussion of other programs with long term monitoring 

needs (e.g., LTER program). 

ThieffeactiManotheof thto sprogNPS but othenati

2 2. Discussion of trade-offs between precision, increased 

monitoring, cost, and effectiveness and how the program should look at the scientific implications. 

We Chathe com

3 3. Description of current and projected funding elements not 

under CM so that we can better see what is in and what is out. 

Thithis plan long GCman

4 4. Full integration of CMINs into the strategy for each goal. For 

conrevithe each redurevipriofor 
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

5 5. Key goals of our long term monitoring program. We 

Chaand 

6 6. Discussion of “core of the core” vs. other elements which 

might be good to have. 

The provinforevicurrIf thhighthe plan TWrefinCM

7 General Capron Western Criteria and strategy for developing a CMP. One of the tools I 

was hoping to see in this document was a set of criteria or a strategy for determining what the core monitoring programs should be. For example, it might be important to sample 

resource X for core monitoring, but at what frequency (monthly, yearly, triennially) or extent?. Based on the choices we make it inherently involves risk in the sense that by sampling less your power to inform the program is likely reduced. Also, the CMINs are somewhat vague and are open to interpretation -- one person may have a broader (inclusive) interpretation while others may have a more minimalist viewpoint on the type of information they believe should be collected. Criteria and a strategy are needed to evaluate these tradeoffs and to involve managers in the decision making 

process. For example, some potential types of criteria: 1. CMIN: activity is essential to address the minimalist view point for the CMIN. 2. Frequency/extent: a series of options might be given which show how the power is reduced, or other scientific effect, by either reducing or increasing sampling rate or extent. 3. Priority: relates to a high priority item. 4. Confidence: include only those activities with high confidence of relating to the eventual DFCs. etc. Until DFCs are defined, we are developing monitoring approached that allow us to track status and trends in relative conditions 

PrioThe core and the valiannrelaaccuTWmon

8 General Capron Western What if we don’t move forward right now with CM, are there 

LTEP (NEPA compliance) implications? 

CM manmon
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

expactiManto ghighhighprocCMit is effeand proc

9 General Capron Western It would be informative if there was a section addressing other 

long term monitoring programs and provide some background, 

lessons learned, approaches for these. For example, the LTER sites: http://www.lternet.edu/sites/

Plea

thindiscthis DOAMto frmonthoshow genthe condevCMmonprogSciethis 

10 General Palmer Western Western suggests a core monitoring plan that describes the 

long-term monitoring: what data would be gathered regardless of the shorter term interests and current research. This suggestion is derived from the “Position Statement on Core Monitoring from the Core Monitoring Team” 9 April, 2004. In 

this document, the CMT suggests that the long term plan 

“adopt a minimalist framework (e.g., no ornaments on the Christmas tree)”. When first considered, the budget for GCMRC was uncertain. The TWG suggested developing in a plan that would continue in the face of budget shortfalls. The cost of the core monitoring plan (as opposed to the monitoring plan) should insulate it from significant budget shortfalls. Further, a plan that would be supported by the TWG and AMWG so that it wouldn’t need to be reviewed every year. 

Rework the plan within a minimalist framework 

Thineeand all gthe goaprogmonevaexpor nAMappneedecprogapp
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

infoAMbelicon

11 General Capron Western The document does not include line numbers which are 

essential in providing detailed comments. Recommend SOP that line numbers be required for all documents undergoing TWG review. 

Thinumdocof c

12 General Capron Western Chapter 1: I really appreciated this section. I thought it was 

generally well written and informative. 

Thafeed

13 Docum

ent wide 

Kurt Dongoske 

Pueblo of Zuni 

Overall this document is deficient in the consideration and integration of the Native American perspective in the monitoring of these core resources. Over the years, each of the participating tribes have been developing their respective monitoring programs, but there has been little to no effort by GCMRC to initiate consultation with the tribes toward the development of a program or a system into which the tribal 

monitoring data and perspectives of key resources is integrated into the overall monitoring program that is detailed in this plan. The Pueblo of Zuni finds this unacceptable and suggests that GCMRC should begin to develop a program with the 

tribes that incorporates tribal monitoring data into this plan. This is necessary for GCMRC to meet some of the monitoring goals/targetss that are identified in this plan. 

Initiate a dialogue with the tribes to design a progam to be detailed in this plan that delineates how tribal monitoring data and activities will be integrated into this monitoirng plan. 

GCthe wormonsountowhas conyearof Tmeeexpcollthe progwithand scopis uoccuthe occu

14 General Grand 

Canyon Wildlands Council, Inc. 

In general, the plan is well written and referenced, and several elements are sufficiently well researched to merit moving them towards core monitoring status, including: Goals 2 (native fish), 4 (trout), 7 (flow and WQ), 8 (sediment), 11 (cultural), 

and perhaps 10 (economics). Basic understanding and suitable protocols for the other goals either have not had sufficient study and integrated analysis, or involve on-going projects that 

are essential for developing efficient, effective monitoring protocols; therefore, understanding of the other goals does not yet warrant transition into core monitoring. Overall, we recommend that the core monitoring plan be implemented gradually, with elements added when scientifically merited over the decade. Annual reporting on CMP implementation should be made to AMWG, including the status of elements 

Thi
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

not yet included, and revisions that arise to existing protocols. GCMRC has made a good effort to begin to codify a long-term core monitoring program for the Colorado River ecosystem (CRE) affected by Glen Canyon Dam. It is gratifying to see that the many historical reports and peer-reviewed literature are cited and help contribute to the foundation of the present effort. Those involved in previous phases of scientific understanding of CRE component and process interactions contributed much to the development of a coherent CMP. Recognizing the derivation of concerns, assumptions, and monitoring approaches is critical to meeting the scientific challenges of adaptive ecosystem management. 

15 GCWC Consider a search and replace for “spring” (the season) with 

“springtime”, and to pluralize “spring” as “springs” to eliminate confusion over these terms in the context of the CRE. 

OK 

16 GCWC We didn’t see any acknowledgements or even authorship in 

this document. Science in the real world requires accountability, so please place the authors’ names on the document. Also, it would be polite to acknowledge those who 

contributed to the writing. 

We Pleathe provhistackn

17 GCWC Although not specifically necessary for this document, it is 

appropriate for the GCD-AMP to consider compiling an administrative history of its program – the why, who, when, did what, and where elements of program history, including documentation of existing precepts (and biases), the scientific literature generated by the program, and contemporary concepts and issues. Such a compilation will clarify conceptual advances, and prevent the program from repeating inquiries as time goes on. This is already a problem for the program, and 

enough of the historical figures are still with us to accomplish 

such an undertaking. Please consider contracting to an administrative historian outside of the federal government for such an undertaking. 

ThiNRsubjbein

18 GCWG Please clarify how changes in core monitoring protocols will 

be incorporated over time. We expect that improved protocols will arise through future PEP reviews, and expect that such shifts will include methods to calibrate past data with future data, to extend data interpretation. We did not see mention of this process in the CMP. 

Thi

descdocprog

19 NPS General Comment: if the format for commenting is to include 

line numbers, then the pages need to include line numbers. 

See 

aporesuthro
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

20 NPS General Comment: 2 weeks for review of a guidance 

document for the next 5 years is inappropriate. 

We requiniti

21 NPS General Comment: It’s interesting that in numerous places in 

the document, AMWG “decisions” are mentioned. Given that the AMWG is an advisory committee, it seems inappropriate for the stakeholder group to make decisions in this context. 

AMrecorevirole doc

22 NPS General Comment: Throughout the document, reference is 

made to the stakeholders needs, requests, decisions, etc... The program is the Secretary of the Interior’s program and the 

work conducted is for the Secretary to be able to make informed decisions. 

No 

23 NPS General Comment: 

As in other GCMRC proposals, there seems to be very little 

integration of monitoring with actual management activities that have been or may be implemented to achieve GCDAMP goals. 

The manand and necthe long monevahigh infomec

24 NPS General Comment: 

The plan should explain how the various relevant management 

agencies will be incorporated into the core monitoring programs. For example, there should be a strategic plan for how GCMRC and NPS will work together to get the data collected for Lake Powell. 

We agendefionc

25 NPS General Comment: 

There is no recognition of economic value core monitoring and 

R&D. The AMP is having a workshop in December to talk about priorities but not even a mention of the need is in this plan. 

TWdiscWe the 

26 NPS General Comment: 

There has been an on-going issue related to the systematic delay in reporting from the GCMRC. Remedies to this problem should be addressed in this document. 

Repagrehavto presu“sysWe oftewe manand con
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

effi

27 NPS General Comment: 

Integration of NPS Inventory and Monitoring Network (more details in comment below) and on-going park I & M should be included in this document. In addition, a recognition and integration, where possible, of similar upper basin science 

should be included. GCMRC’s work does not happen in a vacuum. 

We therto ainto plan asseactiby Goveprogthesvery monknocurrupprecebaseupp

28 NPS General Comment: 

It is unclear how NPS priorities were considered when developing the CMP priorities. 

NPS and deepprev

General Comment: The review period was extremely short and did not include an agency review before TWG review as GCMRC had agreed to previously. 

We 

with revibee

29 Table of 

Contents 

28-43 Grand 

Canyon Wildlands Council, Inc. 

Goals 1 (food base) and 2 (native fish) are listed as being the same. 

Thi

30 Table of 

Contents 

Goal 1 & 2 

Ted Kowalski 

Goal 1 and Goal 2 are identical, but in the document they are different. It is probably just a formatting issue, but if not, the document needs to better describe why Goal 1 and goal 2 are separately listed identically. (page 3, lines 28 and 36) 

See 

31 SA 4 Capron Western DFCs, clarification. In a number of places the need for DFCs 

is discussed. GCMRC responses are varied and should be coordinated to one response. In some places it is viewed as a TWG, AMWG, AMP, and a GCDAMP responsibility. I think it is clear that DOI has taken on this responsibility and that the 

AMP has been told to stand-down on DFCs and MOs until further notice. But there seems to be a recognition among AMP members that DFCs are needed for this program to be successful. This could be clarified in the document and responses. 

OKong
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

32 SA 6 Capron Western Can or should the program move forward with CM without 

DFCs? Here, and in many other places, the need for DFCs is articulated. We all recognize the importance of DFCs to the 

program, but is it prudent to move forward now with a CMP without them? I would suspect that many activities would occur regardless of the DFC (e.g., LCR HBC monitoring, water temperature). I can also see activities that might not be implemented in the same way if we had DFCs (e.g., tributary fish monitoring, beaches throughout the canyon, perhaps sediment mass-balance). It occurs to me that the development of CM must be an iterative process: 1. CMINs are developed and prioritized. 2. The AMP provides draft guidance to GCMRC on the total budget which should be used for core monitoring needs. 3. GCMRC develops monitoring program based on the CMINs and draft budget. 4. The AMP reviews the proposal and considers risk of not doing activities on information needs and needs for funding in other areas. 5. The CMP is revised based on AMP feedback, some programs are scaled back/cut and others may be added. Steps 3-5 could be iterative over a number of years to reach consensus. 

