GLEN CANYON DAM ADAPTIVE MANAGEMENT PROGRAM 

 AMWG FACA COMMITTEE GUIDANCE 

Purpose of this Document 

During the first two years of implementing the Glen Canyon Dam Adaptive Management 

Program, it has become apparent that several aspects of the program, specifically relating to the 

Record of Decision, the Glen Canyon Dam EIS and the Grand Canyon Protection Act need to be 

clarified in order to facilitate and focus the activities of both the Adaptive Management Work Group 

Committee (AMWG) and its subcommittee, the Technical Work Group (TWG). It is the purpose of 

this document to provide that direction. The following guidance represents the Department=s 

understanding and intent concerning the purpose and role of the AMWG Committee and the scope of 

work given to the Committee in its Charter, pursuant to all relevant law and Departmental policy. 

This guidance has been assembled with the assistance and legal guidance of the Office of the 

Solicitor and has been shared with all members of the AMWG prior to finalization. 

Background 

During the past century, there have been numerous developments affecting the Colorado 

River that have led to the present juncture. On November 24, 1922, the Colorado River Compact 

was signed at Santa Fe, New Mexico, allocating the water of the river between the Upper and Lower 

Basins, as defined therein, as well as establishing the rules, rights, and obligations governing the use 

of that water among the seven respective states within the Colorado River Basin. The United States 

also has a treaty with the United Mexican States (Mexico) guaranteeing Mexico 1.5 million acre feet 

annually from the Colorado River. Among the other obligations established in the Compact was that 

of the Upper Basin not to deplete the flow of the river at Lee Ferry "below an aggregate of 

75,000,000 acre-feet for any period of 10 consecutive years." 

Earlier, in 1908, Congress set aside the Grand Canyon as a national monument and in 1919 

expanded the reservation and redesignated it as a national park. There are only about fifteen river 

miles separating the outlet works of Glen Canyon Dam and the upstream boundary (on the northerly 

side of the river) of Grand Canyon National Park. Later, Congress also established the area 

surrounding Lake Powell and extending down river to the Park boundary (except for the area within 

the pre-existing Navajo Reservation) as the Glen Canyon National Recreation Area, also managed by 

the National Park Service. 

In large part in order to assure that the rights and obligations in the Colorado River Compact 

and the Upper Colorado River Basin Compact could be met without jeopardizing the water uses of 

the Upper Basin states in the future, Congress passed the Colorado River Storage Project Act on 

April 11, 1956, which provided the authority for the construction of the four "initial units" of 

CRSPA, namely Flaming Gorge, Aspinall, Navajo, and Glen Canyon dams. Glen Canyon Dam, 

storing more than 26 million acre feet, over 24 million of which represent active capacity, is situated 

immediately above Lee Ferry, the delivery point to the Lower Basin. In 1968 Congress passed the 

Colorado River Basin Project Act which among other things provided for coordinated operations of 

Colorado River Basin reservoirs. Until recently, Glen Canyon Dam has been operated with 

essentially two functions in mind: compact deliveries to the Lower Basin, and hydropower 

generation. Compact deliveries from Glen Canyon assure that the Upper Basin can meet its delivery 
 

 

 

 

 

 

 

 

 

 

 

 

obligations to the Lower Basin states and effectively manage other Upper Basin reservoirs to meet 

Upper Basin water supply needs. Hydropower generation provides the revenues necessary to cover 

operation and maintenance costs as well as the revenues needed to assure repayment of CRSP 

projects. 

During the 1980s, it became apparent that the existing pattern of dam operations was 

adversely affecting some of the riparian resources in the Park and the Recreation Area below the 

dam. The Department began studying the situation, initiated the preparation of an EIS, and then 

Congress passed the Grand Canyon Protection Act of 1992 to attempt to address this problem. 

