United States Department of the Interior 

U.S. GEOLOGICAL SURVEY

SOUTHWEST BIOLOGICAL SCIENCE CENTER

GRAND CANYON MONITORING AND RESEARCH CENTER

2255 NORTH GEMINI DRIVE, MS-9394 

FLAGSTAFF, ARIZONA 86001

928 556-7094 Telephone

928 556-7092 Fax

June 22, 2007 

TO: Glen Canyon Dam Technical Work Group Members 

FROM: John Hamill, Chief, Grand Canyon Monitoring and Research Center 

SUBJECT: GCMRC Response to Stakeholder Comments on the May 14, 2007, Draft 

 Beach Habitat Building Flow (BHBF) Science Plan 

Thank you for the comments on the subject Science Plan. In total, we received 189 comments from 12 

reviewers. Responses are provided for those comments received by the June 8, 2007, comment deadline 

(Attachment 1). Approximately 65 of the comments were received after the comment deadline 

(Attachment 2). GCMRC will respond in writing to those comments following the TWG meeting. I am 

concerned that only a minority of AMP participants commented on the draft plan and that all the key issues 

may not have been identified. 

Please note that we only responded to the comments that were scientific in nature and within the purview of 

GCMRC to address. Other non-technical comments should be addressed by the TWG, AMWG, and/or the 

Secretary’s Designee, as appropriate. 

Our presentation at the TWG meeting will focus the “major” comments or concerns which were raised by 

stakeholders. Depending on the outcome of these discussions, it may be appropriate to establish an ad hoc 

group to further review GCMRC’s response to all the stakeholder comments, and report back to the TWG 

at its next meeting 

I request that the TWG recommend to the AMWG that the WY08 hydrograph include the option of 

conducting a BHBF subject to (a) the sediment trigger being met, and (b) finalization of BHBF Science 

Plan and acceptance by the Secretary of the Interior. The TWG may also want to consider providing a 

recommendation on the budget implications of implementing a BFBF Science Plan in 2008. 

I regret not being able to respond to all the comments for your review well in advance of the TWG meeting. 

We did our best given the large number of comments and other competing work activities. 

Sincerely, 

JOHN HAMILL 

Chief, GCMRC 

Attachments: 

1. Comments received before June 8, 2007 

2. Comments received after June 8, 2007 
ATTACHMENT 1 

Document Title _Science Plan for Future Experimental Beach/Habitat Building Flows Released from Glen Canyon 

Document Date: _May 14, 2007______ 

COMMENTS RECEIVED AFTER THE JUNE 8 COMMENT DEADLINE 

Comment 

Number 

Page 

Line 

Reviewer 

Name 

Affiliation Reviewer Comments (Be specific) Identify Action Requested Response 

Requested 

1 Gen

eral 

Palmer Western The options considered by AMWG consisted of a "package" of 

actions and experiments. The purpose for packaging several things together was to achieve beneficial results for HBC while protecting or improving other resources. How a BHBF, as a stand-alone activity, fits into a broader experiment isn't known. The development of a draft science plan for a BHBF (s) is useful for its eventual inclusion into an LTEP, but we believe it must remain a draft document until it is incorporated into an LTEP. Western is reluctant to recommend a stand alone action. We must understand how it fits with actions/experiments in a "package" arrangement. 

Y 

2 Gen

eral 

Palmer Western There are several policy issues embedded into the science plan that 

have not been addressed by the AMWG. In this draft of the science plan, the GCMRC has helped to identify these issues (although not specifically identifying them as policy issues). This draft therefore, can serve as the catalyst for an AMWG policy discussion. We believe this discussion should occur as part of completing the 

science plan. We will identify these policy issues specifically below. 

Y 

3 Gen

eral 

Palmer Western There should be criteria to evaluate the success of a BHBF 

experiment. This is needed for the experiment as a whole, for the research questions and for the individual experimental studies. 

Y 

4 Gen

eral 

Palmer Western The “tools” for high flow tests include Habitat Maintenance Flows 

(HMF) and load-following flows. The entire set of “tools” should be available for experimentation purposes to achieve management objectives. 

Y 

5 Gen

eral 

Palmer Western As described in the ’96 GCD EIS and ROD, the purposes for the 

BHBF are related to camping beaches and backwater habitats. We believe that BHBFs may deposit sand where aeolian activity may redeposit this sand at cultural sites. However, this purpose is an effect of a BHBF tested for the primary purposes described above. Western doesn’t believe that the timing, magnitude or duration of a BHBF should be adjusted for its potential effects on cultural resource protection alone. 

Y 

6 Gen Henderson GCNRA Include a TOC to clarify organization 
eral 

7 Gen

eral 

Henderson GCNRA Check references – some are included in text but missing in the 

literature cited section 

8 Gen

eral 

Henderson GCNRA Clarify years – work plans imply that projects are starting in ’07 

(true?). Consider using year 1 and year 2 rather than 2007 and 2008 

9 Gen

eral 

Henderson GCNRA Organization of budget tables sometimes inconsistent 

10 Gen

eral 

Henderson GCNRA Clarify the number of BHBF events being proposed. It is somewhat 

unclear whether GCMRC scientists are suggesting a 10-year test of concept or a one year test to predict whether a 10 year implementation would work 

11 Gen

eral 

Henderson GCNRA The SSQ reference numbers in the work plans are different for the 

same SSQ 

12 Gen

eral 

Henderson GCNRA The following four types of questions are used within the BHBF 

science plan: 

a. AMWG priority questions (page 11) b. Strategic Science Questions (presumably from the 

MRP) 

c. Working hypotheses (in the work plans) d. INs and EINs (in the work plans) 

An explanation is needed as to how each of these groups of questions relates to the work plans proposed 

13 Gen

eral 

Henderson GCNRA The fate of Glen Canyon should be discussed within the context of 

this BHBF work plan, i.e., what do we assume for this reach 

14 

Proposed Experimental 

Study #6 

Palmer Western Sediment has utility to the degree it creates habitat (especially for 

HBC). A significant science question related to this is: does a significant portion of the Grand Canyon HBC population utilize backwater habitats? It’s possible that significant habitat for HBC is talus slopes. Answering this question may take considerable effort. However, if HBC numbers can be increase and/or if this HBC population can be recovered without adding/maintaining sedimentstructured backwater habitats, this will significantly alter the utility of BHBFs as a management action. (When this is added, it would also be added to the summary table: Table 1.2). 

15 2 11 Palmer Western For sediment deposited by a BHBF to protect archaeological 

resources from erosion a “double coincidence” in special relations is required. First, sediment deposition needs to occur at or near an archaeological site. Second, wind patterns need be predominantly from the sediment deposit to the archaeological site. Ex ante, it seems as though this will only occur serendipitously. We would like this document to display or summarize the data related to sediment deposition from previous BHBFs as compared to the location of archaeological sites. 

16 2 5-15 Henderson GCNRA The justification for further BHBF testing should include recreation 
17 3 10 Palmer Western This primary science question should be modified to reflect the “big 

picture” goals. As written, this science question implies that one should explore operational regimes at the GCD until (and if) flows can be found that accomplish the stated goal independent of other 

GCD-affected resources. Even if such a flow were found, what utility would it have if it adversely affected other key resources? The science question should be worded so as to take this reality into account. The research that it prompts should also take this into account. For example: “Is there a “flow-only . . . that maintains key resources as described in the ’96 GCD –EIS?” One might be tempted to respond that this question is for sediment only and therefore stands alone. However, this science question, as written, has already prompted GCMRC scientists and others to promote very restrictive release patterns to find the “flow” that answers this question. We believe that this question – and others pertaining to other resources – would better reflect the needed research if it added this. 

Y 

18 4 19-35 Palmer Western This is a clear description of the “end game” for BHBF 

experimentation. Western believes that this is a policy issue. Specifically: the “repeated BHBF tests under multiple sand enrichment scenarios” for the purpose of “cumulative increases in systemwide sandbar area and volume over decadal time scales” should be considered in a policy venue. 

AMWG 

discussion 

Y 

19 4 25 Palmer Western The strategy of attempting to build sandbars through multiple 

BHBFs in an attempt to achieve “cumulative increases in systemwide sandbar area and volume over decadal time scales” is described as only being “feasible” if the “intervening power plant releases do not completely erode the sand deposited in sandbars” by the BHBF. While the science plan doesn’t specify what degree of fluctuation is incompatible with this “strategy” and infers that this question is a subject of scientific exploration, we cannot ignore past statements and attitudes related to this. Repeatedly, in public presentations and conversations, GCMRC scientist have recommended very restrictive operations in order assure the success of the “strategy” described here. Specifically, in the science workshop held at GCMRC in April, one of the GCMRC sedimentaligists recommended steady flows and another; relatively 

steady, low volume releases in between BHBF tests. Western feels that very restricted fluctuations will be recommended by BHBF planners once a science plan is completed and the details of a specific plan are developed. We feel that significant restrictions on power plant fluctuations are incompatible with the “big picture” goals. To be more compatible with the “big picture” goals, we feel that the science plan specify an experiment in which BHBF tests are combined with fluctuating flows in order to conduct an experiment 

Y 
to see if sediment goals can be accomplished within the context of 

the “big picture” goals. This actually occurs in the project goal for Experimental Study 1.B. (page 21), where the goal is stated as “determination of the optimal BHBF hydrograph shape for a given sand-supply condition to achieve sandbar resource management goals, while minimizing negative impacts to other resources (e.g., hydropower).” To make this change, the key science question and the “strategy” will need to be modified. We provide more detail below. 

20 5 1-24 Henderson GCNRA Research/monitoring on past BHBF tests (specifically 2004) did not 

provide a comprehensive assessment of the size and specific location of channel deposits. This information is important to the NPS since it is the foundation for many resources and activities it manages (camping beaches, vegetation, fish habitat, cultural resources etc.), and should be mentioned 

21 5 21 Palmer Western The first sentence of this bullet is a finding. The second sentence is 

probably not so much a finding as it is a hypothesis. 

