TO: Bureau of Reclamation Attn: LTEMP SEIS Project Manager
125 South State Street, Suite 800
Salt Lake City, UT 84138
November 3, 2023
RE: Bureau of Reclamation (Reclamation) requests public comments to prepare a Supplemental Environmental Impact Statement (SEIS) to the December 2016 Record of Decision for the Glen Canyon Dam Long-Term Experimental and Management Plan (LTEMP) Final Environmental Impact Statement and will analyze flow options to prevent smallmouth bass and other warm water invasive nonnative fish from establishing below Glen Canyon Dam (by preventing additional spawning) and will analyze new information regarding the sediment accounting window associated with the LTEMP High-Flow Experiment (HFE) protocol.
Part One: Introduction
This comment letter is provided by Center for Biological Diversity, Colorado Riverkeeper, Glen Canyon Institute, Great Basin Water Network, Great Basin Waterkeeper, Las Vegas Water Defender, Living Rivers, River Runners for Wilderness, Save The Colorado, and Utah Rivers Council.
Collectively, our organizations, members, staff and trustees have provided comments on the operation of Glen Canyon Dam (GCD) since 1989 when a Notice of Intent was published to develop the first Environmental Impact Statement for operations at Glen Canyon Dam. The scoping report for that original EIS highlighted that 71,000 unique comments from the public were received by April of 1990. We now know that 71,000 people will not be commenting for this SEIS because of the persistent state of recalcitrance demonstrated by the water managers of the Colorado River Basin (CRB). The reduction in public participation is a failure, signifying that current river management has demoralized the goodwill of the general public for parts of five decades.
The best example of this deliberate recalcitrance by water managers toward the public is best demonstrated by the last sentence from this 2002 letter to Reclamation from the Upper Colorado River Commission which is provided here:
Therefore, the Upper Colorado River Commission strongly believes that through the Annual Operating Plan process and under the general guidance of the Operating Criteria, operational needs of the Colorado River reservoirs are being accommodated without any changes to the existing 1970 Operating Criteria. In addition we see no need for public meetings to review Operating Criteria that are working satisfactorily at this time.
Because of the present and failed state of reservoir storage in the CRB, and the looming jeopardy toward federally protected fish species in Grand Canyon National Park, we submit that long-term solutions submitted by citizens is what Reclamation must adopt for this process of developing new operating criteria for GCD in this current epoch of advancing and debilitating climate change.
The documentation of agency recalcitrance is detailed by John Weisheit and Robert Lippman in a web-based post dated October 3, 2008 and entitled “A Legal History of Operations at Glen Canyon Dam.” We invite the readers of our scoping document to analyze the merits of this post.
Part Two: Negligence by Reclamation
Reclamation has failed to adopt new operating criteria for Glen Canyon Dam in a timely and prudent manner to avoid jeopardy to biological and cultural assets in Grand Canyon National Park; a failure of the authorized agency to be precautionary and adaptive to the long-term monitoring programs mandated by the Grand Canyon Protection Act of 1992.
The development of this Supplemental EIS in 2023 means the Final EIS of 2016 (a 20- year management plan), was inadequate before the first day of its implementation, because basin-wide discussions about avoiding system shortages as a result of climate change were actually underway as early as February of 2014.6 These discussions culminated five years later with federal and state agreements known as 2019 Drought Contingency Planning.7 Shortages in the system were declared by the Secretary of Interior in August of 2021.
Therefore, this Supplemental EIS process of 2023 must take a hard look at the following missteps that occurred in the last nine years:
- To the extent that Reclamation made a decision not to prepare a precautionary SEIS in a timely manner, and that this decision was contrary to the guidelines of the National Environmental Policy Act (NEPA). This inaction demonstrates our argument that Reclamation and the seven states have not upheld their public interest obligations.
- The 2016 analysis relied upon incomplete and outdated data in regards to the impacts of climate change.
- Reclamation relied solely upon historic flow predictions rather than also considering climate change flow predictions to Year 2036.