Authority (Questions 1a, 1b, 1c, 2a, 3, 4c, 5a, 5c, 5e, 6a, 6b, 7a, 7c, 8, 12c, 13a, 14) 

Grand Canyon Protection Act, Legislative History, and Law of the River 

It is quite clear that when Congress enacted the Grand Canyon Protection Act of 1992, 106 

Stat. 4669 (GCPA), it intended to maintain all that had gone before B the Compacts, the Park units, 

and Glen Canyon Dam B"1 downstream NPS resources without interfering with the "Law of the 

River," including compact and treaty obligations for water delivery (GCPA, section 1802(a) and (b)). 

The Senate Report on the bill puts it quite simply: A The primary purpose of this title is to authorize 

changes in the operation of Glen Canyon Dam to prevent damage to downstream resources, 

principally the dam=s power operations.@ The Secretary=s responsibilities for water storage, allocation 

and delivery act as limits on the Secretary=s discretion in implementing the GCPA. It is also clear 

that Congress understood that these objectives would have certain costs in the form of lost 

incremental hydropower generating opportunity (GCPA, section 1809) and that the existence of the 

dam was to be taken as a given. 

The basic question Congress was addressing was how Glen Canyon Dam operations might be 

modified within the provisions of existing law so as to improve conditions for downstream NPS 

resources (with similar benefits certainly occurring on other similarly situated lands). The GCPA 

itself does not direct consideration of cultural resources within the boundaries of Native American 

reservations, only "the values for which Grand Canyon National Park and Glen Canyon National 

Recreation Area were established," although all federal agencies have similar obligations under other 

law. The entire adaptive management program (AMP), including the Grand Canyon Monitoring and 

Research Center and the Adaptive Management Work Group, must be understood within this 

context. In accordance with section 1804 of the GCPA, the EIS was conducted to attempt to find an 

answer to that question, and the 1996 ROD was the Department= s best first answer. Recognizing 

that more experience and knowledge with operations might enable further refinements in operations 

and might further improve downstream resource conditions, however, Congress added section 1805 

to the GCPA. This section required the Secretary to "establish and implement long-term monitoring 

programs and activities that will ensure that Glen Canyon Dam is operated in a manner consistent 

with section 1802," namely, "to protect, mitigate adverse impacts to, and improve the values for 

which Grand Canyon National Park and Glen Canyon National Recreation Area were established," 

within the parameters of other applicable law and the physical constraints of the dam. Accordingly, 

the Department included in the EIS and in the ROD the provisions setting up the AMP, thereby 

allowing for further refinement of and changes to dam operations to better meet the GCPA 

objectives. 
 

 

 

 

 

 

 

 

 

 

The charge given to the AMWG in its Charter is to "facilitate the AMP, recommend suitable 

monitoring and research programs, and make recommendations to the Secretary as required to meet 

the requirements of the Act.@ The scope of the AMWG responsibility, therefore, is to identify 

aspects of dam operations that can be modified to beneficially affect the downstream resources 

identified as the focus of study (i.e. "the target") in the EIS. This covers flow rates, ramping rates, 

periodicity of peak flows, monitoring sediment input rates and the relation of sediment movement to 

water release and ramping rates, chemical content and temperature of releases, among possible others 

--any aspect of dam operations, in other words, which has a reasonably demonstrable effect on the 

downstream resources sought to be improved by the GCPA. The key to the scope of AMWG=s 

responsibilities is whether a specific desired resource effect downstream of the dam can be achieved 

through some manipulation of dam operations. Under the ROD, the upper limit of planned release 

level is 45,000 cfs. Long-term monitoring and research, including test flows within the current 

range of authorized operations, are intended to enable finer and finer tuning of operations over time, 

as additional knowledge and experience are gained, to better achieve the target mix of resource 

benefits, as outlined in the EIS, pages 54-65. 