Y 

22 5 23 Barger Western Insert the word temporarily between thereby and reducing Y 23 5 26 Palmer Western The new trigger is a characteristic of a policy-related issue. Based 

on the findings of the 2004 BHBF test, as described on page 5, an increase in sandbar total area volume occurred in the upper half of Marble Canyon. This would seem to be a positive finding for this reach. Since this reach was described in the ’96 GCD –EIS as a “critical” reach for beaches, it may be that one or more of the BHBF “goals” was reached. The question remains regarding what the canyon-wide goals, if any, may be. 

AMWG 

discussion/ 

decision 

Y 

24 5 28 Barger Western Clarify what is meant by lesser tributaries. Since they are not 

gauged, please explain how this sediment is gauged. 

Y 

25 5 41 Barger Western I don’t support the statement that repeated experiments might occur 

more frequently. This implies that each time the trigger is met, there could be a BHBF. I see this as making a policy recommendation and this should be removed. 

Y 

26 6 1 Barger Western The title does not reflect the discussion in this section. Y 27 6 17 Barger Western Change this to state, basin hydrology may affect releases. Y 28 7 46-end Palmer Western The word “replication” as used here (and elsewhere in this 

document) is a mischaracterization. The word is accurate when used as a modifier to the phase“2004 hydrograph”, but, the implication when it is used in this document is that GCMRC proposes to “replicate” the 2004 BHBF experiment. The BHBF experiment described herein is significantly different from the 2004 experiment. The main difference is that it is not described as a BHBF immediately following a “trigger” amount of sediment input. It recommends “conditioning flows” that may distribute new sediment inputs more evenly throughout the Grand Canyon. So, the 

Y 
experiment is this: can sediment inputs be retained and distributed 

canyon wide? If so, can a BHBF mobilize sediment canyon-wide and conserve it within the canyon (rather than transport most of it to Lake Mead)? Should new sediment inputs be exported out of the canyon between the time they are deposited and the time a BHBF is conducted, the BHBF experiment would not be implemented in a “locally sediment enriched” condition. 

We suggest that, beyond the description on this page, the document clarify, where relevant, the difference between the 2004 experiment and the one described in this document. 

29 9 Figure 

1.2 

Palmer Western The following should be added to this decision tree: 

 - the first box includes only a sediment trigger. In fact, prior to another BHBF test, Western and Reclamation will need to assure that funds are available to cover electrical contractual obligations – 

a financial trigger. Also, a BHBF will need ESA compliance. We’d like to have that completed so that decision makers know what commitments of resources are required from the action agencies as mitigation and/or conservation measures prior to recommending a BHBF test – an ESA trigger. Perhaps these added triggers can be described as precursors to “following” the decision tree in Figure 1.2. In any event, they will need to be determined and added to the plan. 

 - the lower left-size box should eliminate “changing intervening operations” (if what is meant is further restriction) and should add “increased peak magnitude, timing or hydrograph shape.”  - the second box should be changed to measure the changes in camping beaches and back-water habitats (see our comment below) 

30 10 13 Barger Western Give page references for linked elements. N 31 10 30 – 

36 

Palmer Western Reference is made to the ’95 EIS. The ROD allows a BHBF only 

when a hydrological trigger is reached. This ROD restriction exists in order for BHBFs to be implemented in accord with legal restrictions. BHBFs have twice been tested in the past to test the utility of BHBFs as management actions to be implemented in under the ROD constraints. This restricts the timing of a BHBF to the “forecast” and “run-off” season. In line with our comment #1 (above), the policy issue is how the AMWG would (or would not) recommend a deviation from these criteria for testing purposes. For example, the “Cook-Moody” proposal, passed by the AMWG in 1998, recommended a test of a BHBF with a magnitude of 60 k cfs (when hydrologically triggered). 

AMWG 

Discussion/ 

decision 

Y 

32 10 15 Barger Western I believe that tamarisk is a big issue that does not appear to be 

addressed in this study. Larry had referenced that BHBFs can affect distribution of tamarisk seeds/ thus their proliferation. 

Y 
33 11 8-38 Henderson GCNRA Not all the resources and questions listed are “priority” as specified 

in the MRP. Please clarify the title of Table 1.1 or modify table contents 

34 11 9-40 Henderson GCNRA In some instances the priority questions don’t clearly translate into 

the questions asked or the projects proposed in Part 2. For example, specific questions are asked about the creation of near shore habitat (line 15-16), how BHBF flows affect the persistence of sandbars and backwater habitat (line 13), how a BHBF-changed food base would affect native fish (line 18), and effects on Kanab ambersnail (line 35) with no corresponding study plan recommended in Part 2. Further, I’m not sure that AMWG made some of them high priority. 

We clearly learned from the 2004 test that sediment can be conserved in certain areas, at least temporarily, by a BHBF following a tributary input (of a certain magnitude). We need to continue to test the needed magnitude of the trigger as well as how to better distribute tributary sand once it has been deposited into the Colorado River. But now that we know that sediment can be conserved, we need to know how this conserved sand stored as far as the specific location (along the river corridor as well as elevation) and amount (area/volume). Such information is crucial to managers to understand how effective conserved sand is at providing additional native-fish and vegetation habitat, open beaches available for camping/recreation, and conservation of archeological sites. Consider using remote sensing to accomplish this task 

Y 

35 11 14 Barger Western I did not see any HBC studies identified in this plan. The last 

BHBF flushed out YOY. 

Y 

36 

11 28 Palmer Western 

An Economic and/or financial science question should be added. If the AMWG has none at this time, it would be important for the AMWG to adopt one. 

Y 

37 13 Table 

1.2 

Palmer Western Sediment is an intermediate resource and has utility to the extent it 

accomplishes two things: 1) it maintains and/or increases camping beaches in critical reaches and 2) it maintains and/or increases backwater habitats. It may therefore be less than useful to have a focus on questions related to mass balance. This may or may not be the same as the “sandbar fate” study that is directed at eddy sandbars. If backwater habitats are a subset of eddy sandbars, we suggest evaluating whether a BHBF maintains or increases backwater habitats only. (to be clear, if a BHBF proves to “conserve” sediment inputs, but in locations that do not provide HBC habitat, we would suggest that the BHBF did not achieve the management objectives). This comment is in line with the AMWG science questions on page 11. We suggest that the focus of the 

AMWG 

Discussion/d

ecision 

Y 
gathering of data and the analysis be on the HBC questions. 

38 16 Barger Western I did not see these addressed in this plan. Where are the discussions 

for the KAS and cultural sites. I thought public outreach is done by USBR. 

Y 

39 17 1 Henderson GCNRA A study is needed to determine the specific location and size 

(area/volume) of the sediment that might be conserved by the BHBF test (see 11 above). Such a study would serve as a foundation to determine the amount and location of backwater habitat, recreation beaches, in situ arch site preservation, invasive plant establishment, shifting of movement of major vegetation types etc 

Y 

40 17 9 Barger Western For each study, please clarify the reasoning behind the duration. Y 41 

17 20 - 25 Palmer Western 

Project goals: Sediment is an intermediate resource. The importance of sediment to managers is the “work” that sediment can do. The goals for this project should be to document: 1) the change in campable beach area and 2) the change in HBC habitat 

Y 

42 17 37-39 Palmer Western Same comment as above regarding the strategic science question Y 43 18 11 Barger Western Please define Lagrarian N 44 18 45 Barger Western For each study for the section on INs, please incorporate them into 

the discussion of methods to show how each one will be met. Listing them at the end will not suffice. 

Y 

45 

20 1 Warren Western 

As I understand the task, this is an “off the self:” science plan. The cost table then, should not categorize the costs by specific fiscal year. 

Y 

46 22 24 Henderson GCNRA How will the data collected as part of this study relate to the other 

BHBF deposits along the river corridor? This study will provide us a great deal of information about hydrological process (very interesting to scientists) but little information regarding the results of that process in the entire system (of interest to managers). Consideration should be given to balancing the needs of both groups 

47 25-

30 

Henderson GCNRA I question the amount of funding needed this project since, it seems, 

it could be easily folded into the existing/proposed site archeological site monitoring plan now under development. If sufficient sand is deposited in areas in the needed proximity (orientation/distance) to existing archeological sites, it would seem pretty logical (without study) that additional sand might be deposited. What is crucial is knowing whether the sand is deposited in the key areas. Neither this study nor the others will get at this issue since a comprehensive sand deposit study is not included in the work plan. However, even after you know where the sand is deposited it would seem that understanding whether this newly deposited sand is blown onto the sites could be easily added to the arch site monitoring program (now under development). A simple 

Y 
comparison between those sites affected by newly deposited BHBF 

sand and those not affected would show the effect of the BHBF. Further, by utilizing only select sites to study (as advocated by the author) it does not tell us much about the overall effect of BHBF sand on arch sites throughout the CRE. I would suggest using the funding allocated for the above study for the study recommended in 12 above 

48 25 36 Barger Western A BHBF of up to 45,000 cfs will not fill arroyos on sites since the 

sites are located at higher elevations. This needs to be clarified. 

Y 

49 27 26 Barger Western The discussion of analog cameras at 28 selected sandbars and 

cultural sites is not well reflected in Table 1.C-1. It looks like there might be eight cultural sites. The site numbers need to be included. 

Y 

50 27 29 Barger Western What is meant by “also be surveyed.” Please clarify. Y 51 27 39 Warren Western We understand these instruments have already been deployed. This 

should be updated. 

N 

52 27 40 Barger Western The sites are not listed anywhere, please list them by number/name. Y 53 28 15 Barger Western This was not done for both of these BHBFs. Please rewrite. Y 54 28 21-24 Barger Western This is a description of sandbars, not archaeological sites. 

Restoration of sandbars does not equal restoration of archaeological sites. Please rewrite this section. 

Y 

55 30 22 Barger Western This comment applies to costs listed for each study. Please clarify 

what is meant by some of the titles in Funding History. For example, explain training needs, and why GCMRC salaries are not always included. If you do not include the salaries the real cost of the BHBF is under represented. 