Thiprogand MRinfowisDFC DFCthe adoWe AMavaappto rto mprogDOof thcongoaa fenumdecadd

33 SA 11 Capron Western Figure 4 is a good start to a conceptual model, but agree with 

the SA comment that it could include much more. It is a very complicated system, but I think one could create a very large one sheet representation of linkages, including CMINs and research – of course it wouldn’t fit on a small sheet, poster size. I find these types of schematics to be helpful to illustrate the decision points (or results needed) and data necessary to support them. I don’t feel like Figure 4 get’s us there, but doing something more complicated would take substantial time. 

We conmonmodgoathe 

34 SA 13 Capron Western I agree that remote sensing is expensive and the utility is 

unclear to me across programs. Could we meet our needs with less expensive approaches in some areas? No doubt remote sensing is an amazing tool, and it may be important to include 

in the program on some levels, but maybe not to the extent that it is. It might be good to dedicate some discussion time to 

remote sensing at the workshop. 

We aborem

35 SA 17 Capron Western I’m still not clear on the LCR reach sampling need and plan. It is 

recothe 

36 SA 24 Capron Western I also agree that data could be served in graphical mode and 

that it could be beneficial to the program. NMFS also serves a 

OK
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

lot of data in this way on fishing activity, sea lion counts, fish survey data, catch rates, etc. Most of it is automated now. 

37 Iii 36 Should be fish and not foodbase Thi38 NPS GRCA Chapter 1 Introduction and Background 

This is an interesting history of the program. It seems that many of the same obstacles that prevented work in the early 1990s are still in place today. Perhaps the GCMRC should address the problems of the AMP rather than continue to push forward with programs that may never be implemented. A good example of this would be how the NPS continues to ask for specific information, have programs address NPS needs, and for reporting in a timely manner. In some cases the NPS has refused to issue permits and therefore implementation of GCMRC’s desired programs has been delayed. Shouldn’t the individual stakeholders information needs be included in a CMP? Multiple stakeholders have issues with work proposed, yet those issues are not addressed and it appears that GCMRC resolves the issue by elevating the concern to their regional director. 

GCall AprogGCwith idenGCbee

39 1 Line 

numbers not provided; to do so would be beneficial in future reviews 

Kubly BOR A wider look at the monitoring literature would improve the 

introduction to this document. The purposes of monitoring can go well beyond the four identified purposes in the draft CMP, 

particularly in an active adaptive management program where comparisons of resource state are made before and after major experiments. Some examples that you may already be familiar with are: MacDonald, L.H., A.W. Smart and R.C. Wissmer. 1991. Monitoring guidelines to evaluate effects sof forestry activities on streams in the Pacific Northwest and Alaska, an oft cited EPA document, identify 7 types of monitoring and the general characteristics of each (note MacDonald is identified on p. 6 of this document). Green, R. H. 1979. Sampling design and statistical methods for environmental 

biologists provides a description of BACI (before and after, control and impact) monitoring, which has relationships to GCDAMP monitoring needs. A third applicable reference, particularly to assessment of flows in Australian regulated rivers, is Chessman, B. and H. Jones. 2001. Integrated monitoring of environmental flows: design report. Department of Land and Water Conservation, New South Wales, Australia. 

Provide broader perspective on monitoring 

Yes, et seq. We 

revithis monto rappaddprevPlan

40 1 Kubly BOR It is not clear to me how a 4-step process that ends with 

“prepare final core monitoring program reports for each resource goal” produces project-level core monitoring protocols. Could you elucidate how the identified reports become proposals for monitoring? Or is this just a semantical difference? 

The been versand 
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

41 1 33 Barger Wapa Please clarify the purpose for the information needs workshop 

here. 

Add language The 

in C

42 1 34 Barger Wapa This discussion of PEPs is problematic since the PEPs are to 

review the monitoring aspects of each program. They are not for the core of the monitoring program. Somehow, there needs to be a way to get at the core of the monitoring. This is also a general comment for this document. 

Add language See 

(e.g

43 1 41 Barger Wapa Please include the year that the AMWG priorities were set. Change 

language 

OK

44 2 Kurt 

Dongoske 

Pueblo of Zuni 

Please change “Zuni” to “Pueblo of Zuni” or “the Zuni Tribe of the Zuni Indian Reservation” 

yes OK

45 2 Grand 

Canyon Wildlands Council, Inc. 

It would seem relevant to cite Stevens and Gold (2002) here, as we presented the AMP strategy to the science and monitoring communities. Note that the year (2002) of that citation should be changed throughout the text, as 2003 was the date of a widely read review of that book, not the publication date. Also, it would be relevant to cite Lovich and Melis (2007), who tested the premises and preliminary results of the program. 

The thropubpubpub

46 2 Kubly BOR I do not find the term “management action” in the GCPA 

language. There is reference to “activities that that will ensure that Glen Canyon Dam is operated in a manner consistent with that of section 1802” in addition to monitoring. Since the GCDAMP is still in the process of defining management actions, could you be more specific on where in the GCPA you find this reference, including which actions would apply. 

SecundGCwith 

47 2 29 Barger Wapa This state that the GCPA allows for management actions, but 

this language is not in the Act. 

Please rewrite See 

48 2 47 Barger Wapa The sentence, “In a broad sense...” overstates what is in the 

GCPA. These are the resources for long term monitoring for the effects of dam operations. 

Please rewrite We 

this 

49 3 P. 3, 

L.17; P.7, L. 30-39; P. 18, Fig. 3 

Grand Canyon Wildlands Council, Inc. 

We argue that the areal scope of the GCDAMP prevents or actually prohibits (rather than “effectively constrains”) the program from achieving its scientific adaptive management goals. River ecosystem analysis requires several forms of scientific controls, including comparison of less affected reaches upstream from the dam with the impounded reach. Not being able to evaluate ecological conditions in Cataract Canyon, upstream from Lake Powell, has kept the GCD-AMP from testing many embedded biases and potentially incorrect assumptions about ecosystem stewardship options, the resolution of would greatly improved the efficiency and effectiveness of the program. 

We PEP assoThe agrestakstud

50 3 Kubly BOR The razorback sucker and southwestern willow flycatcher are 

included in conservation measures, but absent from your list of 

We list 
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

federally listed species. com

51 3 Kubly BOR GCMRC seems to constrain the scope of monitoring beyond 

the language that you cite. The word “primarily” suggests that there may be activities outside the geographic scope that you 

identify, as there are for the Little Colorado River fish investigations. If there are differences of opinion on the geographic scope, they can be made through an in-out process, rather than defined in the general core monitoring plan. 

The 

the 

52 3 1.3 NPS Please note that in discussing other compliance requirements 

that the CMP is trying to respond to, other agencies have the responsibilities and that needs to be reflected in the document. All the actions and responsibilities are not those of GCMRC 

alone. 

OK

53 3 14 Werner AZ The geographic scope is defined in the Strategic Plan through 

the definition of Colorado River Ecosystem. That definition 

discusses tributary streams. Later in the CMP there is mention of tribs. The text on p 3 should be revised to reflect the definition in the glossary of the Strat Plan. 

 Revise text for clarity 

Y The 

stra

54 3 31 Barger Wapa This is not just for status and trends, but for how these relate to 

dam operations. The focus of long term monitoring is on dam operations effects. 

Add language In th

monstra

55 4 26-37 Grand 

Canyon Wildlands Council, Inc. 

The earliest records of information from the CRE began with the photography and diaries by nineteenth century explorers (Powell, Stanton, etc.; as documented by Turner and Karpiscak 

1980, Webb 1996, Stevens et al. 1997a, and others). 

Collections of insects (some of which are Grand Canyon endemic taxa) began prior to 1900 (e.g., Stevens and Huber 2004). The 1934 Rockefeller Expedition contributed much additional information on low-elevation insect life in Grand Canyon, and the 1938 Nevills expedition contributed substantially to knowledge of CRE flora (Clover and Jotter 1944). Efforts to compile species lists were undertaken, most notably by Bailey, McKee, MacDougall, and others. Other early sources of information are listed in Stevens et al. 1997a, sources which predate those listed on P. 4. 

We comCan

56 5 4-11, 

43-48 

Grand Canyon Wildlands Council, Inc. 

The raison d’etre of the GCES and subsequent GCMRC programs came about because river recreationists and wilderness advocates responded strongly and negatively to 

Reclamation’s 1980 FONSI. That FONSI claimed that no 

impacts on camping beaches would result from increasing the already extraordinary daily flow fluctuations downstream. It 

has always surprised me that river recreation has received so little attention in this program and that river recreationists have not exerted their influence more strongly, given the seminal influence they have over public opinion. As another aside, it 

might be useful to review the environmental compliance to 

Not
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

evaluate which of the advocated changes contribute to our contemporary standards for ecosystem integrity. 

57 P.5, ; P.7 17-18; 

1-6 

Grand Canyon Wildlands Council, Inc. 

Primary among our early concerns with establishment of a CMP for the CRE was that our ability to foresee changes in the system have been poor. Each year, some form of major change occurs (e.g., erratic high or low flows, the arrival of an endangered or non-native species, such as peregrine falcon or bald eagle, and Ravenna-grass or quagga mussel), potentially 

shifting the ecosystem’s developmental trajectory. This indicates that we need to maintain a strong inventory program, 

a process that has largely been eliminated by GCMRC. We still do not know the identities of most of the zooplankton and macroinvertebrate taxa in the CRE, but efforts to document terrestrial invertebrate and vertebrate distributions have languished. Without recognizing the extent of our ignorance of 

these many life forms, efforts to manage ecosystem process will continue to founder because of unanticipated population changes of rare or ecologically important species. 

Inveidenseveidenupdresorespbrin

58 5 44 Werner AZ “turbine” should be replaced with generator. The water moves 

the turbine. A shaft connects the turbine and the generator, which has coils of windings of a conductor on it. 

Revise text for accuracy 

Y OK 

outcRecfor hyddiur

59 6 26-30 Kurt 

Dongoske 

Pueblo of Zuni 

Noticeably lacking from this symposium was the Native American perspective. No Tribes that were currently participating in the GCES and/or the development of the GCDEIS were asked to participate. 

N0 Not

60 6 Kubly BOR Suggest making “William Lewis” “Dr. William Lewis, 

University of Colorado, Boulder, the NAS Committee Chair.” 

ThidistFor sug

61 7 Kubly BOR The statements “Some AMWG members have expressed the 

desire to mimic these characteristics in Grand Canyon. However, the native fish populations in that reach appear to be in poor condition, though there are logistical limits on sampling there” seem out of place here. The point about the desire for controls and limits from geographic scope is adequately made. 

We Somdesithe and enhGra. 

62 P.7 

P.8 

41-50 1-2 

Grand Canyon Wildlands Council, Inc. 