Without losing track of this primary focus on improving conditions for downstream 

resources, the Charter also specifies that the AAMWG may recommend research and monitoring 

proposals outside the Act which complement the AMP process, but such proposals will be funded 

separately, and do not deter from the focus of the Act.@ This would include anything the AMWG 

committee considers relevant but tangential or attenuated in its effects on riparian resources 

downstream of the dam, as identified above. The relevant Senate Report language says, after the 

discussion of the primary purpose of the Act, that: A other reasonable remedial measures may be 

available to the Secretary. The phrase >exercise other authorities under existing law= means that the 

Secretary should consider and may implement non-operational measures to address downstream 

effects of Glen Canyon Dam if such other remedial measures meet this title=s goal of protecting, 

mitigating damage to, and improving the resources downstream of the dam.@ Again, as emphasized 

in the Senate Report, "the water storage, allocation and delivery requirements of the Law of the River 

place substantial limits on the Secretary=s ability to change other elements of GCD operations. All 

measures undertaken pursuant to the authority of this Act have as their focus the improvement of 

conditions for downstream resources within the two Park Service units." The TWG= s responsibility 

is similarly limited, but even more so; it is to carry out only specific assignments within the scope of 

the AMWG=s responsibility, as directed by the AMWG. 

The AMWG was set up pursuant to the Federal Advisory Committee Act (FACA) and must 

comply with FACA=s requirements for notice and public meetings, etc., as laid out in the GSA 

regulations at 41 CFR Subpart 101-6.10. The AMWG and TWG may establish their own internal 

operating procedures as they wish, so long as they comply with the specific requirements of FACA 

and its implementing regulations. 

One area that has been a source of recent discussion has been the question of planned high 

releases from Glen Canyon Dam for such purposes as "beach habitat building flows." The 

Department expects the AMWG to work and provide its recommendations within the following 

context. Since the GCPA is clear that it was not intended to modify the compacts or "the provisions 

of the Colorado River Storage Project Act of 1956 and the Colorado River Basin Project Act of 1968 

that govern allocation, appropriation, development, and exportation of the waters of the Colorado 

River Basin" (GCPA, section 1802(b)), any operational changes under the auspices of the GCPA are 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

clearly subordinate to and must fit within the constraints of those provisions. Historically, there have 

been differences of legal opinion over some related issues, such as whether releases of water above 

power plant capacity, if made for authorized purposes, can be considered as not constituting "spills" 

within the meaning of section 602(a) of the Colorado River Basin Project Act of 1968 and the 

Operating Criteria implemented pursuant to section 602, and more recently over whether the GCPA 

"amends" existing law by adding additional authorized purposes for the operation of Glen Canyon 

Dam. These legal issues have not been finally resolved, but given the limitations provided in the 

ROD, the Glen Canyon Dam operating criteria, and the 1996 agreement between the Department and 

the Basin States, it is believed that they have been adequately addressed. Clearly, section 7 of the 

CRSPA, which directs the Secretary "to produce the greatest practicable amount of power and energy 

that can be sold at firm power and energy rates" provided that the primary purposes of compact 

deliveries and state compact allocation development are not precluded or impaired, remains in effect, 

even though the GCPA (section 1809) authorized, and the EIS/ROD implemented, an incremental 

reduction in the value of the hydropower resource. Under the conditions of those documents (the 

ROD, the operating criteria, and the 1996 agreement), flows above power plant capacity would be 

conducted utilizing reservoir releases required for dam safety purposes. The Department is currently 

focusing on operational modifications at release levels below 45,000 cfs. Modifications to the 

operating criteria involving flows above 45,000 cfs would require additional NEPA compliance. 

EIS/ROD (Questions 1b, 4c, 5a, 5c, 7b, 7c, 12a, 12b, 12c, 13a, 13b, 13c, 13d, 13e, 13f, 15) 

As mentioned above, the EIS conducted on Glen Canyon Dam operations contains the 

Department=s selection of a mix of targeted resource benefits and its attempt to balance these benefits 

against costs to hydropower generation. As stated in the ROD: 

The goal of selecting a preferred alternative was not to 

maximize benefits for the most resources, but rather to 

find an alternative dam operating plan that would permit 

recovery and long-term sustainability of downstream 

resources while limiting hydropower capability and 

flexibility only to the extent necessary to achieve recovery 

and long-term sustainability. 