Y 

56 31 Henderson GCNRA It seems logical that open patches of ground would be more 

susceptible to pioneering plant establishment (invasive species being of most concern). Invasive establishment would be quite variable and dependant on further disturbance (elevation of the river) and seed availability. Knowing this, is this study intended to reaffirm this basic concept or quantify the amount of invasion within the entire corridor? It would seem that the first question to ask is how much (and where) additional bare sand (in ideal establishment zones) would be made available by the BHBF test for invasive establishment 

Y 

57 32 21 Barger Western Please be consistent in your use of cfs. N 58 38 Figure 

3.1 

Warren Western - do the curves depend on the distance from the GCD? 

- please indicate some sense of the time scale on the X axis 

N 

59 41 Henderson GCNRA Given the priority question posed on page 11 related to backwater 

habitat, a study is needed to specify where and how much of this habitat is created by the proposed BHBF testing. We already know that BHBFs can create backwater habitat it is now necessary to understand if there is sufficient amount created in the right locations to significantly affect HBC recruitment (of interest to mangers 

Y 
60 45 Hendrson GCNRA Given that CPUE is a pretty coarse estimator of relative abundance 

of fish (rather than a population estimate), it would take a major change in population level to show up in a significant difference in CPUE and, therefore, many fish could be lost from the population (and move downstream) without being measured (of great interest to mangers). 

Y 

61 49 42 Warren Western Replace “influences powerplant releases” with “water quality below 

the dam” 

N 

62 50 Warren Western There are no strategic science questions or RINs associated with 

this experimental study. 

Y 

63 52 11 Warren Western Similar to our ESA comment above, what is required of the NPS for 

permitting purposes should be worked out in advance so that decision makers know what the requirements are. In addition, logistical limitations need to be known in advance so that decision makers know if significant science activities will be suspended or lost as a result of the BHBF test. 

Y 

64 67 Henderson GCNRA Given the recommendations by the science advisors and the 

questions by the AMWG, I would advocate adding a project to more fully understand how young HBC are affected by the BHBF high flows in the mainstem. 

Y 

65 76 18 Henderson GCNRA Change C.1 to B.1 
ATTACHMENT 2 

Document Title _Science Plan for Future Experimental Beach/Habitat Building Flows Released from Glen Canyon Dam 

Document Date: _May 14, 2007______ 

Comment 

Number 

Page 

Line 

Reviewer 

Name 

Affiliation Reviewer Comments (Be specific) Identify Action Requested Response 

Requested 

1 Gen

eral 

Kubly BOR We would appreciate it if GCMRC would consider setting up the 

document to better facilitate environmental compliance that will have to be done if the proposed action(s) is evaluated or implemented. For example, there are two durations of releases identified. The recommendation for 60 hrs seems equivocal, based largely on learning, and much less on differential effects on resources. The magnitude being considered seriously is only in the range of 41-45,000 cfs. Only a passing mention is given to higher releases “when Lake Powell storage is high...” What is the likelihood that this condition will occur in the timeframe this plan is expected to cover? Should it be given more attention? Higher experimental releases could be considered, although they would require a full reservoir and use of the spillways to conduct. Did GCMRC consider and reject higher releases, or were they not considered. Also, the sediment trigger does not consider other combinations of Paria and LCR inputs than are in the trigger. Was there consideration given to an experimental flow caused by a larger Paria input, say 1 mmt, with a smaller input from the LCR? Greater detail on what was considered and why other alternatives were rejected would improve the document. 

Format, Consider Expansion of Actions 

Y A 60-hour, 

at length duresult, it wanext BHBF are not feasto low resermaintenancsediment trimetric tons input from tPlease refer hour vs. 60-Please note AMWG and science plan although we provided hecompliance 

2 1 9 Werner AZ The stated purpose of the document is to identify monitoring and 

research activities to be conducted in the event of approval of a BHBF. Work needed for the physical sciences may link to the event more clearly than some of the biological work, such as for fish, which may require that certain efforts were ongoing to know baseline conditions and that other efforts will continue long enough to monitor effects. Integration of BHBF work into the Long Term Experimental Plan will be important. It is not clear that the biological work identified in this document would logically be conducted each time this plan was used as an “off the shelf” research and monitoring plan for a BHBF. 

Consider Y 

This proposthe next BHresulting adto determinneeded duri

3 1 12-14 James CREDA This sentence is not completely correct from a legal standpoint – 

suggest consistency with approved AMP documents 

Substitute description from GCDAMP.G

Y Paragraph s

part of that impacts to tfrom the on
OV fact sheet 

on home page www.gcdamp.gov

paragraph 2, description of Adaptive Management Program 

Dam. To adDam Adaptestablished research and resources. Tunder the Aas the basis operations aHowever, aThank you f

4 2 7 Werner AZ The statement “In transferring sand to shorelines, BHBFs are 

known to form nearshore habitats, such as backwaters that structure the aquatic environment.” should be supported by citations. This statement doesn’t clearly track with one on p. 76 ln. 8. 

Include citations to document what is “known”. 

Y The citation 

be added to provides an the pre- and features typsand in the rthe specific fishes has n

5 2 8 Persons AGFD “such as backwaters that structure the aquatic environment” seems 

like a stretch. Don’t the rapids, riffles and pools structure the aquatic environment? Perhaps say “such as backwaters that may serve as nursery areas for fish”. 

Reword Y Yes, it is tru

ecosystem icanyon featdeposits. Hstructure for ones, such a

6 2 9 Werner AZ Paper cited not in the main lit cited but on p 75 in App. A check N Citation has 7 2 9 Davis CREDA The Minckley and Meffe reference is missing from the References 

Cited. Also, this reference refers to small streams (Aravaipa Cr.) wherein flows of 2 orders of magnitude influenced native/non native diversity. The effect of large river high flows on diversity has not been fully fleshed out so citing this example as a way to justify higher flows is very premature. 

The reference appears on pg. 75 but not in the earlier section at pg. 60 but should be. 

Y Citation has 

This article higher flowhypothesis tmay disadvadapted to tnonnative fismall river disadvantag

8 2 9 Knowles FWS Why not cite Korman et al. 2005? My interpretation of Minkley 

and Meffe 1987 and Meffe 1984 is that a flood of historical magnitudes (100 K cfs) would be needed to achieve similar effects in Grand Canyon, and any negative effects to nonnative trout from a ~ 45 Kcfs flood would be offset by compensatory survival (both points GCMRC also makes later in the document). 

FYI N Thank you f

consider. Plcomment (7

9 2 9 Persons AGFD Minckley and Meffe 1987 is not in lit cited. Citation has 9b 2 11 Kubly BOR There are published studies and agency reports that document Incorporate N Accepted. 
predation by non-native fish on native fish in Grand Canyon (and 

other rivers). Use of “thought to” is too equivocal for this relationship. 

literature citations 

10 2* 11-13 Dongoske CREDA The process of aeolian sand transport as a mechanism for 

preserving archaeological sites is at best still a hypothesis – it has 

not been scientifically demonstrated. One preliminary study (Draut et al. 2005) was inconclusive that this is a preservation process operant in the Canyon. Additionally, there is no convincing scientific evidence that links the results of a BHBF with the proposed process of aeolian sand transport to archaeological sites. As a “science” organization, GCMRC should stop promoting speculative evidence as scientific fact. 

Modify sentence to read that aeolian sand MAY be transported to archaeological sites, but that there is no conclusive scientific evidence to suggest that it acts as a preservation mechanism. This is still a hypothesis that is being tested. 

Y The origina

work of Drademonstrateincrease whupwind of a2004 BHBFarea and voprior to the also found tcontribute tarchaeologinot approprpredominanbars did not regime that enough to sothers (2005observationthat numerowith sand othese same fluvial or coclaimed thaevery archaaeolian deparchaeologiempirical evaeolian procsand on archoffset the ondeposits due runoff (See detail.) Cleabout how ato archaeoloproposal to studying eff

11 2 12 Berry BOR There has been a continuing reference in TWG/AMWG meetings 

to the beneficial effects of BHBF on archaeological resources. This is an untested hypothesis and should be treated as such. The artificial deposition of sand on intact or eroded deposits may, in fact have a deleterious effect on stratigraphic interpretation. 

Rewrite to consider alternative/deleterious effects 

Y Archaeolog

of GCPA, thPark, mechaus achieve televation sa
rates of eros

as being potalso are fulldouble-edgesites as well 1992, pp. 19experimentaeffects of BThis is why aeolian trancultural siteframed in tepp. 26-27 foaeolian procIf we can doand factors retention at general, and we can then which these throughout which they preservation though, the potential of serve as souhigher elevaeffects of neterms of chasample of aprocesses in helped to prWith regard also agree in archaeologiformation, tthe archaeoimplication by aeolian sthan one thaerode unimpdisagree. Fnothing “artarchaeologi
documented 

and by Draucover derivecommon feathe CRE. It for reworkinmodern dam 

12 2* 12 Davis CREDA The expectation that aeolian transport of sand may hold promise 

for protecting arch. sites from weathering and erosion is premature at best. You could as easily say such transport holds little promise for protection. 

Review language to be sure statements are supported by facts. 

Y See respons

sentence in deposits thasources of sareas upslopresources frsentence doonly that satransported documented and Rubin, protect archarchaeologiaeolian sand Draut and Rsand does bcultural depcover “mayweathering, appears to h

13 2 20 Werner AZ A paragraph on purpose for Appendix B would parallel the 

explanation of Appendix A. At present the linkage of Appendix B to the document is not clear. 

Consider adding a paragraph. 

N Thank you f

sentence wicontent and 

14 3 2 Persons AGFD appendix A = Appendix A Simple fix N Noted. 15 3* 5 James CREDA Page 1, line 19 uses “conserve”. Replace 

“restore and maintain” with “conserve” 

Y We have no

all instances or “conserv

16 3* 5 Davis CREDA Restoration of sandbars to meet levels seen after the extreme 

flooding of the early 1980’s is a questionable goal. 

A conservation goal needs to be quantified so we know what level to attempt to achieve. 

Y There is no 

meet levels early 1980’
17 3* 15 Davis CREDA I recall Jack Schmidt stating that maintenance of sand bars was 

unlikely using flow scenarios but that we may be only able to slow 

the rate of sand loss. 

Y The availab

only” may rdate, testing insufficient 

18 3* 15-24 James CREDA Scientists have “concluded”...”that is the only potential 

option”...yet, what else is needed to “fully” evaluate the approach? What constitutes completion, if “concluded” doesn’t? 

