Issue Paper #1 – Potential Development of MO’s for Lake Powell

Issue: The issue is whether MO=s should be developed for Lake Powell or whether the

MO=s should be limited to downstream resources. Management Objectives are defined as

the desired future condition of a particular resource. Monitoring and research in Lake

Powell is needed, as outlined in the IWQP and the Black/Gray/White monitoring decision

document in order to understand and predict the downstream impact of changing Lake

Powell water quality parameters.

Response: Management Objectives should be developed for resources downstream of

Glen Canyon Dam. Defining downstream water quality MO=s implicitly mandates water

quality monitoring and research work in Lake Powell, but appropriately focuses the

impacts and benefits of such targets on the downstream resources

Rationale: The GCPA directs the operation of GCD to protect the resources of the

Grand Canyon National Park and the Glen Canyon National Recreation Area. In several

places, the committee language accompanying the statute further defines the area of

concern as the GCNP and GCNRA downstream of the dam, noting that while Athe

primary purpose of this title is to authorize changes in the operation of Glen Canyon Dam

to prevent damage to downstream resources@, other authorities were identified Ato 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.@ With this strong focus on the downstream resources, we believe it important to

have the management objectives tied directly to these downstream resources, both for

directness of application and appropriateness of measurement.

Specific downstream targets associated with these MO=s that are directly tied to Lake

Powell characteristics will need to be monitored in order to both predict and ensure that

the downstream management objectives are met. The IWQP was developed with this

conclusion as a basic premise. The Loveless Guidance Document also confirms that

work above Lake Powell is justified based on the impacts to downstream resources. The

term Colorado River Ecosystem used in the principles and goals was defined in such a

way to include the forebay of Lake Powell and appropriate tributaries of the downstream

Colorado River to allow monitoring and research activities in these areas if necessary to

understand and improve and protect the conditions in the downstream riverine

environment.
Issue Paper #2 - Native Fish v. Lees Ferry RainbowTrout

Issue: Is there a conflict between Adaptive Management Program (AMP) goals and

management objectives for native fish versus the goals for Lees Ferry rainbow trout?

Response: Upstream of the Paria River, naturally reproducing Rainbow trout and native

fish populations will attempted to be conserved and enhanced concurrently. Downstream

of the Paria River, native fish are accorded preferential status over all non-native fish.

Rationale: This issue is focused on the need to concurrently manage for two desired

resources that may be in conflict with each other, specifically: endangered native fishes

and non-native Rainbow trout. Healthy populations of native fish in the ecosystem are a

primary management objective as reflected in National Park Service policy directives. A

healthy Rainbow trout fishery is also desired. Both fisheries are considered resources of

concern by the AMP stakeholders and in the GCDEIS.

The principles, goals, and management objectives developed by the AMP imply that the

rainbow trout above the Paria River in the Lees Ferry reach have a different status as

compared to other non-native fish in the Colorado River ecosystem. These same

principles, goals and management objectives provided guidance for resolving conflicts

between native fish and rainbow trout above the Paria River in the Lees Ferry reach.

Under the above guidance, flows, temperature regimes and other management actions

one might consider to benefit native fish throughout the Colorado River ecosystem are

initially constrained by the range of flows, temperatures, and other effects that provide

for the continued existence of rainbow trout above the Paria River in the Lees Ferry

reach.
Issue Paper #3 - Responsibility Scope of the Management Objectives

Issue: Should we include only those MOs that are the responsibility of the AMP, or

should we include all MOs needed to accomplish the Goal? Is it appropriate to include

MOs that cannot be accomplished solely through modifications to dam operations, or that

may require activities that may not be funded by hydropower revenues?

Response: In summary, the MOs should be focused on resources and impacts within

Glen Canyon National Recreation Area and Grand Canyon National Park below Glen

Canyon Dam. The question of whether nonreimbursable CRSP hydropower revenues

may be used to accomplish an MO does not have to be resolved when an MO is listed.

The GCPA authorizes both changes to dam operations and activities other than changes

to dam operations to accomplish the purposes of the act.

Rationale: This question is addressed by Principle 1, which states that "Some of the

Objectives and actions that fall under these Goals may not be the responsibility of the

GCDAMP, and may be funded by other sources, but are included here for completeness."

There are two underlying assumptions. First is that the MOs will be focused on resources

within the scope of the program and second, that some of the actions needed to

accomplish the MOs may be accomplished through "other authorities" and other funding.

The GCPA clearly states that the Secretary has the authority to implement changes to

dam operations as well as non-operational measures to accomplish the purposes of the

act.

The basis for this Principle stems from the Grand Canyon Protection Act (GCPA), the

Senate Report Language for the Act (Report Language), the Charter of the Adaptive

Management Work Group (Charter), and the Glen Canyon Dam Adaptive Management

Program AMWG FACA Committee Guidance document (Guidance) prepared by Scott

Loveless.