The early vegetation monitoring program clearly understood 

the need for on-going inventory. Although we are likely 95% of the way along in understanding which plant species occur in the CRE, more than 50% of the species in Grand Canyon occur within several hundred m of the river elevation, and new species are detected each year. Therefore, an on-going inventory and related protocols are needed in this plan to 

See 
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

continue documentation of plant species and their distribution, of both native and non-native taxa. 

63 8 38-39 Kurt 

Dongoske 

Pueblo of Zuni 

“National Historic Preservation Act Programmatic Agreement for Cultural Resources” is the title of the appendix in the Final EIS. The actual title of the agreement I believe is Programmatic Agreement among the Bureau of Reclamation, 

the Advisory Council on Historic Preservation, the National Park Service, The Arizona State Historic Preservation Officer, 

Havasupai Tribe, Hopi Tribe, Hualapai Tribe, Kaibab Paiute Tribe, Navajo Nation, San Juan Southern Paiute Tribe, Shivwits Paiute Tribe and Zuni Pueblo Regarding Operations of Glen Canyon Dam. The actual title may be a preferable use in this document. 

No Not

64 8 NPS The NPS archaeological site monitoring program begun in the 

1970’s was not “informal”; specific sites were identified, photo replication points identified and assessments taken. The only thing informal was the schedule of monitoring episodes. 

Standardization of information came in the 1980’s and 1990’s, 

but the early work was not “informal”. 

We but todamor

65 8 5 Kowalski Colorado Add the following. “It is within the context of the Law of the 

River that the Glen Canyon Dam Adaptive Management Program operates.” While this is implicit, Colorado would like it to explicitly state this. 

Thipagthis 

66 9 Kubly BOR Do the references to “final” PEP reviews indicate there are no 

plans for further PEP reviews in these resource areas? Or should final be changed to most recent? 

OKRev

67 10 Kubly BOR How accurate does the conceptual model have to be in 

predicting the outcome of experiments before it has utility for 

managers to “serve as reliable tools to inform policy 

decisions”? Have the managers been queried to determine the accuracy and precision necessary for this use? What accuracy and precision are necessary from the monitoring to support the conceptual model development? What are the respective roles of GCMRC and managers in this determination? 

All the idenneecon

68 11 Kubly BOR You make the statement that “[t]he experimental designs 

proposed and implemented in the GCDAMP have been a direct and logical outcome of conceptual modeling activities.” It could be argued that the proposed experimental designs have 

largely not been implemented, e.g. the GCMRC 16-year block design. Could you give examples to support your statement? 

The best conNSE 

69 11 Kubly BOR You end the history of monitoring without any analysis of PEP 

panel recommendations or the extent to which they have been incorporated. This includes recommendations on design and statistical analysis, including the use of power analysis to develop designs and set sampling levels to achieve desired precision. Suggest adding a section for this purpose. 

Indi

addinto An anawithmon
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

add

70 11 Kubly BOR I believe the Science Planning Group was a TWG ad hoc 

group. 

No, by d200

71 11 26 Barger Wapa Another factor that has hindered development of the core 

monitoring plan is the lack of agreed-upon DFCs. 

Please rewrite this section 

OK

72 11 19-25 Grand 

Canyon Wildlands Council, Inc. 

GCMRC has played a large role in maintaining a state of confusion with regard to monitoring in the GCD-AMP. GCMRC has had to be forced to synthesize important flow experiments that shape AMWG understanding of its stewardship options (e.g., the Year 2000 flow experiment - the most costly and least successful ecosystem experiment ever conducted), and has reported as fact preliminary results that 

have not necessarily been born out after final peer review. Will 

we ever know whether trout or warmer water was responsible 

for stabilization of LCR humpback chub population, or even whether the trout population reduction there was really due to GCMRC activities, or just to system-wide collapse of the trout population? Presentation of conflicting results, other communications issues, and continuing lack of advocacy for a whole-socioecosystem approach by GCMRC helps keep the AMP monitoring program in limbo. The AMP involves shared responsibility, but this paragraph inappropriately lays all the programmatic blame on the AMWG, which has been recipient of rather many of GCMRC’s mixed messages. Let us work together rather than at odds to be better stewards of the CRE. 

Para“Otprogmonamoand lack and withdefikindeffeof sof aand to a

GCacceplaycore addwelmonthat tied focuplan for sugwillhoc and 

73 11-12 Grand 

Canyon Wildlands Council, Inc. 

The cause for confusion over the development of an efficient, effective CMP has been the failure of both the AMWG and GCMRC to adopt a whole-socioecosystem approach for the CRE, resulting in the still on-going Christmas tree (or “pin the tail on the donkey”) approach to ecosystem management and, to some extent, monitoring. The 2005 knowledge assessment 

Whbe mgoalimihavspec
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

workshop participants clearly recognized the large gulf between scientific understanding and management, yet GCMRC and AMWG consistently underestimate the depths of that uncertainty, particularly with regard to biological resources. More detail on that KAW report is needed on P. 14 to clarify the extent of that uncertainty and its implications for both science and management. Also, development of the CMP has been thwarted by increased emphasis from AMWG to move to a management approach before the scientific information has been sufficiently integrated to support such a shift. 

condesisommonthe 

74 12 Kubly BOR Surely GCMRC did not answer to the Core Monitoring team 

and would return to the TWG or AMWG before investing a significant amount of time and energy in the Christmas tree ornament approach. Missing from this portrayal are the strong concerns voiced by some team members that the core monitoring budget not exceed 40-60% of the science budget and that without some idea of the relationship among sampling frequency and precision and cost, coupled with the lack of desired future conditions, that it was difficult to identify the desired variables and the sampling regime. 

We adddiscthe morwhe

75 12 Kubly BOR The discussion of green, yellow and red should bring to bear 

the division of the science budget into core monitoring, research and development, and experimental components. Here again there was emphasis on ensuring the core monitoring budget would not grow to the point that it crowded 

out the other two important components of science endeavors. 

See 

76 12 25 Barger Wapa It is unclear why the outcome was to develop a plan with the 

Christmas Tree when in the position statement from the CMT, it sates “adopt a minimalist framework (e.g. no ornaments on the Christmas tree). I recall Jeff telling us that if we do all the ornaments, then the plan cannot work. 

Add language The 

to thmonthis throAMhav

77 13 Kubly BOR It would be beneficial to summarize the findings of the 

Science Advisors on draft CMPs, in addition to those of CMT and TWG members. 

We comthis imppres

78 14 12-24 Kurt 

Dongoske 

Pueblo of Zuni 

My sense is that the tribes have a different perspective of this workshop than the one presented here in the text. Does this last sentence imply that GCMRC is washing their hands of tribal involvement in any of the science monitoring and/or research 

programs it is currently managing or will be developing? As pointed out above, there is a serious lack of integration of tribal monitoring activities and perspectives in this proposed 

monitoring plan that is to be administered and managed by GCMRC. 

No As 

is ocolldesiprotapppropthis 
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

79 14 Kubly BOR The distinction between compliance activities and science 

activities reference tribal monitoring is misdirected. Tribes 

have delivered their protocols to TWG and to GCMRC. If the protocols are wanting in scientific rigor, suggestions for their improvement should be provided. 

GCprotfundstatfrom proj

80 14 7 Barger Wapa There were discussions with the CMT that not all of a program 

would be core monitoring; maybe just a small part of it and 

how that could be shown for budget purposes/ and shown on 

the AWWP. 

Change language 

A lopast recoAMto ain th

81 15 Kubly BOR Were KAW outputs explicitly incorporated into core 

monitoring development? 

The that addmon

82 15 Kubly BOR I assume that you will return to a fuller discussion of the 

prioritization process developed by the SPG. It deserves more attention. Also, there was an important kick-off meeting of the SPG with the Science Advisors that is not noted. 

It won tmos(whaddduriPEPmon

83 15 5-9 Grand 

Canyon Wildlands Council, Inc. 

Desired future conditions have been established by the NPS, although other stakeholders with resource management responsibilities have not necessarily endorsed all parts of those DFC’s and not all DFC’s may be achievable. As recognized in the document, this programmatic deficiency greatly hinders all aspects of adaptive management, and we suggest that clearlydefined DFC’s must be defined. The feasibility of achievement of those DFC’s should be completed prior to finalization of a 

CMP and other program plans. Resolution of CRE DFC’s is likely to require a major federal process. 

See 

84 15 17 Barger Wapa The SPG did put together a recommendation for DFCs for 

sediment and HBC. 

OK

85 16 

17 

10 8 

Grand Canyon Wildlands Council, Inc. 

elsewhere, and in References Cited: Stevens and Gold 2002. Thi

articwhi

86 16 14 Barger Wapa Please clarify what the informed decisions are regarding. Change title The 
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

87 16 19-25 Grand 

Canyon Wildlands Council, Inc. 

Self promotion by GCMRC, a federal office, is not warranted, 

here or anywhere. GCMRC could be replaced by a wellmanaged consortium of academics, coupled with USGS water 

flow and quality monitoring, and overseen by a senior scientist. GCMRC has expanded to a very large staff, far beyond the scope of that originally identified in the 1996 ROD, with most research and monitoring only indirectly under the control of the AMWG. Limited ecosystem-level expertise and failure to integrate historical data by GCMRC has contributed to the failure of the AMP to resolve numerous biological challenges to CRE stewardship. 

Selfparacharfailuecofundannecoare morfunda br

88 17 Fig. 2 Kubly BOR I think Goal 12 is broader in context than successful 

monitoring and research. It entails the interactions among the scientific, political, and legal constructs of human interactions that determine whether the knowledge gained in adaptive management is successfully integrated into policies, including policy change where warranted. There is a rich and evolving literature on this subject that transcends adaptive management 

and enters into the realms of adaptive co-management and adaptive governance. 

We not limi

89 17 Fig. 2 Grand 

Canyon Wildlands Council, Inc. 

Good job with relating GCDAMP goals to ecosystem structure. An expanded version of this general model, in keeping with Walters et al. (2000) would show variation in trophic-goal relationships with distance downstream from the dam, and that not all biological resource impacts are affected by flow and sediment management. 

OK

90 18 figure Barger Wapa This seems to be a monitoring figure, not a focused “core” 

monitoring figure. 

Needs more language. 

The monwithFigu

91 18 Fig. 3 Kubly BOR Effects monitoring is identified in this diagram. I think the 

different kinds of monitoring should be introduced early in the document (see my first comment) and distinguished from one another to set the stage for defining core monitoring. That could be done in an even broader sense by introducing this diagram early in the document. 

OKwheclar

92 18 Fig. 3 Grand 

Canyon Wildlands Council, Inc. 

is the caption offset? Also, the role of scientific controls should somehow be represented in this figure. 

Yes vershow figu

93 19 1 Barger Wapa This discussion is another example of the focus of this 

document on general monitoring, not core monitoring. Somehow there needs to be more discussion of how to find the core of monitoring. 

Thiwhathe (CMis u
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

“genaddnee

94 19 2.2 NPS It is difficult to understand how the CMP can meet the 

outlined objectives of unambiguous and measurable while also stating that the plan is currently designed to report “relative measures”. Defining resource condition and targets is critical to the success of the program. Without those unambiguous and measurable measures, it seems that the plan will repeat the 

very pitfalls it warns against. 