Y See above c

Scientists hrequired to of sandbars 

19 3 18 Kubly BOR Since the proposed trigger for BHBFs is a combination of inputs 

from the Paria and LCR, do we presume these are the referenced “tributaries” in this sentence? If so, suggest clarification. 

Clarify N Yes, the Par

tributaries. 

20 3* 33 Davis CREDA The results MAY have implications for native fish survival..... Please restate 

based on current state of knowledge rather than speculation. 

Y Accepted 

21 3* 33 Dongoske CREDA Is the term “cultural resource” here being used as a synonym for 

archaeological sites? Up to this point the argument has been made that BHBFs will benefit archaeological site preservation, not cultural resource preservation. Cultural resource is a broad category of which archaeological sites are a small subset. Please do not conflate the two. 

Revise to read archaeological sites in all places where the term “cultural resource” is used 

No. The terencompassenative riparimportance understand resources as archaeologivalued resouNational Reand archaeocultural reso

22 3 38 Knowles FWS This is mostly a discussion of 2004 flood effects to bar size and 

arch resources. GCMRC had committed to also providing information on displacement of juvenile humpback chub and effects to physical habitat conditions for humpback chub. Some of this information is included later in the document, and we understand that some is forthcoming; we suggest you summarize this information here. 

Edit Y 

Turbidity adspate limitebefore and astate this in 

23 3 39 Werner AZ A citation to a document should be included for DOI approval of 

triggering thresholds. 

Include a citation to a document 

Y The only do

sediment trithe SPG doc2006 on ExOptions A,Athreshold hatime. 

24 4 9-12 Davis CREDA The net transfer of sand into or out of eddies appear to be opposite 

results. Did the 2004 experiment yield desired results in Marble 

The conclusion 

Y The sand bu

through the 
but then undesirable results in Grand? Does this mean the strategy 

may be good for preserving sediment in Marble but not for Grand? 

should be put in terms of the net effect for the different reaches (e.g., sand bar total area increased in Marble but decreased in Grand 

positive throThis occurrsandbars in greater than downstream Canyons. Toccurred freformed sandintervening response of could propagains in sanCRE. Scienresults.” 

25 4 16 Persons AGFD Do you have any idea how much more sand than 800,000 to 

1,000,000 metric tons will be required to achieve increases in total 

eddy-sandbar area and volume throughout all of Marble and Grand Canyons? Can you model how many metric tons are needed? 

Clarify “more sand” if possible 

All we know than is typicby the Paria achieve “moof tributary plant releascompletely BHBF test, result in incand volume Canyons. 

26 4 39-44 Dongoske CREDA Here the document conflates archaeological sites with cultural 

resources –see comment above. The 2004 study demonstrated an increase in nearshore sand available for wind transport – suggest that it did not demonstrate that the alleged process is ubiquitously operant within the Canyon in preserving archaeological sites. Nor has it demonstrated that the distance and directional relationship between nearshore available sand and an archaeological site is one that is consistently active in preserving a site. It is counterintuitive logic to suggest that wind deposited sand on an archaeological site will act to preserve that site because there wouldn’t be sufficient compaction of the sand to resist subsequent wind and precipitation forces. 

Change “cultural resources” to archaeological sites. Also, these two sentences need to be changed to reflect that just because nearshore areas of available sand increase as a result of a BHBF it does not mean that all these nearshore 

This commefollowing seresources, eothers, 1996many prehisCanyon are flood depossand derivehas helped tfollowing thhigh flows rconditions careas for withe rate of slocations in resources (Dsand transpoand deflated potentially rthe preserva
areas will be 

productive sources of sand for wind transport to archaeological sites. These two sentences are very misleading and need to be revised. 

see responsunderstand can be consDongoske cRubin (2006nearshore salocally after say our studclaimed to dubiquitous tarchaeologiwindblown BHBF testsdeposits of type and anwould have fluvial sour2007). (See deposits in tRegarding tintuitive logon an archasite because compaction and precipiintuitive, buhas higher isoils and heprecipitationoff erosion Supporting included in (2003, p. 76of various tynoted that “non-eolian sof eolian sehigher that t= 0.006 cm/runoff eoliaamount it abUltimately, 
sedimentary 

between eroany given sisand (in otherosion morof loose sanprotection thcontinues to loss due to werosion takeamount of dmechanismover erosive preserved. Isediment exdue to rainfsediment-derather than dwill not be p

27 4* 41 Davis CREDA This is a potential result but the text states it as fact that windborne 

sand will lead to increases in sand. 

Please restate the line based on facts not speculation. 

Y See respons

work of Drafold increasunder similawhere a sanappropriatelarchaeologinew bar waadditional sduring the sis a fact, noBHBFs will other locatiodetermined BHBF scien

28 4 42 Berry BOR It is precisely the backfilling of gullies and deflated areas (should 

this eventually be demonstrated to occur) that has the potential to confuse stratigraphic interpretation. Gullying results in a “lag gravel” effect of artifacts; the mixing of artifacts, ecofacts and radiocarbon samples from different temporal horizons in multicomponent sites. Covering such a palimpsest with sand leads to the false impression that these objects were, in fact, contemporaneous. 

Rewrite to consider alternative/deleterious effects 

Y As the autho

gullying and can mix artistratigraphic Stopping or blanketing tmore likely stratigraphy surface erosRegardless, site formati
have been li

aeolian procthe post-dam geomorphicGrand Canycognizant oand post-desurface eroswell-trained should be abbetween aeosurface from situ archaeodeposition ogoing to serthat has alresurface erospreserve the 

29 5 3 Davis CREDA Since the results of Paria sediment input followed by a BHBF are 

markedly different between the upper Marble reach & the rest of the CRE, we need a much better assessment of the potential trade offs so we know what will be gained or lost by doing a BHBF. 

A best guess assessment of the trade offs between each reach so we will know what is gained or loss by a BHBF 

Y This comme

to comment

30 5 8 Davis CREDA Why is it important to continue this scenario rather than the 

reverse? More resources and those of legal import are below Marble so why are we doing so much to help this area if by doing so it harms resources downstream? There is only vague reference to native fish survival, cultural resource protection and habitat enhancement yet no reference to sand protection to provide beaches for recreational boating. 

Justification for sand preservation in Marble is missing. If the prime reason for sand protection & enhancement is beaches for boaters, then state it so we can make decisions for BHBFs based on real reasons. 

Y Current info

may have omile 30, so protected haand backwaeven in the conserved, etime, it may building at worth testinbeaches for benefit if supurpose. 

Managers hnot a prioritobjectives oor not a mor
response is 

time to redibefore the Bscience planresources arecosystem. 

31 5* 19-24 Dongoske CREDA fourth bulleted item: the second part of this bullet is sheer 

conjecture and should not be advanced as a result of the 2004 BHBF. Assumptions should not be advanced before they have been put to rigorous scientific testing. 

Second sentence in this bulleted item should end after archaeological material. Delete the last part of this sentence. 

Y Following t

(2006) founapproximateremained at spring 2005the river wespring 2004transport waadditional salso Draut ato indicate tincrease win“some locatAt the same that sand blBHBF depothat had begarchaeologiRubin, 2006sentence in “Sediment-rtransport of Canyon thacan thereby been hypothincrease the 

32 5 21 Berry BOR It is precisely the backfilling of gullies and deflated areas (should 

this eventually be demonstrated to occur) that has the potential to confuse stratigraphic interpretation. Gullying results in a “lag gravel” effect of artifacts; the mixing of artifacts, ecofacts and radiocarbon samples from different temporal horizons in multicomponent sites. Covering such a palimpsest with sand leads to the false impression that these objects were, in fact, contemporaneous. 

Rewrite to consider alternative/deleterious effects 

Y See respons

33 5* 23 Davis CREDA The implications that gully erosion can be stalled by dam 

operations depositing sand in arroyos is speculative and unproven. Even if later found to be true, it may remain superfluous to the array of measures available and effective (and cost effective) in 

The section should be written as supported by 

Y We know fr

experimentagradient havgully incisio
preserving these sites. facts rather 

than speculation. 

infilling alreof erosion aof the effectwould not beither direct Draut and R2004 BHBF2004 flood small gully field, which from cutting the river. In deposit the operations (later (over tgully by winDraut and Rintended to affect gullieone of the gscience plan

34 5 23 Kubly BOR Is it known or hypothesized that gully erosion is reduced? The 

sentence seems to imply the former, but my understanding is that this is one of the hypotheses to be tested. 

Clarify Y The answer 

evidence (se

data is needevaluate the elevation sahence this ithrough futu

35 5 27 Kubly BOR Is there a document that contains the evaluation that led to the 

revision of sediment input trigger? If so, it should be referenced. 

Clarify N The revised 

process and Experimentto this docuhere. The othe 2002 EA 

36 5 28-38 Persons AGFD Under revised triggering criteria, is the likelihood of mining sand 

from the upper Marble Canyon (Paria) reach following a large LCR input advisable? 

Assuming sandbars and backwaters formed by eddy return current channels are desirable for humpback chub (HBC), would it be good to leave some of the sand (and backwaters) in the mainstem just downstream of the LCR following high LCR sand input rather than running a BHBF to park the sand above the daily fluctuation zone? Is this a trade-off analysis that managers need to do? 

Y We can reas

moved abovsome is also until displacsome backwmay be of vtesting with resolve somthe reviewebeen establi
Where do we want the sand, and when? 

Even though occurred in sandbars did downstream and Salt Miassociated wUnfortunaterapidly with fluctuations 

37 5 34 Davis CREDA The rationale for discounting the LCR sand input is missing 

when, simultaneously, the claim is made that sand is vital to humpback mainstem habitats which are mostly downstream of the LCR. 

Rationale for lower value for LCR sand input and higher value for Paria input when most chub habitat is downstream of LCR. 

Y The trigger 

Because the nonzero (anand the LCR of sand suppthe Paria) is from Marbldownstream to be deposi

38 6 

Seasonal 

Timing 

Section 

Kubly BOR This section purports to address biology and cultural resource 

considerations, but it is almost solely concerned with fine sediment. 