Sections 1807, 1805, 1804 (c, B) and 1802 of the GCPA authorize the Secretary to use

CRSP hydropower revenue for research, monitoring, consultation, and other activities

that will ensure Glen Canyon Dam is operated in such a manner "as to protect, mitigate

adverse impacts to, and improve the values for which Grand Canyon National Park and

Glen Canyon National Recreation Area were established, including, but not limited to

natural and cultural resources and visitor use." The nonreimbursable expenditures

allowed under the GCPA included preparation of the EIS and its supporting studies as

well as the other actions mentioned in this paragraph.

According to the Report Language "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 geographic focus of the AMP is also described in

the definition of the Colorado River Ecosystem contained in this Strategic Plan. We

recognize that there may be operational impacts on resources beyond the narrow

geographic area defined above. Examples of activities that may be funded through
nonreimbursable CRSP hydropower revenues and other sources are included in the

Guidance (p. 7).

According to the Guidance "The relevant Senate Report language says, after discussion

of the primary purpose of the Act, that: "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."

The Charter further allows that "AMWG 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." However, the aspect

of nonreimbursable funding applies only to specific expenditures within the authority of

the GCPA.
Issue Paper #4 - Riparian Biotic Community

Issue: This paper is focused on clarifying whether the AMP objectives for riparian biotic

communities should be focused on native biotic communities (e.g., old high-water zone

and sand beach), or on the naturalized biotic community (e.g., new high-water zone,

marshes, tamarisk-dominated).

Response: The Strategic Plan ad hoc group believes that we should set objectives to

attain and maintain viable examples of the native biotic communities, but we should also

maintain examples of the naturalized biotic community, especially where it provides

habitat for southwestern willow flycatcher. The riparian objectives may be attained and

maintained through dam operations and/or other management actions. The sequence of

management actions should be consistent with principle seven.

Rational: Both the native communities and the naturalized community are of value to

the stakeholders. Setting objectives to attain and maintain both native and naturalized

communities is consistent with the emphasis on native biodiversity articulated in our

Vision-Mission statement and Principle six.
Issue Paper #8 - Consistency Between Recovery Plans and MO’s

Issue: Should AMP management objectives for T&E species parallel objectives in

USFWS recovery plans?

Response: AMP management objectives for T&E species need to be consistent with our

Vision-Mission and Goals and the current FWS recovery plans.

Rational: AMP objectives need to be consistent with our Vision-Mission and Goals to

meet Principle 1. AMP objectives may not identical to recovery plan objectives simply

because those objectives descend from different goals.
Issue Paper #10 - Socio – economics

Issue: Should there be a goal for Socio – Economics instead of Goal 11 related only to

hydropower?

Response: Goal 11 will be retained and the related MO’s will be measured in metrics

having other than dollar values. Determination and consideration of socio-economic

values will be included in a MO for Goal 13.

Rationale: Although it is not a natural resource, hydropower generation was

recognized as a resource of concern in developing the GCPA, the EIS, the ROD and the

Guidance Document. Goals need to be developed for all resources of concern including

both hydropower and recreation as well as others that are not considered to be primarily

natural resources.

Socio – economic values are are not a goal. They are a way to measure the value of the

resources of concern and, as suggested by the NRC Downstream report, may provide a

useful tool in presenting data to be used in making decisions. Development of socio –

economic data (including non-use values) for use in decision making has been made a

management objective in Goal 13.
Issue Paper #11 - Principle No. 6

Issue: Does Principle No. 6 appropriately recognize the continuing existence of Glen

Canyon Dam (GCD) as well the possibility for management actions other than changes in

dam operations?

Response: The ad hoc group suggests a more appropriate statement of the principle is

“Management actions, including changes in dam operations, will be tried that attempt to

return ecosystem patterns and processes to their range of natural variability. When this is

not appropriate, or beyond the range of operational flexibility of the dam, experiments

will be conducted to test other approaches.”

Rationale: Principle No. 6 must be read and interpreted within the context of the Vision

statement, the Guidance Document, and in combination with Principles 5 and 7. The

second paragraph of the Vision Statement clearly states the AMP program will be

accomplished through the operation of GCD and other means. The Guidance Document

has several references to continued dam operations; page 2 paragraph 2 refers to the

legislative intent in GCPA, and on page 4 quotes from the ROD on finding “an

alternative dam operating plan.” Given the statements in the underlying documents it is

clear that Principle 6 assumes continued operation of the dam and places that restriction

on the range of natural variability target. The principle should be modified to reflect that

situation and to be more clear that non-operational actions are available to achieve some

goals.