Ben Burr, Executive Director March 25, 2024

BlueRibbon Coalition

P.O. Box 5449

Pocatello, ID 83202

Bureau of Reclamation

Attn: LTEMP SEIS Project Manager

125 South State Street

Suite 800

Salt Lake City, UT 84138

BlueRibbon Coalition is writing to provide feedback for the Supplementary Environmental

Impact Statement for short term management of the Colorado River. BRC is a national

non-profit organization that promotes responsible recreation and encourages a strong ethical

dialogue and individual stewardship of our natural resources. We champion responsible use of

public lands and waters by all recreationists through education of their responsibilities and the

empowerment of our members to secure, protect, and expand shared outdoor recreation

access. We are proud to work collaboratively with governments, natural resource managers and

other recreationist groups.

We represent tens of thousands of Lake Powell and Glen Canyon Recreation Area users. Glen

Canyon National Recreation Area is a significant national treasure as well as a spectacular

producer of revenue. In order to keep water flowing to the Lower Basin users Lake Powell has

depleted its storage of water and the level of the lake has dropped to the point that it has at

times precluded any recreational (economic) activity on its north end. This began December 2,

2021 and continues to this point in time with only limited operational capabilities. During periods

of 2021-2023, its south end was compromised to the point that recreational utilization, and its

attendant revenue, almost vanished. While we recognize the importance of water deliveries and
hydroelectric power generation, it is important to recognize the economic benefits of recreation

use of these waters is comparable to the economic benefits of the other uses and vitally

important to the communities that rely on these benefits. The negative impacts of lost recreation

access disproportionately impact Navajo Nation tribal communities on the southern border of

the GCNRA, as well as Page, Arizona. BRC supports a modified Alternative 6 – the Non-Bypass

Alternative – as it best addresses the concerns of BOR. We also believe that BOR should time

releases based on whether lake levels in Lake Powell currently provide access to important

amenities on the lake. For example, BOR should delay experimental releases, if doing so would

impact access to the Castle Rock Cut. The timing of releases should be taking recreation into

consideration. BOR should also not be implementing releases if nests and smallmouth bass are

not detected beneath Glen Canyon Dam.

As non-consumptive users, our rights will not interfere with any of the other users of Colorado

River water. For 60 years Lake Powell has stood as the guardian and fulfilled its role as a

management tool for adequate Basin State water allocation. It is now time to rethink those

original policies and include other stakeholders in future policy considerations.

We feel that recreationists have a right to access and use stored water. As a natural resource,

water is to be used for the benefit of all of us. It is in the public interest to allow recreational use

of our natural resources that leads to no adverse effect or depletion of those assets. Colorado

River water belongs to us all and we encourage any move in a direction that enables the

benefits of this water to be enjoyed by the greatest number of users.

Economic Considerations

BOR should analyze the full impact of recreation opportunities with releases and experimental

flows. In 2023 Glen Canyon NRA had an all time high visitation record of 5.2 million. Economic

impact reports from NPS released last year showed that Glen Canyon had lost over $200 million

in economic benefit to the region surrounding the lake during the two years of low water levels.

When developing future plans potential economic loss needs to be considered. This is why the

timing of releases is so crucial as it could cost GCNRA millions of dollars in economic benefit. In

2022 GCNRA economic output was $372,677,000.1 That is more than $7 million per week. The

Bureau of Reclamation needs to consider the full impact of water levels and releases on the

economy when selecting an alternative and making a decision. Releases that cause lake levels

to drop for an extra week or two cost local communities millions of dollars. Its economic

multiplier is 10, giving rise to over $4 billion in direct economic value to its surrounding and

regional areas. The low water years at Lake Powell were nothing short of a wipeout that cost

1

https://www.nps.gov/orgs/1207/national-park-visitation-sets-new-record-as-economic-engines.htm#:~:text=WASHINGTON%2C%20

D.C.%20%2D%20The%20Department%20of,economy%20and%20supported%20378%2C400%20jobs..
their local economies over $300 million in two years. We now know that the low-water levels

cost the area surrounding Lake Powell hundreds of millions of dollars in direct economic benefit.

In 2022, Glen Canyon NRA showed a $207 million dollar decline. Those numbers are big

enough they should be factored into this decision.

In 2019 both GCNRA and Lake Mead generated more economic output confirming that higher

water levels support economies. According to the Bureau of Economic Analysis, outdoor

recreation boosted the economy by $1.08 trillion in 2022.2 “Boating/fishing was the

second‐largest conventional activity for the nation at $32.4 billion”

Conclusion

We would like to close by saying we spupport “shared use”. As long as overall visitation

numbers are appropriate for the affected resources, motorized and non-motorized users can be

compatible with one another so long as individual users understand designations and plan their

activities accordingly. Indeed, motorized and non motorized recreation use often overlap as

OHV’s often increase accessibility to non-motorized recreational activities such as hiking,

camping, equestrian use, etc. We also hold that responsible recreational use of public lands can

exist in harmony with ecosystem needs.

BRC would like to be considered an interested public for this project. Information can be sent to

the following address and email address:

Ben Burr

BlueRibbon Coalition

P.O. Box 5449

Pocatello, ID 83202

brmedia@sharetrails.org

Sincerely,

Ben Burr

Executive Director

BlueRibbon Coalition

Simone Griffin

Policy Director

BlueRibbon Coalition

2 https://www.bea.gov/sites/default/files/2023-11/orsa1123.pdf