Expand Y This section 

the original editing so thdiscussed. Mto Appendix 

39 6 1 Knowles FWS The title of this section doesn’t match the discussion content, 

which is focused on a rationale for timing, magnitude and duration of the BHBF based entirely on sediment and hydrologic limitations. We would like to see a discussion of timing of a BHBF in the context of the environmental biology of humpback chub (e.g. when is the best time relative to effects on spawning migration, larval/juvenile dispersal, food base, and are there any reasons why a 60 vs 45 k cfs flood or a 30 vs 60 hour duration flood would be more or less beneficial to humpback chub? 

Edit Y This section 

the original editing so thdiscussed. Mto Appendix 

40 6 2 Davis CREDA Optimal timing description only applies to the upper 1⁄2 of Marble 

yet the plan uses chub, cultural and other resources as its reasons for BHBFs. 

Spilling & bypassing hydro to preserve sand in the upper 1⁄2 of Marble has not been adequately justified 

Y This section 

the original editing so thdiscussed. Mto Appendix 
41 7 18 James CREDA Does this sentence imply that the only benefit of a 30-hour test is 

to “advance learning”? Experimentation should not be undertaken unless there is an anticipated improvement to resources, with a secondary benefit of “advancing learning”. 

Y No, the 30-h

minimum pcollection to responses.

42 7 32-36 Davis CREDA This sentence is not clear. Reword 

sentence to better incorporate the message from sentence 4 of the previous para. 

The sentencfrom the pre

43 7 37-39 James CREDA What is meant specifically by “normal dam operations” and “some 

period”? Please provide the citation tied to “sediment scientists now suggest”. 

Y “Normal” d

the 1996 RO

44 7 41 Davis CREDA The reason the eddy sandbars are critical in this reach and should 

be sustained (possibly at the sacrifice of those further downstream) is not given. If sandbars are all deemed “critical” then the BHBF 

should not be designed primarily to help the upper 1⁄2 of Marble. 

Justification for using the term “critical” to describe sand bars in the upper 1⁄2 of Marble should be provided. 

Y 

Recent captappear to hamile suggestake advantbars and bacAdditional Bsandbar size just upper M

45 7 42-46 Davis CREDA Quantification of what is optimal sandbar volume has not been 

done and we are left with the notion that simply ‘more is better.’ Conservation to some previous level is listed as a goal without definition. 

A BHBF designed merely to produce more volume for sandbars in the upper 1⁄2 of Marble and why simultaneous effort for sand bars in the lower canyon is of lesser value should be better justified. 

Y 

Policy queswould help because GCrelation to a currently haThis is true the scientistBHBF testsmanagemenobjectives f

46 9 1 Persons AGFD “Are gains in eddy-sandbar area and volume meeting management 

objectives?” Without a way to answer this question, should we 

Y We agree th

resource ma
conduct BHBFs until the managers can better define management 

questions? 

will assist sresponses in 

47 9 5 James CREDA See comment 2 above Y We have no

all instances or “conserv

48 9 Fig 

1.2 

Kubly BOR GCMRC should give similar consideration to biological resource 

or habitat outcomes in setting up this decision tree. 

Expand Y The reviewe

because of twith trackinthe proposechallenges rundefined g

49 10 10-13 Dongoske CREDA The only sociocultural element and objective related to the BHBF 

research is aeolian transport of sand to archaeological sites? What about other sociological and cultural issues that may be impacted negatively or positively by a BHBF? There appears to be a given assumption that all effects of a BHBF to sociocultural elements and objectives are beneficial. 

Evaluation of some of the negative aspects of the BHBF to other sociocultural resources should be provided and is necessary in performing any trade-off analysis. 

Due to finanpotential imfocus of futfocused on only” option throughout understandisediment mother CRE rhabitats, sannative riparThe potentiwill be conscompliance it was deterNPS, in conAdvisory CBHBFs up teffect, no adNational Rethe CRE (Lsee also Larassumption sites will be warranted a

50 10 21 Kubly BOR “Previous studies” should be cited. The integration of this work 

with existing funded food base research should be made more clear. How will the additional funding help to augment what is already being accomplished? 

Add citations Y Current foo

plan) is inadthat are laid biomass and will likely bBHBF. Onrecovery of abundance f
occur in the 

The proposefrequent (1, following Bregular food base sampliallow us to lower trophorder to accinvertebrate BHBF, our comprehensnovel indicarates (rna:dnwe hypothecommunity support highultimately f

51 10 26 Knowles FWS We understand that GCMRC is preparing a report on the effects of 

BHBFS on fish habitat which will include recommendations for future research. We suggest that GCMRC consider incorporating additional monitoring to evaluate this to answer the question of how habitats are changed in the near term and long term (e.g. are nearshore habitats available to shelter humpback chub during the BHBF? how are nearshore habitats changed during and immediately after the BHBF? How are these habitats changed over time in months/years following a BHBF? What are the changes in the fish communities of these habitats over short and long time intervals? What are the differences in these communities in low water years with and without a BHBF?). 

Edit Y GCMRC ha

biological sWhile there interpretatiohave to be cbackwater sthese habitaproductive wsummer/earto the timinan additionaMay/early Jproject proplines. 

52 10 26 Kubly BOR Coupling sampling of native fish and backwaters that occurs 8-9 

months after the BHBF is a real stretch in assigning any cause and effect relationship. Research on nearshore habitats and the effects of BHBFs needs to be more tightly coupled in time. We know very little about the temporal and spatial dynamics of these habitats or the communities that utilize them. Questions directed at these relationships should be paramount for the integration of physical and biological sciences, as is indicated by numerous differences of opinion among stakeholders and between managers and scientists. Yet, GCMRC proposes to relegate them to the back burner and cover them under existing monitoring. This level of investigation is insufficient. 

Incorporate contemporary studies of the effects of the BHBF on nearshore native fish habitats. Begin to study seriously the temporal and spatial 

Y Please see r
changes that 

occur in these habitats and the communities that occupy them. 

53 10 28 Persons AGFD Revise, Yes response is desired. 

I would argue that backwater sampling data does not provide useful abundance data about fish using these habitats. It is useful 

presence/absence data, but the catch-per-unit-effort data is probably of little value in tracking status and/or trends. 

Backwaters can be very ephemeral and short lived. Their appearance and detection is highly dependent on river stage and daily and weekly to monthly fluctuation patterns. During the daily peak flow many backwaters are under water and are eddies, while during the daily low flow when more sand is exposed, backwaters are more abundant. Thus, as seen from a moving boat, if the trip is traveling on the low flow of the day, they will encounter more backwaters than if traveling on the high flow for the day. Also, a trip immediately after the shift in monthly volumes from August (high flows) to September (low flows) would see many more backwaters than during an August trip when daily flows are relatively high. I wish I better understood their importance to native fishes. It is possible that they are the worst possible place for native fish, but because we are able to sample them effectively with seines we catch fish. We need to be careful about making the assumption that because native fish are collected in backwaters those habitats are important to the life history of the species. I’m not sure how to best address this larger backwater question, but think we need to do so before we go down the path that backwaters will save native fish. The backwater issue keeps showing up in these plans, and I’m almost afraid to question it because some stakeholders seem to hold them sacred, but I think we should be very careful about assuming they are important to native fish. A project synthesizing backwater data and making recommendations for future research or monitoring might be in order, especially in designing a long term experimental plan. With that said, September seining trips are important for 

presence/absence data, and also may provide the opportunity to 

Y Please see r
collect more genetic samples from what appears to be a 

reproducing aggregation of fish between 30-mile and the LCR. 

54 10 29 Persons AGFD Is there a report detailing the backwater work? Who is the PI for 

this work? 

Info. Y GCMRC is 

Contractor Srecent years available. 

55 10 36 Kubly BOR When did the effect of high flows on gravel transport in the Lees 

Ferry reach become a high priority research question? I do not recall such discussions at the TWG. 

Provide justification for placing this research above that on native fish. 

Y Additional w

needs to be reviewer’s ca claim of prather, it takopportunitietest, which transport qu

56 11 3 Kubly BOR Provide more evidence that “current technologies and methods 

were found to be inadequate.” Is there a report that documents this investigation? Perhaps GCMRC needs to let an RFP to determine whether there are other investigators who know of different technologies and methods? 

Cite reports or document efforts 

Y Tracking th

fishes in colwe believe twith such efcatch rates bevent are this pursuing habitat occudisplacemenimprove our such eventsyield novel (assuming fidentified). 

57 11 8 Davis CREDA Are there to be priorities to answering these questions and would 

those same priorities weight implementation of management actions? Why does this plan not address all of these priority questions? For example, scientists continue to speculate on the advantages BHBFs will have for nearshore habitats for young chub but none of the proposed studies suggests addressing this question. Another is the effect of BHBF on native fish survival touted on pg. 3 as a high priority issue yet missing from the table of questions to be addressed. 

The text should explain how all the listed questions in Table 1.1 are to be answered. At present, we are left to guess why some of these priority questions are not addressed. 

Y Please see r
58 11 8 Kubly BOR All these questions are AMWG priorities? Identify 

where and when AMWG identified this set of questions as high priority. I recognize some, but not all. 

Y Table 1.1 ne

scientific quwith a high 

The title of 

59 11 8, 28 James CREDA Table 1.1 lists SOME of the science questions identified by the 

AMWG. Please provide the document/action that determined which are priority—or alternatively, remove “priority” inference. 

See respons

The caption 

60 11 15 Knowles FWS The question “Do BHBFs result in creation of nearshore habitats 

(i.e. backwaters) that can offer physical benefits to humpback chub and other native fishes?” does not appear to be answered by the plan. We would argue that they do (see AGFD 1996 and Goeking et al. 2004) and that this plan should further study this phenomenon. 

Edit Y Agree. Plea

61 11 26 Persons AGFD “Scientific Questions identified as a priority by the AMWG: 

RAINBOW TROUT. Are individual rainbow trout displaced from the Lees Ferry reach as a result of a BHBF? If so, do displaced rainbow trout return to the reach, or do they establish residence elsewhere?” 

Is this a high priority AMP question? Can you refer me to a document that identifies the high priority AMWG questions that this references? Is this the right question, and if so, is it the best way to try and answer the question? 