The to thprermonchanthe DFChavconaboconbasemonthe 

95 19 6-12 Grand 

Canyon Wildlands Council, Inc. 

Include bullets related to continuing basic inventories (as 

indicated in Fig. 3) and a bullet on learning from restoration actions. Although GCMRC has undertaken a few such activities (trout eradication at the LCR, archeological site stabilization), other restoration efforts have been undertaken 

by other GCDAMP partners and outside agencies. CRE restoration experiments include: LCR and Shinumo HBC translocation; tamarisk stand-replacement at Lees Ferry, Hidden Sloughs, and in GC tributaries; removal of Ravennagrass; and other activities; California condor reintroduction; and other activities. 

OKin th

96 19 38 Kubly BOR None of your targets use ecosystem functions. With a large 

emphasis on ecosystem-level measurements, are there no targets that revolve around functions or larger community standards? 

Non

97 19 22 Kubly BOR Point well taken on performance measures. Not98 19 39-45 Grand 

Canyon Wildlands Council, Inc. 

Please do not place the “easy to understand” bullet as the leading target for the plan, as it appears to “dumb down” management. This is a complex ecosystem and difficult-tounderstand elements of management are what the program needs to understand and resolve. 

OK

99 20 1 Barger Wapa This discussion of CMINs may be getting at the problem with 

core monitoring vs monitoring. There are no MINs, only Ins and CMINs. The core monitoring should not be all 

monitoring, only the minimalist part of monitoring. 

The MondefistraTo uon t

100 20 2.3 Capron Western Section 2.3 introduces the CMINS that are found in Appendix 

A, but unfortunately stops there. I was expecting the integration of the CMINs with the strategy for developing the 

We conMR
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

core monitoring. Only a couple of the individual goal sections later in the document reference any of the CMINs. I think it would have been helpful if under each goal there was a process similar to these steps: a) describe the CMINs, discuss priorities b) walk through all the monitoring that has occurred or is proposed for that goal c) relate CMINs to needed research for core monitoring and describe monitoring/activities that will not be proposed as CM for that goal. Table 4 (p. 34) is probably the most helpful section of the document because it lays out the intended focus of each program (along with Table 6). But it needs support. Certain questions arise that I don’t know how to resolve: 1. Which CMINs have been implemented with this proposed plan and which haven’t? 2. Was the CMP consistent with the prioritization of the CMINs? 

docconand 

101 ?? ?? 3. Management decisions: AMP managers must go through a 

process to determine eventually what gets funded and what may need to be forgone. This isn’t a science-only process, it is a compromise between what we want to do and what we choose to do based on our risk level. For example, it might be 

good to measure 10 aspects of a goal, but managers may only 

choose to fund 7/10 – it may limit the questions we can answer, but it may provide funding for other priorities. My sense is that this program being proposed here is responsive to the myriad CMINS and other issues that have been provided to GMCRC but that we haven’t had the opportunity to decide if we want to have all of this be core monitoring. Some aspects 

we may only want to include as monitoring for a few years. I 

don’t see how we even begin to untangle this when the plan doesn’t incorporate the CMINs as integral components of each goal CMP. 

ThidesiobjebudprogrespInfoAMand discleveto bmonWe Our baseadapdectoolor Tsuch of th

102 20 End of 

page 

Kubly BOR Missing text; prior to this you state that “[i] In this case, past 

monitoring data and models cannot offer much insight into 

optimum policy choices” but do not clarify why this statement 

applies to the GCDAMP case. 

We 
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

103 21 5-7 Kurt 

Dongoske 

Pueblo of Zuni 

Does this include tribal values as they relate to ecosystem 

resources? 

Please answer question 

yes We 

To tinteof nbut monesotreso

104 21 Fig. 4 Grand 

Canyon Wildlands Council, Inc. 

Include climate in the model, in one of the lower boxes. Also, add nutrients and zooplankton to the list of basal resources influenced by dam operations. 

We beligenboxsimshou

105 22 6-15 Kurt 

Dongoske 

Pueblo of Zuni 

Why are tribal monitoring programs conspicuously absent from any mention in this paragraph? 

Please answer question 

yes We 

monare withpoinhow used 

106 22 Fig. 5 Grand 

Canyon Wildlands Council, Inc. 

Add terrestrial vegetation (habitat) and invertebrates (fish food) as inputs from other submodels from the lower righthand box. 

We inpulookreso

107 22 1-10 Andy 

Makinster 

AZGFD Perhaps mention cooperation/interaction with the Upper Basin 

in this section. For example, how they have handled nonnative fish invasions (i.e. knowing what they know now, what would they have done differently in terms of non-native species detection) 

Clarify actions taken, if any, in cooperation with the Upper Basin 

Text summarizing interaction with the Upper Basin to describe integration with other programs 

We collthe basisub

108 22+ 2.6 NPS The NPS monitoring program of archaeological sites affected 

by Glen Canyon Dam should be included in the list. Although the program is not currently funded, it was developed, in collaboration with all the entities, to provide information on site condition and threats to integrity of those sites along the river corridor. The program was the subject of a PEP review, 

changes to monitoring protocols were implemented and the resultant information was the basis for the BOR sponsored treatment plan. The implementation of monitoring for NHPA compliance is no different than work done for ESA compliance, yet those projects are listed. AZGFD and USFWS are the only programs mentioned. 

Perhaps a detailed discussion about why the GCMRC hasn’t 

Not 

relePromonmeafor opeimpthe been moninforelatrea
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

collaborated with more programs? There is an entire NPS Inventory and Monitoring Network, focused on regions such as the Colorado Plateau. It would seem likely that the NPS I&M program would be an appropriate collaborator and a way for the GCMRC to move beyond the confines of the CRE geographic scope? The NPS has discussed this with GCMRC in the past yet and it was our understanding that the NPS I & M program would be integrated into this document, however, it appears to still be missing. 

manshou

109 22-23 Grand 

Canyon Wildlands Council, Inc. 

If other agencies (e.g., NPS) are conducting monitoring relevant to the AMP, are those data and reports being provided to the GCMRC database, and if not, why not? The NPS is conducting recreation analyses, avian censuses, vegetation manipulation, and other functions that should be integrated into the overall CRE model; however, there appears to be little communication or data sharing among the two agencies. Also, what about Glen Canyon NRA – have its information needs and management been fully met by Grand Canyon NP? 

ThearchsharGCto improcsharSciethroshar

110 P. 24 

bottom, P.5, top 

Grand Canyon Wildlands Council, Inc. 

Indicate the time frame for PEP reviews. On p. 28 you claim it should be every 5 years, but a more relaxed (7-10 yr) schedule likely will become appropriate once a more complete socioecosystem approach is adopted. 

Poin

the core 

111 24 20-32 Kurt 

Dongoske 

Pueblo of Zuni 

How does the commitment to meet with the Tribes delineated in the Tribal Consultation Plan fit into this annual workshop? 

Additionally, how is the development of this monitoring plan going to comply with the Tribal Consultation Plan? 

Please answer questions 

yes Trib

at aall tcon

112 24 2.7 NPS This section contains only three phases but Table 2 is a very 

detailed explanation of how the programs are developed and implemented. One concern for the NPS is that we are viewed as a reviewer for research permitting only, not for appropriateness or subject matter experts in the various disciplines. 

In sspecBrigsubjrevifututhe coll

113 ?? ?? ?? The process outlined in the table is inconsistent for each of the 

goals that follow. It is important to clearly outline the status of each of the goals, including both the positive components and the obstacles of actual implementation. Somewhere there should also be a place to integrate new information and use it to assess the goals and information needs. The feedback loop is not complete and appears as a never ending set of information needs with no place where information collected feeds back into the process. 

The drafgoaat daligactiimpThe provreviperiman
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

114 24 2.7.1 NPS It seems that there needs to be someplace to identify that 

information needs should come from the management agencies, not just the TWG. There is a basic flaw in the program if management needs, clearly identified as core to the program, are not incorporated with the expectation that TWG will serve as the management review. 

Thireso

115 25 2.7.3 Capron Western I’m not sure that “reports” is the best title for these, I was 

confused the first time I read this. Perhaps these could be called “plans” because this is in fact the individual core monitoring plans that we are going to review right? 

We MRwha

116 25 bottom Grand 

Canyon Wildlands Council, Inc. 

An overall synthesis of core monitoring results is needed to integrate and update core monitoring efforts, likely at least at 5-10 year intervals. 

Not

117 26 1 Barger Wapa This discussion does not address what part of monitoring 

should be core, where is the precision, accuracy, and periodicity. 

See 

118 27 figure Barger Wapa See comment above See 119 27 Table 2 Grand 

Canyon Wildlands Council, Inc. 

Integrated biological inventory should be a component of the planning process, and further inventory efforts should be recognized in the implementation process. 

We GCfiscall ocurrfor terrinveCanfrom limiis lias tdescof thNatcouthey inveresoexpbecof in

120 28 2.9 Capron Western A 5-year interval is being proposed for review, which is often 

an easy choice. But my experience is that this often seems too quick, but 5 is an easy round number to use. It might be better to say 5-10 years or 8 years or something a bit more realistic. My experience is that 8-10 years seems to be a good time for major reviews. That gives 5 years of work with 3 years of 

We app5 yeHowwilldesi
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

write-up and publication to review. 

121 28 2.9 NPS There is certainly value to parallel monitoring protocols when 

new technologies are employed, but redundant systems should come to an end. It would be appropriate to recognize the feasibility of running dual systems and the need to evaluate and move forward with single systems (for both logistical and 

financial reasons). 

We paraWe poin

122 28 13 Kubly BOR “Project budgets should ideally be increased annually by 5 

percent to enable the projects to continue evaluating new methods and monitoring instruments and to cover periodic independent reviews.” If CPI increases an average of 3% each year, how does GCMRC propose to maintain balance of funding among different parts of the program? There has been almost no attention to budget limitations thus far in the GCMP, but there have been considerable discussions previously in the CMT and SPG about whether the CMP budget should drive the level of sampling or vice versa. Also, we lack information on tradeoffs between statistical precision and sampling intensity that will drive costs. 

We 

sensaddfor comthe 

123 29 10 Kurt 

Dongoske 

Pueblo of Zuni 

Are tribal resource concerns and tribal monitoring programs contained within the broad category of “cultural resources” in this bulleted item? 

Please specify what is covered by the term “cultural resources” 

yes Yes

124 29 2.10 NPS Key to the success of any core monitoring element is whether 

or not it is answering the questions it needs to address. It is important to include realization that even if a program was deemed core, if it is not producing desired results, it shouldn’t continue. 

Not ademeaBut respneedisc

125 29 2.10 Capron Western I assume by the first bullet in the list that food base is included 

under the “food web” item? Perhaps you could include the goal numbers here, just to be clear. 