The ROD represents the Department=s "first cut" on providing an answer as to how that 

target might be achieved. The EIS and ROD are relevant to the AMP process in several 

respects. First of all, the EIS identifies the specific downstream resources sought to be 

benefitted (i.e. Aprotected, mitigated for, or enhanced@) by changes in dam operations (see 

EIS, pp. 54-57 and Table II-7). Secondly, its discussions and analyses of various 

alternatives provide a starting point for the state of the science at the time the decision was 

made to implement the Amodified low fluctuating flow@ pattern of operations with a 

commitment for long-term modifications in response to further research. In the language 

of the ROD, "the Modified Low Fluctuating Flow Alternative was selected as the 

preferred alternative because it would provide the most benefits with respect to the 

original selection criteria, given existing information." 
 

 

 

 

 

 

 

 

 

The monitoring, research and experimental programs are intended to develop additional 

information, working with the AMWG recommendations, "which could result in some 

additional operational changes." The selection criteria against which such changes are to 

be measured, however, remain unchanged. Elsewhere the ROD amplifies that this 

alternative was selected because it "meets the critical requirements of the sediment 

resource by restoring some of the pre-dam variability through floods and by providing a 

long-term balance between the supply of sand from Grand Canyon tributaries and the 

sand-transport capacity of the river" with corresponding benefits to habitat. The ROD, in 

part in conjunction with the EIS, also describes in detail the decision made, including 

modifications to the selected alternative, specific environmental and monitoring 

commitments, the scope and objectives of the AMP, the role and function of the Grand 

Canyon Monitoring and Research Center (GCMRC), and the role expected for the 

AMWG and TWG. It is important to understand that before either the targeted resource 

blend or the operational pattern in the Glen Canyon Dam operating criteria can be 

changed materially, additional NEPA work would have to be done. 

Among the environmental commitments made in the ROD was the commitment to restrict 

Glen Canyon Dam release upramp rates to 4,000 cfs per hour and downramp rates to 

1,500 cfs per hour. Consistently with interagency agreements between BOR and the 

Western Area Power Administration (WAPA) both prior and subsequent to the 1996 

ROD, these figures should be understood to represent a firm limit on changes in release 

rates integrated over each hourly interval, to be enforced by the Secretary, subject to being 

exceeded only in times of emergency unless and until changed by subsequent decision of 

the Secretary. 

As part of the adaptive management process, studies and information needs specified in 

the EIS/ROD are expected to be completed and to result in the identification of new 

information needs or definitions of effects, impacts and mitigation requirements. 

All applicable federal laws must be complied with, including NEPA, NHPA, ESA, 

FACA, and the APA, in addition to the federal laws considered part of the ALaw of the 

River.@ It is not expected that the Adaptive Management Program will result in 

additional required NEPA compliance unless additional resources (i.e. "management 

objectives") are identified and targeted for inclusion in the revised dam operations beyond 

those identified in the existing EIS. 

Organization (Questions 8, 9, 10, and 11) 

Prior to the EIS and ROD various Federal Agencies (e.g. BIA, WAPA, BOR, 

NPS, FWS) had various statutory responsibilities for compliance with laws involving 

such areas as the environment, historical and cultural resources, and threatened and 

endangered species. These agencies have frequently entered into agreements among 

themselves to take specific actions to meet those statutory requirements. It was assumed 

when the AMP was adopted by the Secretary that it would include all studies necessary to 

determine the effects of GCD operations on the designated resources selected in the ROD. 

Some of these studies meet scientific needs and also meet statutory requirements under 
 

 

 

 

 

 

 

 

 

 

 

NEPA, ESA and NHPA. In fact the EIS identified some specific studies that would be a 

part of the AMP, such as the study of low steady flows. 

The Secretary of the Interior established the AMP with four key elements: 

AMWG, TWG, GCMRC, and the IRP (Independent Review Panel). The four have 

distinct roles, but ultimately the Secretary of the Interior is responsible for seeing that the 

monitoring and necessary research is done to evaluate the impacts of adjustments made to 

dam operations. The EIS document prepared by the Secretary envisioned the AMP 

program to be a somewhat all-encompassing investigation of impacts, while still 

respecting the statutory obligations of each of the Departmental agencies. One of the 

mechanisms chosen by the Secretary to receive feedback through the AMP is the AMWG, 

which is to provide recommendations on the content of the various budgeting and 

planning documents. The AMWG can recommend studies and priorities for implementing 

individual studies during those reviews, preferably by consensus. In doing so, all 

members of the AMWG are assumed to be equal in importance when voting on 

recommendations, including federal agencies. However, final decisions as to the 

management of Interior facilities and resources, what studies to implement, when, and 

using funds from which sources remain, by statute, with the Secretary of the Interior and 

the appropriate Interior agencies. 