Justify need for project. 

Y We believe 

valuable inf

RIN 4.2.1. Wrainbow troRIN 4.2.2. Wdetect emigFerry reachRIN 4.2.3. Hfrom the LeRiver affecttemperaturePerhaps somprioritizatiobe up to TWBHBF plan it is only thoin conjunctithere are maover whethereach are frobeen cited aBHBF. This potentially udoes not reqTWG determ
the fate of R

withdraw thquestion is o

62 11 Table 

1.1 

Berry BOR How are the “scientific” questions regarding archaeological sites 

articulated with the ongoing treatment plan program for 151 sites in the Colorado River corridor? In particular, which sites will be singled out for monitoring before and after BHBFs. Are these sites already targeted for excavation or other mitigative measures in the treatment plan? 

Rewrite to consider interaction with treatment plan activities 

Y 

Not sure whtreatment pldecisions hawill be treatbetween the plan is not ydocument, sprovided; bubasis. The lBHBF expeinclude any excavation Some of the effects may erosion coneffects at ththis treatmeboth the proaffording us effectivenesand without 

63 12 5-14 James CREDA What is the magnitude of “additional funding” required associated 

with “additional onsite contractors” and the addition of “technical staff”? Are those additional costs included in the program studies detailed in table 1.2? 

Y The costs as

projected to is why there BHBF plan AMP budge

64 13-

14 

Table 1.2: C.2 & C.3 

Dongoske CREDA Prior to studying the potential beneficial effects of aeolian sand 

transport in preserving archaeological sites, why not ask the question: what percentage of archaeological sites located within the CRE are in the appropriate distance and prevailing wind directional relationship with nearshore available sand to benefit from such a study? The plan as drafted is putting the cart before the horse. Even if it can be demonstrated that this hypothesized process is beneficial in preserving archaeological sites, there may not be enough archaeological sites that could benefit from it to make the effort and cost associated with substantiating this process worthwhile. 

Please identify by site number which archaeological sites are in the appropriate distance and prevailing wind directional relationship to benefit from an increase in 

Y The questio

one. Of the detail by Drnecessarily all sites whethird or morassociated wcorrect wind such that it the aeolian sediment-ricB:14:095, avegetation oremoved.) have identif
nearshore 

available sand and the subsequent aeolian transport of that sand. Also evaluate whether the cost associated with scientifically substantiating this preservation process is an efficient and effective use of funds. 

be similarly wind directifrom BHBFWe are not other sites mtransport foexamined aaeolian tranassessment conjunction project) nor directions aknow that thuniform thrpercentage river corridoto a BHBF more involvcould be cowilling to su

65 13 Table 

1.2 

Berry BOR $618,000 to monitor whether or not gully infilling occurs!!? This 

could easily be determined as an aspect of the extant monitoring program or in conjunction with the treatment plan for much less money. 

Provide better integration with understanding native fish habitat changes from BHBFs 

Y The $618,00

BHBF on aljust gullies sand bars crinfilling is ointerdiscipliProject 1.C focused on volume and BHBF throuof Project the amount and how theat a sub-set This project study of aeoarchaeologi

66 14 NA Knowles FWS We are disappointed that there appear to be no efforts to integrate 

sediment research with fisheries research. There is evidence that the 30-mile and RM-65 mile backwaters grew in response to flood events (Goeking et al. 2004). We believe these to be important habitats for juvenile humpback chub, and anecdotal evidence indicates that juvenile humpback chub utilized the 30-mile backwater following the 2004 experiment (R. Van Haverbeke, FWS, pers. comm., 2006), which may have contributed to their 

Edit Y Please see r
overwinter survival (M. Andersen, GCMRC, in litt. 2007). We 

understand that a report of the 2004 effects is forthcoming, but why isn’t there a more direct effort to assess these effects than relying upon existing monitoring? Again, we would like to see an effort to evaluate the effects of the experiment on these habitats over the short- and long-term. 

67 14 Fish Kubly BOR GCMRC’s proposed studies are directed at second-level priorities 

in addressing rainbow trout questions, rather than concentrating on effects of BHBFs on native fish and native fish habitats. It appears the proposed studies are borne more of convenience of access and logistics than of priority considerations. Also, the portion of the budget for fish and food production pales in comparison with other project areas. 

Provide better justification for why contemporary native fish and fish habitat studies are not being proposed. Seriously consider allocation of budget and review past biological opinions to determine likely research requests from FWS to satisfy biological opinion. 

Y Please see r

developed plogistics, thconsidered. projects whmeaningful additional bmeet these c

68 15 Davis CREDA The OTHER STUDIES section should state the Native/nonnative 

diversity project relates to riparian vegetation. 

Change wording. 

Y Accepted 

68b 15 native/

non 

Werner AZ A “recruitment box” model1 may be applicable. Timing of flows 

and available soil moisture may be as or more important than nutrients in native/non-native comp. See also discussion in Stromberg recent paper2

Review hypothesis/explain why the stated hypothesis is the correct one to test in this 

Y Very constr

suggested citeration. 

1 Mahoney J.M. & Rood S.B. (1998) Streamflow requirements for cottonwood seedling recruitment- an integrative model. Wetlands, 18 634-62 Stromberg J.C., Beauchamp V.B., Dixon M.D., Lite S.J., and Paradzick C. (2007) Importance of low-flow and high flow characteristics to re

along rivers in arid south-western United States. (Freshwater Biology) 52, 651-679. [contact J. Stromberg @ ASU for pre publication copy] 
circumstance. 

69 16 Public 

Outreach 

Kubly BOR Public outreach is already funded through the POAHG. Why is 

additional funding required? Is the POAHG budget insufficient? 

Justify public outreach need re: POAHG 

Y There purpo

mitigate potanglers and informing thWe includeeffort becauconsidered POAGH wosupport it. 

70 21 20 Davis CREDA How does this study help us to weigh the achievement of sandbar 

resource goals for other reaches? This is but one area of the canyon and as such, it will not tell us whether management goals 

are going to be met in other areas. This project is too limited to be of value in seeing if BHBFs help us achieve the AMP goal. It is largely duplicative of Project 1A that measures temporal/spatial sediment budgets throughout the canyon and can more broadly answer questions relative to the utility of BHBFs. 

Drop Project 1B 

Y Project 1B i

understanditransport, anBHBFs. Th“the achieveother reachewas chosen many large measuremenreach during eddies gainisand). Giv(perhaps the reach will alikely gain mconditions eeddies lose 

71 21 42 Davis CREDA We see no basis for assuming that the development of predictive 

capabilities at this site (several eddies around RM 45) will have broad application. No discussion is provided on how these results would be applicable to the entire CRE or why we should assume they would be. 

Provide a basis in the text for the assumption of predictive capabilities beyond the vicinity of RM45. 

Y A response 

Physics appcollecting dsandbar respmodels will 

72 23 23 Kubly BOR This section should be illustrating the links with effects of BHBFs 

on nearshore fish habitats, but this connection is not being made. We end up with a very general account of how it relates to biological studies, none of which are of native fish or their habitats. I think this is a missed opportunity. 

Provide better integration with understanding native fish habitat changes from BHBFs 

Y Please see r

This section fact that is wdepositionaerosion) and nearshore h
73 24 6 

11 

Kubly BOR How are different ramp rates being evaluated by this project? 

How do the “simulation models” compare with CEQUAL-W2 and other models already in operation? 

Answer Y 

Y 

The study ostudy, rathesediment dedeposition. 

74 25 1 Mike Berry BOR Glad to see that the presumed benefits to archaeological sites are 

treated as a hypothetical in this project description (although not in most of the narrative text). However, the issue of preservation of archaeological sites may be moot in many instances because sites exhibiting erosion have been targeted for excavation or other treatment options under Reclamation’s Section 106 compliance activities. 

Rewrite in order to consider/explain program overlap 

Y We underst

an agreemenmitigating evisitation imarchaeologilaudable, thfor the most the CRE domonitor and on cultural ran optimal oconsideratioremaining cbenefit of fuevidence inenhance stohigher elevafurther the aarchaeologiprotection othe CRE, independent nfocusing adthe processeenhance sedthe CRE, esa potential tarchaeologi

75 25* 26 Davis CREDA Although of scientific interest, we see little utility in studying 

aeolian transport. The AMP goal is to preserve and protect sand bars and, in that, there may be some dam effect and a measure of control. We have no control over wind. Knowing the degree to which aeolian transport at one sandbar or another contributes to arch. site protection or preservation does not and would not change the AMP goal to preserve and protect sand bars. Since Project 1A will ascertain longitudinal patterns of net erosion and deposition, it should supply all the necessary information to determine if BHBFs will meet the AMP goal of protecting and preserving sand bars. 

Drop Project 1C 

In addition protection, tsitu preservknow that tharchaeologi

of the AMPintegrity anmaintaining much sedimsurface run-1963, dam ohydrologic rGlen Canyo
of the natur

replenished systematicalower eleva2003.) Themechanismsystemwide elevations, wsites are situof alluvium conjunction erosion, sucinstalling chthe only reaintegrity of While it is tover wind, tsupply that limiting aeo(there is plebut if sand itransport withe connectiavailable fosand deposieffects on eof archaeoloThe study oseveral poteevaluated as focus of Proextent of saBHBF, then campsites, bProject 1.A suspended simmediately measure the BHBF; this 

76 25-

30* 

Study 1.C 

Dongoske CREDA The scientific study of the relationship between sandbar building 

as a result of a BHBF and the preservation of archaeological sites is poorly defined. At this point, as the study is described, the 

Please clarify and more effectively 

Y We disagree 

other aeoliabelow.) In 
results of this study will contribute little to our understanding of 

archaeological site preservation in the Canyon. Moreover, this study will not contribute to our ability to tease apart the effects of dam operations from those processes that are naturally occurring in archaeological site erosion or preservation. The funds associated with this project could be better spent elsewhere. 

describe how archaeological site preservation (a management goal) will be measured and evaluated should aeolian sand be deposited on archaeological sites. 

sand traps to sand (which effects of dathat are natuBHBFs will selected arcin sediment topographic whether arcCRE) experBHBF, subsor increasesresult of chaMethods wobeing used bUniversity iPark group standard topstations, whresolution gLiDAR for will be repesites for sevmonitoring over severawindblown altering evetop of those 

77 26* 17-18 Dongoske CREDA It is unclear how this proposed study will provide credible data to 

inform on strategic science question 2.1. 