OK

126 29 22 Kubly BOR It may well be advisable to develop priorities within each 

CMP that will allow selection of monitoring variables and/or sampling intensity within the limits of budgets, i.e. tradeoffs above. This need should be acknowledged and addressed in the general plan. 

We con

127 29 Last 

par. 

Capron Western This is the first place I found where cost is considered. I think 

the biggest issue for the program is balancing our wish to monitor everything (Christmas tree approach) vs. the necessity to have a balanced budget that allows for adequate short-term 

monitoring and hypothesis testing (research). As a reader, it would have been helpful if there was further discussion of this 

We goaprogAMbudmad
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

trade-off between precision, assessing all the CMINs (or not), and cost. When I got to this point of the document and read this I was left with the impression that we have somehow locked ourselves into a CM program that will consume much of our budget. I agree that the CM programs should be protected from annual-budget manipulations, but this only works if the CM programs are the “core of the core” as a former program participant used to say. 

128 30 Table 

3; goal 11 

Kurt Dongoske 

Pueblo of Zuni 

The FY2000 PEP for cultural resources reviewed a program that was substantially different from the monitoring program being designed by GCMRC now.

no Agr

129 30 Table 3 Capron Western Goal 8 should be listed as provisional only. OK130 30 Table 3 Kubly BOR I am not aware that any core monitoring has been 

recommended by TWG and accepted by AMWG or the DOI management agencies. Thus, I do not see how GCMRC can argue that there has been some core monitoring in place since 

2008. 

The been as c

agreplanprojmonand the 

131 31 Figure 

6 

Kurt Dongoske 

Pueblo of Zuni 

This is the first time this document uses the acronym "TCP." Prior to this the document references archaeological sites and cultural resources. Why the change in this figure? Up to this 

point the document has not even recognized that the Tribes may have special places and resources of importance in the CRE that can be categorized by the term TCP. The treatment of tribal concerns and resources in this document up to this 

point has been exceedingly insufficient and somewhat insulting. 

Please answer question 

yes TCP

andcultthat conwelon t

132 31 NPS It’s interesting that the AMP goals for cultural resources were 

relabeled Archaeological Sites and TCP’s in the figure. The point of using the term “cultural resources” was to acknowledge that many resources thought of as “natural resources” such as fish, birds and plants are considered “cultural” resources by the Tribes. We’d suggest using the original label. 

Pointhe 

133 31 Fig. 6 Kubly BOR Figure 6 does not acknowledge the important monitoring (and 

management) of nonnative fish that is being undertaken by the program, outside of that accomplished in the Lees Ferry trout 

fishery. Also, regarding the trout fishery, existing monitoring, 

which GCMRC sees as being core in FY 2010, does not 

adequately address recent questions concerning emigration from the reach and the natal source of trout in Grand Canyon. 

FigurelaAMgoanatifish
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

134 32 5-7 Kubly BOR How do “metrics” fit into the hierarch of core monitoring 

measurements in relation to parameters? 

Neeresp

135 34 Table 4 Capron Western See comment above. OK 136 34 Tbl 

4@4 

Werner AZ Frequency of seasonally isn’t clear. Does this mean 4x/yr? Or 

something else? 

Revise text for clarity 

Y Yes

An 

137 34-37 Table 

4:1 

Grand Canyon Wildlands Council, Inc. 

While emphasis on the aquatic food base has occupied much AMP attention over the past 25 yr, there has yet to be any indication that food is limiting to fish in the CRE. The results of the on-going effort may dramatically shift emphasis of these efforts. 2) There has been not been, to our knowledge, any contribution to the program from springs monitoring. While such findings may be important, the topic has remained loosely described and has not been justified here. Please clarify the rationale, methods, and planned analyses and reports. 3) Recreational impacts on CRE biological resources remain an important, but largely unexplored topic, one the NPS has not addressed, and one that is appropriate to at least mention in this plan. 

No MopresC. Wconlimiupcto dbase The spriand assoresostak

138 36 Table 

4; 11b 

Kurt Dongoske 

Pueblo of Zuni 

Interesting that TCPs are identified here when the program has no idea what the range, types, and numbers of TCPs are within 

the scope of this program. Isn't this a bit disingenuous? The document presents no narrative explaining the integration of 

tribal monitoring programs or even an acknowledgement that a program will have to be cooperatively developed to deal with 

and manage the information generated by these tribal programs. 

Yes See 

aboTrib

139 37 Table 

4; goal 12 

Kurt Dongoske 

Pueblo of Zuni 

Aspects of goal 12 also seek to integrate the tribes into the Quality Adaptive Management Program in a meaningful and productive manner. Seems to be missing from this whole discussion of Goal 12. 

Please include a discussion on how tribes will be meaningfully integrated into this plan 

Yes Yes

data to winteCMdesiplan

140 39 NPS Goal 1: 

Exploring the feasibility of reintroduction of NATIVE invertebrate assemblages should be a focus of CMP. 

We monThialthcou
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

141 40 11-27 Grand 

Canyon Wildlands Council, Inc. 

CRE aquatic food base monitoring was initiated in earnest in 1990, and was initially built upon by GCMRC but then abandoned. Nonetheless, our most basic understanding of flow-benthic ecology was derived from those studies and serves as a foundation for the present effort. Appropriate referencing of that early work may help dispel the notion that GCMRC is simply reinventing this particular wheel. 

ThicominclShaelemAprinte

142 41 Grand 

Canyon Wildlands Council, Inc. 

Methods: All of these approaches have been tried in the past, although they did not receive the support or staff appropriate to accomplish the objectives. The present effort promises to integrate past and present findings to clarify and hopefully develop predictive models for some long-recognized patterns. In addition, the contemporary food base work promises to provide clearcut, long-term monitoring recommendations. We remain concerned that large ecosystem changes occur with individual flow events, and thus the monitoring sites and schedules should remain flexible at least until the results of the present effort have been fully integrated into the overall socioecosystem model. 

No Theresecore the recoinfomod

143 42-48 NPS Goal 2 

I was please to see the inclusion of HBC aggregation monitoring in the plan. The incorporation of humpback chub aggregation monitoring into a long-term monitoring program will be helpful to determine the success of HBC translocation projects that have been implemented (e.g., Shinumo Creek). 

Tha

144 42-48 NPS There is no mention of ongoing management activities that are 

being implemented to meet Goal 2. GRCA translocated 300 HBC into Shinumo Creek in 2009, and additional translocations are in planning stages. While the success of these projects remains to be seen, they may contribute directly 

towards Goal 2. It seems appropriate to at least mention these conservation activities, and how GCMRC’s proposed monitoring efforts may provide information to support these 

efforts. 

Agractieva

145 42 10-14 Andy 

Makinster 

AZGFD Clarify whether the 2008 Bio. Opinion states annual 

assessment of HBC population in the LCR, mainstem CO river, or both 

Text reflecting actual literature in 2008 Bio. Opinion 

Further clarification of Bio Opinion 

Thi

146 42 25-26 Andy 

Makinster 

AZGFD Change ‘an estimate of rainbow trout abundance’ to 

‘significant changes in RBT catch rates and distribution’. 

Researchers have a limited ability to conduct pop. estimate during routine monitoring; instead use long term trends to 

determine significant changes 

Change text Change text 

The CM

147 42 2nd

Paragra

NPS The report mentions that adult humpback chub monitoring 

data provide information for investigating what factor or 

The data 
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

ph factors influence population fluctuations, which is certainly 

true. However, there is no specific mention of how the data will actually be used to assess factors that influence HBC trends. In fact, the latest HBC status update using the data described in this monitoring proposal (cf. Coggins and Walters 2009) warns the reader that “...this recruitment time-series must be used with caution in any attempts to develop post-hoc hypotheses concerning management actions or environmental factors that may or may not have influenced recruitment and subsequent adult abundance.” The environmental or management-related factors that may influence HBC population fluctuations may arguably be the most important assessment that can be completed to achieve Goal 2. The question is, when and how are the data collected, through monitoring proposed here, going to be used to actually answer this question? 

(e.gratestakpop

furtto o

madecomay 

148 43 Grand 

Canyon Wildlands Council, Inc. 

Background analysis of handling impacts on HBC remain uncompleted. Whatever the cause of this delay, potential conflicts of interest may be too great for GCMRC to conduct such an analysis. Therefore we urge the AMP to have the SA engage qualified, unbiased fisheries biometricians to investigate potential handling impacts on HBC from the Center’s fisheries database. 

Thiduristak

149 44 32-33 Andy 

Makinster 

AZGFD Primary species captured in the LCR reach are native FMS, 

HBC, SPD, and BHS. Primary non-native is still RBT. Catfish species are captured occasionally in this reach 

Change text Change text Cha

non

150 44 39 Andy 

Makinster 

AZGFD Stone et al. (2007; The Southwestern Naturalist 52(1): 130-

137) is a good citation regarding potential sources, impacts, 

and management concerns of Asian tapeworm 

Include citation 

Review literature 

Addwhe

151 45-48 Grand 

Canyon Wildlands Council, Inc. 

Insufficient attention has been paid to other native fish population dynamics in the CRE. HBC are not necessarily a good “umbrella” for all native fish species in the system, and certainly are not appropriate as umbrellas for the terrestrial taxa. More attention to other fish species is warranted, as is restoration of HBC range to the full river, and the reintroduction of extirpated fish and other species, as indicated on P. 49. 

MaiabuHBaddnon

152 46 15-20 Kurt 

Dongoske 

Pueblo of Zuni 

GCMRC has been alerted to the importance of the confluence of the LCR/Colorado River to the Pueblo of Zuni. At what point is GCMRC going to "consult" with the Pueblo of Zuni concerning these activities? The need to consult should be 

recognized in this plan because the out come of that 

consultation may impact future activities in this location. 

Please respond to the question 

Yes DO

Puewill and conthes

153 46 5th

paragra

NPS It seems that the GCMRC is considering the PEP 

recommendations to scale back the number of sampling trips 

Any 

will 
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

ph on the LCR. Specifically, the fall trips may be dropped. Fall 

sampling may be necessary to determine the status of YOY HBC in the LCR, and possibly assess YOY survival. These data may be important to support efforts to create an off-site refuge population or translocation projects. For example, YOY survival rates and/or abundance may be needed to determine how many YOY HBC can be safely removed from the LCR for management activities. 

the disc

154 47 15-16 Kurt 

Dongoske 

Pueblo of Zuni 

The need to continue mechanical removal of non-native fish at 

this reach is being contested by the Pueblo of Zuni. The Pueblo of Zuni believes that the future that the mechanical removal will continue is uncertain at this time. Does this imply that GCMRC does not seriously consider Zuni's position and that you will continue with this program irrespective of what is decided during consultation with the DOI? 

Please respond to the question 

Yes Of c

whaSec

155 47 Capron Western Hunt, 2008 not in References. Ref

ComApr

156 47 3 Andy 

Makinster 

AZGFD Change ‘The 2009 PEP for Grand Canyon fish recommended 

that some of the methods and locations of this sampling be incorporated...’ to ‘Dependent upon review of the 2009 PEP recommendations, methods and locations of this sampling may be incorporated...’. At this time, review of 2009 PEP recommendations for the lower 1200 meter project and FWS hoop netting is incomplete. 