Funding (Questions 2b, 4a, 4b, 5b, 5d, 6a, 7a, 17, 18, 19, 20, and 21) 

Funding for any federal effort comes from the statutory authorities provided by 

enacted laws. In the case of the AMP, several funding authorities can come into play --the 

most visible being the Grand Canyon Protection Act (GCPA) of 1992. The GCPA makes 

several statements with regard to potential sources of funds and also imposes some 

restrictions. With regard to the use of revenues generated from the sale of electric power, 

section 1807 is specific and restrictive. The hydropower revenues may be used for 

preparation of the EIS, including supporting studies, and the long-term monitoring 

programs and activities described in section 1805. Both hydropower revenues and 

appropriated funds can be used for administrative expenses to implement the specified 

work. However, the use of such funds to pay expenses of non-government employees 

may be covered under FACA and other fiscal regulations and must be treated on a case by 

case basis. The GCPA also authorizes such sums to be appropriated as are necessary and 

encourages use of other authorities under existing law to determine the effect of the 

Secretary's actions under section 1804 (c) and 1805 (b) on the natural, recreational, and 

cultural resources of Grand Canyon National Park and Glen Canyon National Recreation 

Area. The activity and its authorization determine the funding. To date, hydropower 

revenues have been the source of funding for almost all AMP activities because they meet 

the definition above. Research and monitoring proposals outside the Act which 

complement the AMP process are to be separately funded. 

As stated in the authorities section above, the focus of the GCPA is downstream of 

the dam and primarily on the operations of the power plant. The existence or construction 

of the dam and its associated impacts is not a focus. This is clear in both the EIS and 
 

 

 

 

 

 

 

ROD, i.e. in the EIS at page 2, top of page, right hand column ASince the dam has long 

been completed, alternatives to the dam itself have been excluded from the scope of the 

analysis.@

To illustrate the range of activities and associated funding, some examples are 

provided below: 

o Studies of control sites in Cataract Canyon or on reservation lands, for example, may be 

supported by revenues, if the studies are determined through scientific peer review to be 

necessary for determining the effects of the Secretary's actions downstream within the park 

units under 1804(c). 

o Studies of water quality in Lake Powell are allowable if necessary to determine the 

effects on downstream resources. Studies of the effects on cultural resources around the rim 

of Lake Powell are not allowable under AMP (GCPA) funding. 

o It is reasonable to assume that while the primary focus is on power plant releases the 

releases from the bypass tubes and spillway outlet works also fall into the operational 

category and funding could be used to conduct experiments and study impacts from their 

operation. In fact, this has already occurred to a degree during the 1996 beach habitat 

building test flow when the bypass tubes were used. 

All Federal agencies have a special responsibility to Native Americans by law, including 

statutes, treaties, and executive orders. With the Secretary of the Interior being trustee, Department 

of the Interior agencies have a special role. Certainly the direct impacts of the dam operations on the 

Native American trust resources within the park units can and should be funded from hydropower 

revenues, but such impacts outside the boundaries of the river corridor in the park units must be 

studied using other appropriated funds. Participation in the AMP or education activities should be 

funded from appropriate sources. For instance education activities may come under self-governance 

and self-determination programs and be funded from BIA funds, activities surrounding general NPS 

requirements may be funded from NPS funds, and participation in AMP work group activities may 

be specific enough to be funded by revenues or appropriations from BOR. Funding of Native 

American activities should be a shared responsibility. 