Please be more specific in the explanation, because as this project’s description reads the linkage between a BHBF and any benefit to archaeological site preservation appears to be at best 

Y The propose

dam-controcondition chhigher elevachanges masand availabincreasing pto the additiproposal, afeffects are teffects of thcontinuing tsurfaces and monitoring. 
indirect and 

incidental. Moreover, tracking longterm preservation benefits, if they exist, at archaeological sites to establish the efficacy of the hypothesis does not seem to be included. The connection of the geologic study to the archaeology is not well described or defined. 

78 28 16, 23 James CREDA See comment 2 above. Replace 

“restoration” with “conservation” 

Y We have no

all instances or “conserv

79 28 20-24 James CREDA This sentence is very broad and could be excluded from this 

specific science plan. What are the target reach or reaches? 

Y Target reach

managemen2004 BHBF CRE. 

80 28 Table 

1.C-1 

Dongoske CREDA Specifically describe which archaeological sites are being 

observed for the beneficial effects of aeolian sand transport. Also, describe the distance and directional relationship between the targeted archaeological site(s) and the nearshore sand bar and/or beach. This is vital information for evaluating this proposed study because otherwise it appears that the archaeological sites are incidental to the main focus of the study which would reduce the importance of this effort toward preservation. 

Please identify by site number which sites will be studied. Also, identify the distance and directional relationship between the targeted 

Y Since this is 

avoided incsites and ketable very garchaeologithe table captheir relatioprovided on that the aeocomponent response to that it is “in
archaeologica

l site and the nearshore available sand. 

importance” our understapreservation in the CRE. 

81 29 18 Knowles FWS There is a lot of time between March and September. Can we 

monitor the fate of backwaters on a finer time scale (see comment 6)? 

Question Y Please see r

82 29 18 Kubly BOR As indicated previously, I question the value of surveys done 6 

months after the BHBF when we know so little of the temporal dynamics of these habitats. What parameters and metrics will be measured to determine the extent to which observed changes are related to the effects of the BHBF? 

Answer Y Please see r

83 30 24 Berry BOR The table indicates that $493,200 will have been spent on this 

project by the end of FY07. How can this be true if we do not have a BHBF in FY07. Also, wasn’t that funding approved by the AMWG for other aspects of the cultural program? Were these accomplished? 

Explain the discrepancy between the approved AMWG budget for FY07 and this reallocation of funds to BHBF support. 

Y The FY07 b

assumption could allow during FY0paid for from direct relatifor this projnor are any another bein

84 31 22 Davis CREDA As a way to answer EIN 6.5.1, this project makes doubtful 

assumptions. The project has limitations in documentation that prevent its use in trying to see if BHBFs meet the goal of creating community changes in the CRE. Nearly 80% of the CRE is left out of the project and we question the value in extrapolation from one river reach, especially the reach closest to the dam, to the entire CRE. Expecting to establish a “flow-only operation that will rebuild sandbar habitats” would be difficult enough for one reach yet we need to know if there is one operation applicable to the entire CRE. This project is not broad enough to provide that level of information. Also, this project will not provide temporal information (influence of time of flooding on species ratios) nor distinguish between grain sizes downstream of LCR both of which may be critical to establishment of either native or nonnative plants. 

Review the number of sites in the reach to see if they could be reduced and other sites downstream of LCR added to broaden the project’s utility. 

Y The project 

change occuvs. vegetatecommunity exotics, or nanswer all rquestions, babout pattertrajectories association data collectthe locationBecause the established we will excthose farthemarsh commare some loimplicationinformation 
these plots a

monitoring Annual survmonitoring, and could bincorporatinmanaged higround sites following thbut this woupropose. 

85 33 31 Kubly BOR Compliments on the most detailed description of data analysis in 

the document. Still, providing the ANOVA table(s) and identifying the specific F-tests would improve the reader’s ability 

to understand. 

Provide the ANOVA table(s) 

Y We will ide

the plan. 

86 34 14-19 Dongoske CREDA The plan does not appear to integrate other tribal program work on 

traditionally culturally important plants with work proposed in this 

plan. Unless such linkage is clearly demonstrated, this plan should not cite such linkage as product or benefit of this study. 

Delete reference to Traditional Cultural Properties or resources of importance to Native Americans. Proactively develop a science program that equitably integrates Native American values and perspectives. 

Y We disagree 

with the AMnative riparvalued resoucontinuation several tribeon documenare importadesigned thchanges in tat specific sintegrated, sculturally-spresponses osuch, will pfactors and and abundanriparian spebenefit the ithe AMP. Tand benefit 

87 36 22 Davis CREDA The project proposes to measure the affect of BHBF on fish but 

absent is any mention of the limitations on the project’s ability to generate data on specific fish, including humpback. 

Specify information will be collected to enable inferences about humpback to 

Y Please see r

B. 
at least begin 

addressing problems identified in Appendix B. 

88 36 36 Kubly BOR A connection could be made here between algal and invertebrate 

recovery rates, fish bioenergetics, and the frequency of BHBFs. Is this relationship being considered in the integration between sediment and biology? 

Answer Y Aquatic foo

suggestions 

89 37 36 Davis CREDA Inferring growth rates for fish should not be a ‘one size fits all’ 

approach owing to vast difference between fish diets. Food available for different fish species before, during and after a BHBF should be highly variable. 

Provide more explanation about the specific way the project will avoid making broad statements about food availability when addressing the array of native and nonnative fish. 

Y The most di

will be addrthis habitat be developeaddressing aspecies. 

90 37 37 Kubly BOR Are there cold-water stream examples that provide comparisons 

with the hot desert Sycamore Creek? Minshall studies perhaps? 

Citations? Additional c

requested. T

91 38 18 Davis CREDA Although trout K- factor is important to track, humpback may also 

be affected by a BHBF influence on food resources. Where does the K-factor for humpback come in during the BHBF project? Can we use a surrogate NA species? Also, are you looking at different life stages? As written, the project seems too limited to provide insight on fish other than trout and that limits its utility. 

Consider finding a way to look at effect of BHBF on food resources for native fish species downstream of Lees Ferry. Appendix B gives some insight to the difficulties but the project should at least 

Y 

It is importasubset of all Ongoing fomonitoring concerns 
show how to 

begin to address these difficulties. 

92 38 Fig 

3.1 

Kubly BOR Couldn’t you also have a hypothesis that presumes intense 

cropping, rather than flows, impedes senescence? Any idea of the extent to which the changes in the algal-macrophyte communities are due to biological control (cropping) as opposed to physical effects (flow)? 

None Aquatic foo

reviewer’s c

93 41 1 Knowles FWS How will the experiment affect spawning and recruitment of 

humpback chub in the mainstem (30-mile) and at the LCR, and how will this be evaluated? 

Add study? Y Please see r

long-term mpopulation w

94 42 24 Persons AGFD I thought Project 4.a (RBT early life stage survival) fit well with 

ongoing studies by Josh Korman, but don’t know yet if it is the best way to address BHBFs in the future. It would have been very convenient in 2007 because of the pre-BHBF data that exists. I’m not sure if this project will continue as a monitoring tool but if it does, the study as described can probably be pulled off the shelf and be ready to use. Does the project plan to use tags with a mortality signal? We don’t understand the fate of fish that die in 

the reach, but suspect they become disoriented and drift downstream. If this were to happen with tagged fish would you be able to tell if the fish were dead or alive as they passed a downstream SUR station? 

If the smallest trout that can be tagged are approx. 100 mm (4 inches), will it answer the movement question for smaller fish? Is there a better way to do this? This seems like a good project to put out for bid to see if other options exist to answer the emigration question. 

Consider soliciting other projects after clarifying need for project. 

Y 

Will review reviewer to 

95 45 1 Persons AGFD 4B Effects of BHBF on adult trout distribution. Is it a high 

priority AMWG question, or should we focus on looking at displacement of native fish (HBC) during a BHBF using sonic technology? Again, this looks like a good project to put out for bid, now that the rush to develop studies has slowed. 

Please provide more justification for this project rather than a project to assess impacts of BHBF on native fishes? 

Y Some TWG 

question whthe Lees Fehelps addreany rainbow developmen

96 45 9-12 Persons AGFD Who will be the PI for this study? Y Now that G

Hilwig and/

97 45 29 Knowles FWS Juvenile humpback chub are thought to be killed, incapacitated, 

and disadvantaged by cold-water effects on swimming ability; 

Edit Y Please see r
intuitively, their ability to respond to flooding events may be 

compromised. You should provide a discussion of this effect in light of the 2004 experimental results (not necessarily here but somewhere in the document) and provide some means of evaluating this, even if its just replicating the hoop net surveys of the prior experiment. 

98 47 18 Davis CREDA A BHBF is triggered by rather sudden events and their prediction 

is uncertain so how much prior to a BHBF can these be inserted? If tags are inserted in anticipation of a BHBF but there is no BHBF trigger, when would we lose the tag transmitters? 

The coordination of tag insertion with the uncertain likelihood of a BHBF should be discussed so we can see the risks associated with the project. 

Y We would h

decisions coBecause of concerns in We propose decision to 

99 48 14 Davis CREDA We do not see this project directly answering this question, as 

stated, but it may help determine if emigration occurs. 

Check text language. 

We agree thquestion, buprovide sominform this informed hythe reviewe

100 48 15-22 Persons AGFD I don’t think 4B addresses the information needs (RIN 4.2.1, 4.2.2 

and 4.2.3) about alleged emigration in a useful way. Isn’t the big question “at what densities” do trout move downstream? We have good evidence that adult trout will not be displaced by a BHBF (1996 and 2004), and hints that small trout might be. We also have suggestions of downstream movement of young trout at high densities without BHBFs. I don’t think a study around a BHBF will answer the bigger question about trout movement, I think we need a longer term approach to address the emigration question. We have resumed Floy tagging adult trout captured in the reach during monitoring activities, and over time that may provide movement data for adult trout. 