Text reflecting analysis of PEP recommendations is yet to be complete 

Change text Rel

GCdiffdetetran

157 47 middle 

pars 

Capron Western The annual spring/summer LCR inflow assessment. The last 

time this was done was for the concurrent estimate in 200?. I wasn’t aware this was an integral monitoring component of the 

program. Also, is this the work that is slated to include trammel nets? I have serious concerns with adding trammel netting to our monitoring program without understanding why it is critical to do so and what the effects on HBC may be. I hope this will be a consideration in the CMP for goal 2, and that we will discuss these techniques with the upper basin recovery program. 

The revitranoccu

158 47 26 Andy 

Makinster 

AZGFD Change ‘....in some years’ to ‘...during the latter of two spring 

mainstem electrofishing trips’. AZGFD has conducted this monitoring regime below Diamond Creek since 2004 during its downstream monitoring program. 

Adjust text Change text Tra

mainot maiinclcon

159 47 28-30 Andy 

Makinster 

AZGFD Change to ‘A stratified random approach is used to sample 

individual sites throughout the river between Lees Ferry (RM 0) to Lake Mead. Delete the text stating the project samples aggregations of humpback chub and the data collected by the project supports the ASMR model for humpback chub abundance and trends. Electrofishing conducted during this 

project is ineffective at capturing humpback chub. While the 

Change and delete text 

Change and delete text 

Texvers
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

project does conduct random sampling in humpback chub aggregations, this species is rarely encountered. The only support for the ASMR model is that the humpback chub that are rarely captured are scanned for the presence of PIT tags and given a PIT tag if absent. Other native species (FMS, BHS) are frequently captured with electrofishing. 

160 47 46 Werner AZ Why is it important to survey when the water temp is the 

highest? Aren’t the fish there through the year? 

Revise text for clarity 

Y Tex

vers

161 49 28 Werner AZ There is active recruitment in Lake Mead. The latest report is 

in the lit cited. This sentence should be revised to clarify the scope of the work from the Shortage BiOp. The “potential” question fits the river in the GC but not Lake Mead. 

Revise text for clarity 

Y Tex

162 49-50 NPS Goal 3 – This goal has been ignored for too long by the AMP 

and GCMRC as reflected in the minimal attention it is given in the CMP. All extirpated species should be listed with CMP needs not just the razorback. In addition, the razorback sucker information is out of date. The NPS, BOR and others working collaboratively have made some progress toward meeting the 

parts of the shortage BO tasks. That progress should be 

reflected in the report and at a minimum a plan to outline GCMRC role in future razorback work should be included in CMP. 

Curappare CMprog

163 52 Goal 4 

Why is there no research goal to determine population estimate 

of trout and just relative abundance? 

The of rProtFishinclaburepean uabutracestiresomormonthis colla ra

164 52 5-7 Andy 

Makinster 

AZGFD Add ‘The GCDAMP desires to maintain a viable, selfsustaining sport fishery for rainbow trout....’ Add text Add text Not

vers

165 52 7 Andy 

Makinster 

AZGFD Add ‘...this fishery is a popular recreational activity for local 

and visiting anglers that provides a substantial economic benefit for the Marble Canyon business community’. 

Add text Add text Not

vers

166 52 7 Andy 

Makinster 

AZGFD Add ‘Rainbow trout were stocked into the Lees Ferry reach 

soon after the closing of Glen Canyon Dam. The stocking regime continued until 1998 when it was determined the 

Add text Add text Not

vers
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

majority of recruitment into the adult population was from natural production’. 

167 52 18 Andy 

Makinster 

AZGFD Add ‘Monitoring of the Lees Ferry and downstream COR 

RBT population.....’. 

Add text Add text Not

vers

168 52 30 Andy 

Makinster 

AZGFD Add ‘....include monitoring of nonnatives and that the 

management goals of the fishery shift away from maintaining a target number of adult fish to managing instead for high 

angler satisfaction’. 

Add text Add text Not

vers

169 52 30 Andy 

Makinster 

AZGFD Change ‘This recommendation’ to ‘The first recommendation’ Change text Change text Not

vers

170 52 31 Andy 

Makinster 

AZGFD Delete ‘due to’ and change to ‘or through’ Delete and 

change text 

Delete and change text 

Notvers

171 52 33 Andy 

Makinster 

AZGFD Add ‘The second recommendation focuses on adjusting creel 

(angler) interview questions which have been ongoing since the establishment of the fishery. The questions will be designed to elicit responses from the Lees Ferry angling community about the satisfaction of their angling experience. 

Add text Add text Not

vers

172 53 16-18 Kurt 

Dongoske 

Pueblo of Zuni 

If the 2009 PEP did not recommend continuation of the young life stage studies, why is GCMRC continuing to fund this work? 

Please respond to the question 

Yes PEP 

conrelaand conThiefferela

173 53 7-9 Andy 

Makinster 

AZGFD ‘...call for assessment of the population, including population 

estimate, growth rate...’. Annual population estimates for the Lees Ferry reach, I believe, was deemed unnecessary due to the cost associated with such an undertaking. Past population estimates correlate very well with monitoring the catch per unit effort index. Thus, the index likely serves as a sound surrogate for the population estimate. 

Change text Change text Not

174 54 27-33 Kurt 

Dongoske 

Pueblo of Zuni 

How is this monitoring going to help us understand if Lees Ferry RBT are moving downstream to the confluence with the LCR necessitating mechanical removal? Why isn't this discussed under this goal? 

Please respond to the questions 

Yes Thi

resePleasugreac

175 54 bullets Capron Western This section seems to simplify the PEP recommendations to a 

point that I think misses some important issues. My interpretation of the PEP recommendations is that too much effort has been expended in trout monitoring and that we should reduce that effort and focus primarily on adult numbers 

and condition. I think this section should be expanded and that the PEP recommendations should be described in more detail 

and be complete. That type of summary is likely to be completed during the PEP review this winter for Goal 2, but a 

Notvers
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

good start could be made here. 

176 54 23 Andy 

Makinster 

AZGFD Change to ‘For future years, the sampling of the Lees Ferry 

reach should continue to monitor all species present...’. Current monitoring attempts successfully to monitor all species present in the reach (FMS, rare occasions of nonnatives such as SMB, WAL). Its not like we’ve been selectively sampling for RBT only; that species is just the most dominant one in the reach. 

Clarify text Clarify text Not

vers

177 54 25-29 Andy 

Makinster 

AZGFD Monitoring of the Lees Ferry reach will not continue 

downstream of the mouth of the Paria River. First, conductivity issues associated with the mouth of the Paria 

River will prohibit effectively sampling with electrofishing. Second, the area surrounding the mouth of the Paria River is logistically unfeasible; it’s a shallow area in the middle of a mild rapid. Third, areas where it is feasible to sample with electrofishing are included in the random sampling design of the downstream electrofishing monitoring program. 

Delete text Delete text Not

vers

178 55 32-34 Kurt 

Dongoske 

Pueblo of Zuni 

Thanks for recognizing the Tribal values associated with this place, but will it be a consideration in the development of a monitoring protocol? 

Please respond to the question 

Yes Yes

179 55 Grand 

Canyon Wildlands Council, Inc. 

The AMP has pursued detailed studies of Kanab ambersnail genetics and mortality, which the AMP has been informed will result in synonym of KAS with Niobrara ambersnail. 

However, no recent progress has been reported on publication 

of those results, and further policy attention to KAS has stalled. The emphasis on KAS in this program is likely to dissipate after publication of those findings. In keeping with AMP Goal 12, we urge GCMRC to move forward swiftly with peer-reviewed publication of study results to prevent even more backlogs of unpublished information from slowing program progress. 

We and 

180 57 11-13 Kurt 

Dongoske 

Pueblo of Zuni 

Perhaps the GCDAMP should leave the monitoring of the ambersnail to the NPS. 

No Cur

assitranbe c

181 57 last par. Capron Western I thought this was an excellent section with good questions 

about how to integrate KAS into our program considering the potential change in listing status. 

Ack

182 58 22-24 Kurt 

Dongoske 

Pueblo of Zuni 

Where is the intention of integrating Traditional Ecological Knowledge (TEK) from the tribes that can inform on these plant communities? Is GCMRC acknowledging that TEK is important information (i.e., data), but choosing to ignore its importance to this plan? 

Please respond to the question 

yes Inco

assifacimon
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

183 58 24-27 Kurt 

Dongoske 

Pueblo of Zuni 

How does campable area fit into this goal? Please 

respond to the question 

Yes Veg

influcov

184 58 Plan should include some monitoring strategy (working with 

the NPS) for tamarick beetle (diorhabda elongate) which could have profound impact upon the riparian vegetation community 

GCcoowill veg

185 59 17-18 Kurt 

Dongoske 

Pueblo of Zuni 

GCMRC is acknowledging the importance of the native terrestrial environment to Native Americans, but that importance and concerns are not directly addressed in this 

monitoring proposal. Does GCMRC really know what the tribe(s) want monitored or what their resource concerns are? 

Please respond to the question 

Yes Prob

wish We infomor

186 59 bottom Grand 

Canyon Wildlands Council, Inc. 

P. 59: bottom: The TEM program involves an enormously complex study design that may, over the next century, provide something worthy of management concern, but is neither realtime nor habitat-related. Virtually no peer-reviewed studies of dam influences on riparian vegetation have emerged from this program. We feel that a realistic examination of the terrestrial vegetation field program should be conducted, taking into consideration the recommendations of the vegetation monitoring program PEP review panel, and focusing on development of a predictive model relating vegetation responses to flow. 

Agrrecorefl

187 59-60 12-22 Grand 

Canyon Wildlands Council, Inc. 

Because of study design issues and poor data collection, previous terrestrial invertebrate and avian monitoring and research has generally failed to demonstrate any real difference between lower and upper riparian zones. Also, 

previous invertebrate studies have largely failed to meet NPS database management requirements, and specimens from that program appear to have disappeared without databasing into a host of collections around the U.S. The results of those studies 

have not been published in the peer-reviewed literature, a 

shortcoming that limits the credibility of the studies. The text on P. 60 is essentially wrong, vastly oversimplifying variability among invertebrate life histories and habitat requirements, and it fails to even mention rare or endemic river corridor invertebrate taxa that may eventually play a much larger role in river management. The topic of invertebrate monitoring requires rethinking before it is posed here as a 

long-term monitoring topic. 

The feasCanand 

188 60-61 Grand 

Canyon Wildlands Council, Inc. 