Other Compliance and Consultations (Questions 11, 16, and 21) 

Prior to passage of GCPA and formation of the AMP, federal agencies had many 

responsibilities embodied in existing law. Those responsibilities remain today. The GCPA, 

EIS/ROD, and AMP did not take over responsibility for nor remove the legal obligations of the 

agencies to fulfill existing legal mandates. The GCPA states as much in several places. The AMP is 

a process by which the Secretary of the Interior has chosen to include all studies and other 

compliance activities necessary to determine the effects of GCD operations on designated resources 

and to modify operations to meet the purposes of the GCPA. 

It is possible that some of the studies recommended and performed under the AMP and the 

AMP budget will coincide with and help to satisfy obligations of the federal agencies under other 

laws, such as the Endangered Species Act. The obligations imposed by other laws must be complied 
 

 

 

 

 

 

with by the responsible agencies, whether they are funded as part of the AMP process or separately. 

The AMP budget does not imply that these compliance functions will automatically be assumed or 

raised to a higher priority through the AMP process, although where reasonable, the AMP process 

may assist or even satisfy such functions in a given instance --"two birds with one stone," so to 

speak. 

While the AMWG and TWG should be aware that the involved federal agencies face these 

responsibilities, those factors should not detract from the committee=s focus as described in the 

GCPA, EIS, ROD, and Charter. The committee=s recommendations for studies and their relative 

priorities should remain on the effects of dam operations on downstream resources within the park 

units. The implementation of such studies, their timing and funding and the like remain the decision 

of the Secretary and the federal agencies, as noted earlier. 

Embodied in the NEPA process is the requirement to comply with ESA and cultural laws in 

order to discuss and present the impacts on all resources and eventually arrive at a preferred 

alternative. For example, the AMWG is not chartered to be a formal participant in ESA consultation 

processes. However, the AMP does not prevent AMWG members from participating as members of 

the public or in their other official capacities. In this regard, AMWG should focus on helping 

Reclamation determine how to apply the reasonable and prudent alternatives within the area of 

concern of the GCPA. In regards to the consultation requirements under NHPA, the action federal 

agencies and affected tribes have signed a programmatic agreement (PA) document and hold 

periodic meetings. Parties not signatory to the PA are welcome to attend and comment. Here too, 

however, the ultimate decision on how to proceed rests with the Secretary of the Interior and the 

federal agencies delegated the responsibility for management of the resources. 

Other Program Relationships 

While programs in other areas of the Colorado River do not require direct input from the work 

performed for the GCPA, it is certainly envisioned that information will be shared and that 

participants will keep abreast of other relevant basin activities. The GCPA requires compliance with 

existing laws and consultations with a variety of groups. To meet that requirement it is important 

that all members share knowledge obtained from activities arising from e.g. the upper basin recovery 

program, the salinity control program, and the lower Colorado multi-species conservation program. 

APPENDICES: 

QUESTIONS 

Scott Loveless has responded to and the TWG has discussed a list of questions which was prepared 

by Bob Winfree on December 15, 1998, and which was attached to Steve Magnussen=s memo of 

December 29, 1998. Those discussions generated the following additional questions for Scott from 

TWG. The following numbered list embodies the questions that led to the above guidance 
 

 

 

 

 

 

 

document. 

1. (a) What is the scope of the AMWG Charter? 

(b) How do the EIS, the ROD, and the Act impact the scope? 

(c) Can the AMWG charter expand upon the scope and authorities in the Act?

 (EIS & ROD) 

2. (a) Is the AMP limited by section 1804? Can AMWG recommend changes in the 

operating criteria? 

(b) Can the program expend funds to study (research) impacts of proposed 

(recommended) changes that are clearly beyond the limitations of Sec. 1804(c)? 

3. What constitutes the target? 

4. (a) Can funds as designated in 1807 be used to fund studies outside the effects of 

dam operations (outside the operational confines of the dam)? 

(b) How direct must the impacts be to allow funding under 1807? 

(c) Where does the burden of proof lie for determining the effects of dam operations? 

5. (a) Is the AMP limited to power plant operations when hydrologic triggering criteria 

are not met? (paraphrase, Can you do an experimental flood when not required for 

dam safety purposes.) 