I’ll repeat my earlier request to look at downstream movement from the Lees Ferry reach with coded-wire tagged stocked fingerling trout (perhaps sterile triploid fish). There are no projects to address this in the FY 2008 work plan. I think it will take several years to collect enough data to understand the 

Provide justification for this project rather than another looking at the bigger question of alleged emigration. 

Y We don’t th

BHBF will this is one pwith the revto be develo

Introducing trout compoconfounds epolitical/polTWG could stocking if t
relationship between trout density, flows, and any downstream 

movement. I think a long term approach will be a better way to 

address this question, rather than around BHBFs. 

101 48 15-22 Persons AGFD In the 2004 before and after BHBF studies, there were changes 

seen in HBC relative abundance (confounded by catchability issues) near the mouth of the LCR Would it be more useful to implant native fish or small fish near the LCR with sonic tags and track their movement? 

Why not look at BHBF effects on native fish movement? 

Y Agree. Plea

proposes th

102 48 31 Persons AGFD Budget (GCMRC salary) seems insufficient for this project. Can 

you clarify costs? 

Clarify costs & who will do the work 

Y Because of 

salary costs reviewer’s sfunding to twith fiscal s

103 50 12 Knowles FWS What potential is there for BHBFs to entrain fish from Lake 

Powell? 

Edit? Y 

Unknown. Ssuch escapetransport thr

104 52 1 Knowles FWS Add a section on compliance here; section 7 consultation will be 

necessary. We will need additional monitoring of humpback chub associated with the experiment, as discussed in comments below. 

Edit Y We were no

document, tinformation efforts. 

105 52 38 Davis CREDA The conduct and timing of the science trips are well known to the 

NPS by their participation on the AMWG. Also, how does the conduct of a BHBF during the winter non-motorized season fit with the NPS policy especially since 9 trips will be taken over a 3 month period? 

It seems appropriate and feasible to routinely obtain such permits well in advance of any potential BHBF (6 weeks seems too tight) to allow NPS adequate time and avoid any delays. 

May have to rules depen

106 66 38-40 James CREDA See also comment 3 above. How many times does a particular 

BHBF need to be performed to “confirm its effectiveness”, if the 2004 test “did result in robust sandbar building in the reach (upper Marble Canyon)”? 

Y This questio

between scithe 2004 testest. Managcertainty is implementestill trying t
enriched co

building and conditions a

107 67 

(see also page 70, line 11) 

15 James CREDA It is unclear what the “proposed timing of future BHBF 

experiments” is. This section refers to “late March”; elsewhere there is reference to fall events. Are different event timetables associated with different resource impacts, and if so, it would be helpful to array those scenarios for the AMWG members to consider in trade-off analyses. 

Y This section 

tied to late wreference to 

108 67 30 Knowles FWS We are of the understanding that ongoing investigations by 

GCMRC are revealing the extent to which turbidity effects gear efficiency. We suggest that catch rate data may still be useful and should be collected. 

Edit Y Even if the 

as valuable monitor fishdata the rev

109 68 26-35 James CREDA Disagree that economic impact assessment has “not been 

conducted and can not be definitively determined with available information”. 

Suggest rewording as follows: Specific studies to assess the economic impacts of conducting future BHBF experiments need to be undertaken following determination of a specific experimental plan and timetable”. 

Y The analysi

experimentawas a financeconomic animpact analin breadth asufficient sptiming of prwith varyinrewording o

110 68-

69 

General 

James CREDA See comments below** Y These appea

makers to c

111 69 3-7 James CREDA GCMRC has indicated its inability to assess “valuation” 

economics as part of a trade-off or cost-benefit analysis. Therefore, recommend removing “societal value” from line 5. 

Y GCMRC is 

expertise to future, if thi

112 71 NA Knowles FWS Under “PROS” for “AMP RESOURCES” you have “Creation of 

backwater habitats used by native fishes” and “Mimics seasonal flood disturbance to the river ecosystem” We agree with both these statements, but there is little discussion and justification for/about them or foundational basis for additional testing in the 

Edit Y 

Accepted. Wby the revie
plan. We suggest you add in sections on what is known about 

these concepts (including importance of backwaters to humpback chub, creation of backwaters from flood events, and importance of seasonal hydrographs to humpback chub biology - e.g. Goeking, 2004, AGFD 1996, Valdez and Ryel 1995, Converse 1998; see also Muth et al. 2000) and how this plan will improve our understanding of them. 

113 71 26-35 James CREDA Disagree that economic impact assessment has “not been 

conducted and can not be definitively determined with available information”. 

Suggest rewording as follows: Specific studies to assess the economic impacts of conducting future BHBF experiments need to be undertaken following determination of a specific experimental plan and timetable”. 

Y Please see r

114 71 Table 

A.1 

Dongoske CREDA Again, wind transported sand is identified as will result in 

archaeological site preservation – a scientifically unsubstantiated hypothesis that is being promoted as scientific fact and a benefit of BHBF. 

Please reword to indicate the uncertainty in this result of a BHBF. 

Y OK, this wi

preservation secondary w

115 71 Table 

A.1 

Dongoske CREDA Another uncertainty that is missing from the AMP resources is the 

impact, positive or negative, of a BHBF on traditional cultural important biological and physical resources to Native American communities. 

Why is this resource omitted from this table? This appears to be inconsistent with the claims made earlier about traditional cultural plants in the riparian 

Y The referen

Vegetation important panother cate
study. Please 

be consistent throughout the document when addressing resources and issues of importance to Native Americans. 

116 76 8 Knowles FWS AGFD 1996, Converse 1996, Valdez and Ryel 1995, and Chart 

and Lentsch 1999 all found that nearshore habitats are important 

to humpback chub and subject to changes due to flow. How will changes imposed by the current experiment affect these habitats? GCMRC should add a study, utilizing methods similar to these studies cited above, that analyze pre and post short-term and longterm effects of the experiment on these habitats and fishes that occupy them; this should also be done in relation to other flow regimes (daily, monthly). 

Edit Y 

Additional bplease see rthat the BHadditional f

117 77-

79 

N/A Knowles FWS Telemetry is a good idea and the concept of testing it first on 

rainbow trout to answer questions on dispersal makes sense. But the idea that you won’t use standard capture techniques to test hypotheses of the effects of the experiment because catch rate does not always equal abundance seems esoteric. Catch rate data is nevertheless valuable data, and there is no other way at present to gain any understanding of the effects of flow on juvenile humpback chub. The new method suggested of using occupancy models sounds intriguing, but why not try it in this plan? If not yet fully developed, we ask that you rely upon existing methods. 

Edit Y We remain 

academic limvariable thaexpense of oemphasize twhich, for fgathering of so still requthe reviewe

118 79 8 Persons AGFD Specific recommendations for use of sonic tag technology will be 

prepared, reviewed, and distributed at least 120 days in advance. Can this be done in CY 2007 after the catfish sonic tag work? Does it need a BHBF to evaluate and learn to use the gear? I know this was put together in a hurry, but it seems that we have more breathing room now, and can consider other options. 

Consider other options? 

Y 

Assuming 2will develop association minimum 1single projetimeframe, 

119 80 20 Knowles FWS We disagree that “impacts of fluctuating flows on humpback chub 

recruitment are not supported by the timing of decline in humpback chub abundance ...” and ask that you elaborate on this statement with data and/or citations. There are numerous studies that support the strong implication that diel fluctuations have adverse effects on juvenile humpback chub, likely reducing survivorship, and therefore limiting recruitment (Stanford 1994, 

Edit Y 

We will ediwill be revienew stateme
Valdez and Ryel 1995, AGFD 1996, Converse 1996, Robinson et 

al. 1998, Chart and Lentsch 1999, Muth et al. 2000, Stone and Gorman 2006). 

120 80 33 Knowles FWS We acknowledge that there are difficulties and variability 

associated with using traditional methods of catch rate and markrecapture to assess young humpback chub survivorship and recruitment, but these are the only methods currently available. We suggest that these methods be employed, and over a long-term period, to assess use of nearshore habitats by juvenile humpback chub and other fishes, including the effect of flow regime on these habitats. 

Comment 

Agree; we wresponse to in interpretibegin mode

121 81 1 Knowles FWS We agree that flows need to be evaluated over long timeframes; 

consistent monitoring of nearshore habitats, even using methods with high variance, would better evaluate changes in habitats due to flow and associated effects on juvenile humpback chub than no monitoring at all. [My mistake, there is the fall backwater sampling – why is there no mention of the results of this monitoring in relation to the plan?] 

Comment 

The additionpropose for the fall seinTable B.1 fo

122 82 30 Werner AZ Citation not in lit cited in App B but in lit cited for main body. 

Not clear why some are located in App B and some not. 

check N Citation now 

Note from Werner: I have reviewed comments submitted by CREDA and believe those comments warrant careful consideration. 1 Mahoney J.M. & Rood S.B. (1998) Streamflow requirements for cottonwood seedling recruitment- an integrative model. Wetlands, 18 634-645. 2 Stromberg J.C., Beauchamp V.B., Dixon, M.D., Lite, S.J., and Paradzick, C. (2007) Importance of low-flow and high flow characteristics to restoration of rip

south-western United States. (Freshwater Biology) 52, 651-679. [contact J. Stromberg @ ASU for pre publication copy] 

**Where reference is made to impacts to the hydropower RESOURCE (not “interest”), discussion is limited to “lost revenue generation opportunities”. This i

AMWG meeting of December 5-6, 2006, there was discussion that centered around the following points, which should be incorporated into this assessment an

recommendations regarding a BHBF: 

• The cost to power users resulting from bypass flows, subsequent power purchases to meet unmet contractual obligations, and possible rate increases that 

unanticipated burden on the Basin Fund and the power customers 

• Costs of a BHBF may result in cash flow problems in the Basin Fund similar to those experienced in past years • The ROD doesn't allow for a BHBF in other than hydrological trigger years (risk of spill years) except for experimental purposes (ROD/GCPA). 

• Consideration should be given to inclusion of a “financial trigger” to be used in conjunction with a “sediment trigger” and a “hydrologic trigger”.