Stage-vegetation relationships are, after 12 yr, still preliminary and do not yet appear to be useful for riparian succession modeling. Data collection around such a model should be the focus of the terrestrial vegetation monitoring program; however, the model must be developed prior to establishing 

The inclgeoThechan
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

vegetation monitoring criteria. The agglomerative methods on p. 61 are only useful for description, not for predictive modeling and at this point we are left with anecdotal rather than predictive capability for this important component of the program. We consider the riparian vegetation monitoring protocols to be premature, and the first focus should be on modeling needs. 

modfeed and 

189 61 39-43 Kurt 

Dongoske 

Pueblo of Zuni 

Where is the integration of tribal monitoring into this new program of terrestrial monitoring? 

Please respond 

Yes We 

throhow thosby tpres

190 64 

71 

24 4-10 

Grand Canyon Wildlands Council, Inc. 

P. 64, L 24: Misplaced indent. The Goal 7 flow and WQ section looks good. P. 71, L. 4-10: Monitoring sandbars every 4 yr does not seem 

sufficiently frequent. A 1-3 yr schedule would be more appropriate, with a subset of bars surveyed each year. 

We

maiprecgradtrento bcurr(NAmonevemonfreqor fto 3was 

191 68 26; 

protection of archaeological site 

Kurt Dongoske 

Pueblo of Zuni 

Don't believe that this has been conclusively scientifically confirmed. I thought GCMRC in conjunction with the USGS was still researching whether this was in fact a by-product of sandbars. If it is a by-product of sandbars it will only help a very few number of archaeological sites and to broad brush its preservation capabilities is a bit of hyperbole. 

No Opi

192 70 NPS NPS support the addition of system-wide sediment inventory 

using orthophotos to suite of excellent legacy sediment monitoring protocols. Continued integration of the various elements of the sediment monitoring and analysis of sometimes conflicting information from the various sediment monitoring tools still needs to be addressed by GCMRC and should be mentioned in the CMP as a goal for the next few 

years to complete. 

Goointemonchanto aann

193 71 16 Werner AZ Should the word be aggradation rather than aggregation? Check 

context/word usage 

Y Rev
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

194 72 NPS Goal 9 – the text recognizes the NPS role to some degree but 

fails to recognize the integrated nature of the recreational work proposed. The NPS, as land manager, is intimately involved 

in assessing affects to recreational experience. The campsite atlas, for example, is a cooperative venture between NPS and GCMRC yet the text downplays NPS integration (while highlighting AZGFD involvement in the trout work). Other 

than the text stating that the program will compliment the NPS/CRMP program, there is nothing specific to detail how these programs will be coordinated. It would be useful to work with NPS recreation specialists on a more robust discussion on how these programs will work together. GCMRC should be relying on NPS to provide data on the downstream recreational values given that these are tied to NPS mission goals. 

GCNPS monaddcolldevmon

195 73 3-7 Kurt 

Dongoske 

Pueblo of Zuni 

How is being out of sight and sound of other parties a function of dam operations? 

No Dam 

of saffeof c

196 73 middle Capron Western First place a CMIN was incorporated into the CMP for a goal, 

Goal 9. 

Yes

197 73 14-16 Kurt 

Dongoske 

Pueblo of Zuni 

Camp crowding, safety, and types and intensity of human impacts seem to be marginally related to dam operations and more directly affected by the NPS permitting process and the resultant over-crowding in a "wilderness" setting. 

No We 

permpart 

198 75 31-34 Kurt 

Dongoske 

Pueblo of Zuni 

Monitoring of the recreational experience should be left largely to the NPS and the monitoring program of GCMRC should be a reflection of a program that allows the NPS to do the majority of the monitoring and evaluation. 

no Opi

worproj

199 76 9-10 Kurt 

Dongoske 

Pueblo of Zuni 

Shouldn't this be the primary responsibility of the NPS, not the GCDAMP? I find it curious that so much energy is being put into recreationists' enjoyment satisfaction and the Native American communities are ostensibly absent from this plan and are by and large disenfranchised from GCMRC's proposed core monitoring plan. 

Please respond 

yes We 

asseare 

200 76 NPS In the methods section, it would be useful to discuss how the 

vegetation evaluation will be linked to the vegetation mapping and monitoring described in goal 6 and how this information 

will be integrated into NPS work. 

OKabo

201 76-77 Grand 

Canyon Wildlands Council, Inc. 

How were the elements recommended by the PEP selected. Such decisions should be based on conceptual or empirical models, which should then drive monitoring data compilation. 

For example, we need a simple sandbar recreational use model, but that does not appear to have been attempted thus 

far. Also, it seems to us that monitoring river running safety is 

The that CMelem
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

an obviously important task, one that should be undertaken by the NPS; however, being familiar with past information on the topic, we have yet to see a report on this topic the updates the findings of Myers et al. (1999). In this arena, GCMRC should work more closely with the NPS. 

202 Goal 10 Palmer Wapa This section will likely need to be rewritten following the 

Economic Workshop in December, 2009 

We pan

203 78-80 Grand 

Canyon Wildlands Council, Inc. 

Please proceed with developing a power marketing core project – it is an important resource for the AMP to keep track of and report upon. However, it is premature to include monitoring methods and plans in the CMP. 

Not

204 General Goal 11 Palmer Wapa This section needs to be rewritten to distinguish goal 11 from 

the efforts to complete NHPA Section 106 compliance on the federal action of GCD dam operations from the longer-term monitoring of cultural sites authorized under the GCPA. 

Add clarifying information to this section 

Purpeffethis and requhist

205 81 12-13 Kurt 

Dongoske 

Pueblo of Zuni 

Not to mention information and data on past human behavior and lifeways. 

no 

206 81+ NPS GRCA Goal 11: This goal refers to cultural resources in the broadest 

terminology, yet the monitoring program is focused on archaeological properties and physical changes, ignoring the greater purpose articulated in the goal. The issue of erosion is significant and both BOR and NPS are implementing a treatment plan specifically related to this issue. Erosion as a result of Glen Canyon Dam is a generally accepted principal. The 2000 PEP “panel concluded that distinguishing natural erosion from dam caused erosion is a task that is probably “not cost effective.” The PEP continued by noting, “Glen Canyon Dam has made it (the sedimentary system of the Canyon) increasingly sediment-starved, and thus erosion rates must be increasing at some scale and dam operations must contribute to the spatial and temporal variability in rates of erosion of deposits along the river corridor (Doelle 2000, pg. 39). It seems that trying to develop core monitoring relative to this topic is not cost effective and offers little useful information for active management of the resources. Information on rates of erosion is interesting and are less critical for the land managers given the limited resources available to implement the approved treatment plan. We believe the core program could focus on elements not addressed in other programs such as monitoring protocols for non-archaeological properties. 

We resoand resomanThe variPEP monprevthrowertopiconthe mon“ReRes“Thproginfofor effechethe 
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

The 2000 PEP offered 3 primary recommendations supported by a number of sub-elements. The CMP does not fully relay the recommendations of the PEP relative to the existing NPS monitoring program. The 4 parts were: 1. prioritize properties for treatment; 2. evaluate effectiveness of treatments; 3. document progressive erosion where treatment has not yet been implemented but is planned; 4. ensure visitor effects remain below a threshold that causes long-term damage or loss of integrity. The first and second recommendation have been implemented (it would be appropriate to state that this has been completed) and on-going monitoring efforts are the mechanism for documenting progressive erosion where treatment has yet to be implement. The proposed core program does not practically address the recommendations even though the text suggests that GCMRC is simply following through on the recommendations made in 2000. The reviewed plan currently identifies different variables to collect than has been detailed in proposal requests. This suggests that the monitoring of archeological sites continues to be an experimental process where equipment is being tested and new variables get collected. This also suggests that the Chapter 2 table 2 programmatic approach is not being followed for this resource. This is also evident in the methods section where the first sentence of the paragraph is “Potential monitoring protocols include”. It would seem that the core monitoring should be refocused to address true needs, not ones that have been addressed or are parts of other on-going programs. 

mucto dpresimppartthat belodamIn ahad mon“A placNeithe incodecsubhas cou“ReNwith longarchThithe straauthPA, MOncshouthe man2) MBOregiand changain monorgaquadam 
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

contreaFra gemodtype visievePrbe eusefmonThand tradquaidenand In areco“Arongprovconinteimprecoalso the conbeinthat phybouindierosevaoveIn tupenit is resoacti“Gilong
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

modappas thresoacce(All the recomon

207 82 1-6 Kurt 

Dongoske 

Pueblo of Zuni 

How does GCMRC propose to incorporate this information, if shared by the Tribes, into their overall evaluation of the health of the CRE? Additionally, what steps have been taken by GCMRC to work with tribes to develop an information management system that appropriately deals with tribal 

information that is considered sensitive? 

Please respond 

yes It w

DFCconGCTribunledo soutcwor

208 82 19-22 Kurt 

Dongoske 

Pueblo of Zuni 

Still a hypothesis that GCMRC is testing; stop incorporating the presentation of hypotheses as proven scientific fact. 

no 

209 82 3rd

paragr 

Barger Wapa I disagree there is a strong linkage, especially since the sites 

tend to be above 80,000cfs. Rather, there may be a linkage, but since most sites are actually above 95k, it is unlikely there is an effect. Also, in the last sentence, we really need sediments up to the sites, again, at least above 80k. 

Opi

othe

210 82-83 Goals 9 

& 10 

Ted Kowalski 

Goals 9 and 10 do not seem to be well flushed out in my opinion. Additional description of the survey work that would be conducted for goal 9 could be helpful. Rather than photos of 45 popular campsite sonly, (page 82, line 12) perhaps the 

annual documentations should be more thorough (focusing on 

the top 90 campsites perhaps). Page 83, line 9, the camping atlas makes a lot of sense. 

Takof thsurvdonof rsystmodscop

211 83 13-20 Kurt 

Dongoske 

Pueblo of Zuni 

This is one interpretation of these past events. Another 

interpretation would be that the Terrestrial Ecosystem Monitoring program was established without tribal input and then the tribes were asked to fit their monitoring needs within a pre-designed western science paradigm setting the tribal 

participation up for failure. Tribes went to the BOR for funding their monitoring programs because it became very apparent that GCMRC was not interested in collaborating with tribes as this current document demonstrates. 

no We 

the 

212 83 34-38 Kurt 

Dongoske 

Pueblo of Zuni 

Please include the citation for this review panels report. Yes OK
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

213 84 9-12 Kurt 

Dongoske 

Pueblo of Zuni 

I didn't think LiDAR could detect artifact movement! In fact, 

the biggest criticism of LiDAR is that it cannot detect or 

evaluate changes to archaeological surface features. This program continues to be narrowly focused on what is currently happening to the surface of archaeological sites when we should be more interested in understanding the past hydrologic behavior of the river that has preserved some sites and presumably scoured others out of existence. We need a more holistic view of how and why some archaeological sites continue to remain rather than focusing solely on current natural processes. Wind and sand are not directly tied to dam 

operations. 

No Thi

undcan occudrapimavarimeaWe sand worsand undholi

214 84 18-21 Kurt 

Dongoske 

Pueblo of Zuni 

This monitoring program or the R&D program for monitoring does not address TCPs. In fact, one seriously doubts whether GCMRC even knows where or what the TCPs are that the tribes consider important. Had GCMRC known about and was sensitive to tribal issues, then the recent letter from the Zuni Governor about the mechanical removal of trout at the confluence would not have needed to have been written or sent. 