- The purpose and need statement unreasonably omitted climate change in favor of a nonexistent obligation to produce hydroelectric power.
- The Final EIS included only near-identical alternatives and failed to consider any alternative that could potentially address the realities of future climate change.
Part Three: Submission of our administrative record in regards to providing public comments to Reclamation and specifically about operations at Glen Canyon Dam.
In consideration of the heavy lifting that we have already performed in providing public comments to Reclamation, we will again submit all our NEPA letters about operations at Glen Canyon Dam in the following table…(download the original letter here, for links to previous public comments)
Part Four: Engineering of Glen Canyon Dam did not account for global warming
Glen Canyon Dam (GCD) is not engineered for a water delivery system that includes the impediments of maximum human consumption under conditions of global warming that will persist for time periods that will last for multiple centuries. To protect downstream resources and jeopardy to living communities, Reclamation must begin discussions about decommissioning this facility.
- Sea level elevations began to rise in the 1880s, indicating a trend of thermal expansion and the melting of continental ice.
- The geologic bedrock at Glen Canyon and the climate of the Colorado River Basin is problematic for a reservoir that can store 27 million acre-feet of water, entrained sediment and decaying organic materials.
- In 1983 it was discovered that the outlet works at GCD could not safely handle a four-month snow melt of 15 million acre-feet, which induced property damage to people and businesses that occupy the floodplain below Davis Dam.
- During the lifespan of this facility, the demand to safely bypass a five-month snowmelt in the range of 30 to 60 million acre-feet will arrive. This structure will fail and damage and destroy all critical infrastructure downstream and will inundate the structural depression at the Salton Trough (Salton Sea) for decades, which currently provides the nation with dependable supplies of fresh produce.
- In 2015 (before the implementation of the LTEMP) it was discovered that non-native fish can safely bypass through the penstocks of GCD.
- In 2022 it was determined that hydropower production would be seriously impaired at GCD should the snow melt of 2023 fail to provide adequate runoff.
- Reservoir water seepage through the bedrock at the dam site is significant. The Upper Colorado River Commission’s annual report of 2015 reports the gain in river flow below Glen Canyon Dam averages 153,000 acre-feet per year, which is 211 cubic feet per second. We understand that leakage is normal, but this amount is unacceptable. We request an explanation from Reclamation that addresses this concern we have about dam safety.
- During episodes of significant water evacuation from Lake Powell since 1992, we have observed the degradation of the natural cementation of the sandstone formations of the Glen Canyon Group. For example, you can easily crush these rocks types without tools. Reclamation’s chief engineer recognized this issue too, in an engineering report.15 This natural incompetence of bedrock is a dam safety issue that Reclamation should explain to the public.
- Sediment storage in Lake Powell is often interpreted as increasing the lifespan of Hoover Dam, but this belief is deceptive. With each passing decade, there is less water storage and less capacity for flood control at Lake Powell. In other words, the issue isn’t where the sediment is stored, the issue is when does sediment storage compromise the priority mandates of flood control and water storage? Reclamation must explain this issue to the public.
- Lastly, connectivity to the tributaries from the confluence of the Green and Colorado rivers to the basin-and-range country at Lake Mead is how you will solve all the threats to the endangered species of the Colorado River Basin. Give them the habitat and the food web that they need to flourish by removing Glen Canyon Dam.
Part Five: Conclusion
Thank you for this opportunity to share our concerns with the agencies and the public. Again, progress to attain sustainability and resiliency in the Colored River Basin can only be achieved when the seven states yield to the rights of nature.
Very truly yours,
John Weisheit, Living Rivers and Colorado Riverkeeper
Kyle Roerink, Great Basin Water Network and Great Basin Waterkeeper
Taylor McKinnon, Center for Biological Diversity
Eric Balken, Glen Canyon Institute
Tick Segerblom, Las Vegas Water Defender
Tom Martin, River Runners for Wilderness
Gary Wockner, Save The Colorado
Zach Frankel, Utah Rivers Council