(b) Does the GCPA authorize funding to be used for mitigation of power plant 

operations, or is it broader; e.g., mitigate for spillways, bypass tubes, dam 

existence (Furnace Flats)? (i.e., Can AMP funding be used to mitigate sediment 

reduction, temperature averaging effects due to the existence of GCD.) 

(c) Does NHPA require mitigation for damage to properties eligible for listing on the 

National Register of Historic Sites as a result of the dam=s existence? 

(d) Does the law allow for funding mitigation activities related to construction 

[existence] of the dam versus operations of the dam? 

(e) Were power plant spills other than those hydrologically induced authorized by the 

Act? 

6. (a) Does the monitoring program allow for research and monitoring of potential 

effects of releases up to 256,000 cfs? 
 

 

 

 

 

 

 

 

 

 

 

 

 

(b) What is the legal boundary for lateral extent for all resources? 

7. (a) When is it appropriate to propose experiments outside the preferred alternative? 

(b) Can experiments be performed which are outside of the ROD? 

(c) What are the limitations when performing an experiment outside the ROD? 

8. What are the TWG responsibilities relative to review and editing of the monitoring and 

research plans prepared by GCMRC? 

9. What organization is responsible for developing needed AMP planning documents and 

reports other than science program reporting? 

10. Do recommendations of all stakeholders represented in TWG and AMWG carry equal weight 

in [TWG/AMWG] decisions? 

11. The AMP has only been in place for a few years. Before the AMP, the various Federal 

Agencies involved had certain statutory responsibilities for environmental, historical and 

ESA compliance and they entered into agreements to take specific actions. Does the 

existence of an AMP budget automatically assume these compliance responsibilities for the 

agencies; and if so, do the agencies compliance responsibilities automatically become the 

dominant focus of the program? (e.g., Biological Opinion, Cultural Resources, etc.) 

12. (a) Can the management objectives as outlined in the EIS be changed and, if so, how 

much can they be changed? 

(b) Are the management objectives as outlined in the EIS different from the expected 

changes in management goals adopted by the Secretary when he selected the 

preferred alternative? 

(c) Were the recommended changes in power plant operating criteria made to achieve 

the desired changes in management goals? 

13 (a) What is the force and effect of the ROD? 

. 

(b) What limits does it put on our actions? 

(c) Are there any parts of the paper, prepared by Reclamation and WAPA and 

distributed at AMWG, which are illegal? 

(d) Are the numbers in the ROD hard and fast? 
 

 

 

 

 

 

 

 

(e) Is it possible to exceed them? 

(f) What is the penalty for exceeding limits specified in the ROD? 

14. Does the GCPA authorize activities on Native American reservation lands (for example, 

above 124,000 cfs outside Grand Canyon National Park on Hualapai land)? 

15. When is it appropriate to propose experiments outside the ROD? 

16. Are there any prohibitions about AMWG contributing to the formal consultation on BO for 

Kanab Ambersnail? 

17. What are the limits of the use of GCPA funds on other areas outside those specified in the 

GCPA, Grand Canyon National Park and the Glen Canyon National Recreation Area? For 

example, what is the restriction on the use of funds on tribal lands? Further, what about the 

effects that are caused by the action but do not have a resultant influence downstream? For, 

example what if there were effects of dam operations in Lake Mead? Could GCPA funds be 

used to study impacts to Lake Mead caused by operational impacts of Glen Canyon Dam? 

I=m thinking here of whether these funds could be used to study the effects of operations on 

an endangered bird species in delta area of Lake Mead. 

18 . Can GCPA funds (nonreimbursable power revenues) be used for agency compliance 

responsibilities related only to the operation of Glen Canyon Dam? Specifically, can they be 

used to pay for continuing activities related to BOR or NPS NHPA, Endangered Species Act 

Biological Opinion requirements, NEPA compliance etc. The BOR has made a very strong 

argument in the past that these activities are strictly an agency responsibility and outside the 

purview of the AMP (The AMWG makes no recommendations to the secretary on these 

issues). If so, and because they are not related directly to section 1804 or 1805 of the GCPA 

how can GCPA funds be used to support them? 