No So f

with Are aboWitthat contribremprepto MwereffetroudontribotheZunto aand negunw

215 84 27-29 Kurt 

Dongoske 

Pueblo of Zuni 

This appears to be merely lip service to the tribes by GCMRC. I don't see any effort by GCMRC to pro-actively work with the tribes to develop a monitoring and assessment program that incorporates the results of tribal monitoring into the GCMRC system of resource condition assessment and health of the ecosystem. 

No We 

repedisc

216 84 Grand 

Canyon Wildlands Council, Inc. 

Please proceed with developing the cultural resource monitoring program – these are critical resources for many AMP stakeholders and need to be monitored in a scientifically credible fashion. However, it is premature to include 

OK
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

monitoring methods and plans in the CMP. 

217 84 5 Werner AZ Why stop at Diamond Cr? Clarify 

rationale 

Y Not

218 84-89 Grand 

Canyon Wildlands Council, Inc. 

Pp. 84-89: This section should be about how to maintain the long-term scientific integrity of the monitoring program, and how to keep it functioning effectively. As it is written, it is a make-work wish list for more sophistical and costly remote sensing technology, not about maintaining and improving scientific integrity. The following section on the structure of GCMRC should be merged with this section, rather than oddly 

subdividing it up. This technology wish list presented here should be reduced to one paragraph and presented in the context of advocating for good science by improving 

technology. 

In the rewrite, provide a description of all of the 

original ROD language describing GCMRC and its role. That should be followed by a section on how science and scientific review is conducted for the AMP, and what the challenges and 

successes have been. Include information on how results on each major undertaking are used to inform the program and the scientific community and the public. Reference to the peerreviewed and gray literature produced by the program for each 

AMP Goal should be developed, to better evaluate scientific progress and efficiency in each. The theme of planned 

flooding can potentially be used as a theme, but please include an explanation of the timing and consequences of GCMRC’s delay in evaluation of the Year 2000 flow experiment, and how that delay has affected program assumptions and 

directions. The description of the present staffing plan should include how many individuals are employed in what capacity, why some positions are or are not filled, and more detail on how well the program involves outside collaborators, and how many students are supported by the program. A justification should be provided about how the present staffing varies from the original concept for GCMRC in the ROD. The recent recommendation by AMWG to provide qualified stakeholders with first option on surplused equipment also should be mentioned as a benefit to the program. 

Remby s A fof nNSEdocmongrosabuand perssensrecoanamonappThe reviscieoutsaddthe to h

219 86 10 Kurt 

Dongoske 

Pueblo of Zuni 

Nice to see the use of the word "may" in relationship to windblown sand protecting archaeological sites. The rest of the document seems to imply the term "will" protect archaeological sites. 

No 

220 86 29-31 Kurt 

Dongoske 

Pueblo of Zuni 

Cultural resources are a broader category than archaeological sites, but this document by and large focuses only on 

No 
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

archaeological sites and merely gives lip service to the other places and resources that comprise the category of cultural resources; especially Native American resources and places of concern. 

221 89 4-13 Kurt 

Dongoske 

Pueblo of Zuni 

Problem I see with LiDar is that it cannot interpret or evaluate 

surface archaeological features. therefore, the utility in detecting impacts to archaeological sites and their information content is minimal. Based on the high cost of doing LiDAR, I don't believe that the limited information gained is worth the 

cost. 

No 

222 90 ?? ?? This is an area that GCMRC has seemed to let slip over the 

last few years. In fact, the lack of access to data and the lack of website updates indicate that DASA is a very low priority of the GCMRC. Given the current state of its DASA program and its outreach efforts, there are many changes needed for this section including: 

1. Concrete analysis and plan to update website 

2. Concrete plan to get better access to all GCMRC 

datasets 

3. Plan to integrate legacy reports with current reports 

in accessible on line search and downloadable format 

4. Plan to make GIS data available for public 

download. 

5. What happened to the legacy data scanning project 

(photos, old reports, etc.)? What is the plan to get that back on track? 

6. Plan to make datasets of general interest including 

hydrology, water chemistries, sediment, fish, etc. 

more easily available for download. Even summary statistics from some of these areas would be better than what stakeholders have access to now. 

7. Reporting of findings from GCMRC staff and its 

cooperators has been unacceptably slow. Plan to remedy this situation should be outlined in this section. Assume overhaul of peer review process is needed to speed review and reporting process. 

Thi15, http

A sby Swebhttpns_reduavaDAwebdatadow

Funtabuby tSys201inclspecLaknutrSpaServfor webprovServfor Redredu
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

DAdata sharGCbeinDAImphigh to dmor

223 90-99 Grand 

Canyon Wildlands Council, Inc. 

The information management plan is outstanding and is 

needed before a long-term information management program or a core monitoring program can be implemented. When will 

that plan be completed? GCMRC has been collecting data for 

more than a decade and sits on the previous decade of largely uncompiled information. Each day the task of integrating those data grows more difficult. Please expedite the development and completion of this plan. 

We inteimpwith DAdevdescFGDThe Dat(DAcurrand webAmDA

224 100 Capron Western Chapter 5: I think this chapter would have worked better 

earlier in the document. I’m preparing a revised outline that illustrates a different approach to the topic. 

Thiversinco

225 100 Capron Western Ch 5: This chapter is lacking a discussion of other programs 

like the LTER sites. 

A gthe addmigrevi

226 100 Grand 

Canyon Wildlands Council, Inc. 

How much of the USGS’s Southwestern Research Center and staff is supported by the AMP. Are long-absent USGS staff being supported by the AMP? On lines 7-10 a quote is given about the quality of information; however, the EIS and ROD also indicate that GCMRC is to be a small, efficient body, which does not appear to be the present condition of that office. See comments for Pp. 84-89 (above). 

The conadmtravGCthe suppclea
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

is recertstafacknlargenvthe the Secsciecooconand GCits srespand resedata suppbelicurrdimstafinvowor

227 101 4-6 Kurt 

Dongoske 

Pueblo of Zuni 

Please define the process for outside monitoring data being integrated into this core monitoring plan. No mention of that effort until here. 

Yes Out

to bdata the For PariRanGCGCIn adamclimmonand 

228 101 34-36 Kurt 

Dongoske 

Pueblo of Zuni 

Are these positions in addition to your program managers? Please 

respond 

Yes Sec

MoFullposto 1bioldata man
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

GCadmmanthe 

229 101 43-44 Kurt 

Dongoske 

Pueblo of Zuni 

Interesting that there are no archaeologists identified as science specific specialists for the monitoring of sociocultural science; especially after the majority of the program is devoted to providing information on the status of archaeological sites. Seems incongruent. 

No GC

fully acco

230 101 Capron Western Staffing: I can’t follow the staffing requirements which are on 

this page and follows to the next section with a conclusion of 26 FTEs needed in 2015. This certainly seems like a lot of FTEs especially given our recognition of recent funding limitations. It is hard to tell how much time these FTEs will give to CM vs. other operations. I’m concerned that a growing number of FTEs will lead to less available funding for science/research, and it is difficult to evaluate these tradeoffs with this limited information. It would be helpful if the staffing requests were related to the GCMRC org. chart. 

The somthe idenneecapcurrexpTWmonThe the orgamonthat core 

231 101 16 Grand 

Canyon Wildlands Council, Inc. 

Periodic reviews of GCMRC’s productivity and competence 

also should be conducted, either by the SA or by external reviewers or auditors. 

We our the revi

232 102 10 Werner AZ This paragraph doesn’t fit well under the Information Outreach 

heading. Check paragraph structure, flow from previous page. 

Check Y Agr

placStaf

233 102 16 Werner AZ If the specifics are not known for several resource areas can 

the FTEs/budget be predicted now? 

Explain Y Gen

coocon– inthe are suppTheagreGC
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

234 102-103 Capron Western CMP costs: The first paragraph ends with a total cost of about 

$6 million ($6.4 million on page 104) for the CMP and GCMRC estimates this as 60% of the total AMP budget. However, I think a better representation of this is the percentage of the budget allocated to GCMRC, which works out to about 75%. It is not likely that the portion of the budget allocated to BOR administration of the program will be used to fund CMP activities, so I think 75% is a more accurate description of the relative cost. This leaves about $2.3 million 

for other monitoring programs and research related activities. 

Table 6 is very helpful in figuring out costs related to programs and funding. It would be really helpful to see this combined with the full program for each goal, in order to see what is not proposed as CM. Plus, I don’t think these numbers are included with the discussion of each goal, at a minimum a reference should be included under each goal to this table. At this point in time, I think the AMP needs to decide if this is 

the right mix of CM and other science. From this CMP I don’t 

think we have a lot of tools to do that, other than a gut feeling that this may be more than we want to spend on long term monitoring (given current funding constraints). This brings up the following questions: 1. What is our long term need for funding for experimental programs and short-term monitoring? 2. What are the DFCs and MOs such that we can accurately determine which of the core monitoring proposals meet our needs, or perhaps is beyond our needs? 3. What are the tradeoffs between cost and loss of precision in our data collection (i.e., could we sample on a biennial schedule instead of annual and still reach the same conclusions and have roughly the same power in the data?). 4. There is a trade-off between core monitoring to support nearly all of the CMINs and cost – my sense is that GCMRC is preparing a CMP that covers many of our needs to respond to the vast majority of the CMINs (although I can’t follow that here, this is just my assumption), how do we move from this point to either accept that strategy or refine our CM needs in order to reduce the budget to something less than proposed (e.g., something on the order of 40-50% of the GCMRC budget)? 

One long resemanmanall ocappmajbelimonadapabilstatuachthe such revecomstranot of threso

235 104 Table 

6; line 11 

Kurt Dongoske 

Pueblo of Zuni 

Does this mean that more than 90% of the cost of cultural monitoring will be spent internally by GCMRC? 

Please respond 

yes No, 
Comment 

Number Page Line Reviewer Name Affiliation Reviewer Comments (Be specific Identify Action Requested Response Requested 

236 104 Table 5 Grand 

Canyon Wildlands Council, Inc. 

The costs presented do not appear to be competitive with what could be achieved though other routes (e.g., academic institutions or NGO’s). The number of GCMRC staff supported for many of the goals appears to be excessive. 

Opi

237 112 Grand 

Canyon Wildlands Council, Inc. 

The last reference: Stevens and Gold was published in 2002 (an ESA review on that book appeared in 2003, and likely is the source of confusion to the authors of this report). 

OK

238 132 QA/QC Werner AZ The font is different from the rest Note the irony Iron239 Grand 

Canyon Wildlands Council, Inc. 

LITERATURE CITED Myers, T.M., C.C. Becker, and L.E, Stevens. 1999. Fateful 

journey: injury risk and death on Colorado River trips in Grand Canyon. Red Lake Books, Flagstaff. 

OK