19. Can GCPA funds be used to support salaries, travel, per diem etc. not directly related to 

Section 1804 and 1805 activities? For example, it would seem that there is a fundamental 

question related to the legitimacy of the use of GCPA funds for agency or stakeholder salary 

costs related to administration of the AMP. Sections 1804 and 1805 make no mention of 

administration costs for an AMP, and AMP is not directly related to research, studies, or the 

preparation of the EIS 

20. Can GCPA funds be used to assist tribes to attend and participate in the AMP process? 

21. If the BOR has legal obligations as a result of the Biological Opinion, are these obligations 

automatically the obligation of the AMWG? 
 

 

AMWG OPERATIONS 

FACA Overview 

AMWG Member List and statement of their constituency and mission, including potential conflicts 

AMWG Charter 

Proposal for Renewal of AMWG Charter 

AMWG Operating Procedures 

Appropriations Committee language re: budget 

Budget (current) 

Issues papers and AMWG Guidance Document 

Other issues yet to be resolved 

TWG OPERATIONS 

TWG Member List 

TWG Operating Procedures, Proposal to Modify OP, Ground Rules, Consensus Definition, 

Recommendations regarding travel payments to TWG members 

Ground rules for meetings 

Code of conduct 

Definition of consensus 

GCMRC OPERATIONS 

Letter Establishing GCMRC 

GCMRC Monitoring and Research Center Guidelines 

Center Protocols 

RFP's and AMWG input 

Peer Review 

Administrative review (focus on priority information needs, permitting and 

compliance
 

responsibilities 

Awarding contracts, competition 
Information transfer (reports, workshops, etc.) 

Annual Plan (current) 

Strategic Plan (current) 

LAWS, AGREEMENTS 

 Law of the River synopsis 

Colorado River Compact, November 24, 1922 

Colorado River Storage Project Act, April 11, 1956 

Colorado River Basin Project Act, September 30, 1968 

Long-Range Operating Criteria, 1970 

Long-Range Operating Criteria, October 30, 1992 

National Environmental Policy Act (Section 7 consultation) 

Grand Canyon Protection Act, October 30, 1992 and Legislative History 

National Historic Preservation Act (Sections 106 and 110) 

Programmatic Agreement on Cultural Resources, August 30, 1994 

Historic Preservation Plan 

Endangered Species Act 

36 CFR 2.5 (research and specimen collection in National Park Service areas) 

Record of Decision, Glen Canyon Dam Final Environmental Impact Statement. 10/25/96 

BOR-WAPA Operating Agreement 

Biological Opinions 

Final GCD EIS (included by reference) 

Rebecca Tsoi article on trust responsibility 

GLEN CANYON DAM OPERATING CRITERIA 

Operating Criteria for Glen Canyon Dam In Accordance with the GCPA, 2/24/97 

Operating Guidelines Associated with Glen Canyon Dam Operating Criteria 7/7/97 
 

Operating Criteria and other Operating Parameters (C. Palmer 7/97) 

Annual Operating Plans 

AMP REPORTS AND RECOMMENDATIONS: 

TWG Position Paper -Glen Canyon Dam Spillway Gate Extensions 

Integration of Programmatic Agreement with AMP, Federal/Tribal Trust Responsibilities 

BHBF Triggering Criteria 

Spill avoidance
 

Glen Canyon Dam release issues recommended for further study, and GCMRC reply
 

Report of the NEPA/ESA Issues Subgroup 

Recommendations to the TWG for expediting environmental compliance and improving
 

coordination on Biological Opinion Issues 

Letter to Secretary Babbitt from non-federal members 

Management Objectives (current) 

Information Needs (current) 

Resource Criteria (current) 

Report to Congress (current) 

State of Natural and Cultural Resources in the Colorado River Ecosystem (current) 

Lake Powell Assessment 

BHBF Flow alternatives
 

TWG, TWG, AND AMWG 

MEETING AGENDA AND MINUTES 

1995, 1996, 1997 
 

 

TWG, TWG, AND AMWG 

MEETING AGENDA AND MINUTES 

1998