Colorado River Restoration In Grand Canyon (Back to Water Program Index)

	Jim Ruch       Colorado River at Lee's Ferry

Harmful Fluctuating Flows from Glen Canyon Dam

Releases from Glen Canyon Dam have not been kind to Grand Canyon.  Day after day, month after month, year after year, flows fluctuate up and down like a washing machine, sometimes varying in a 24-hour period as much as 15,000 cubic feet per second.  Scientists have learned that these fluctuations, although good for generating cheap peaking power from Glen Canyon Dam, are bad for Grand Canyon health. 

The U.S. Geological Survey found in its 2005 SCORE Report that Modified Low Fluctuating Flows (MLFF, the flows coming through  the dam since 1996) are destroying beaches, backwater habitats, humpback chub habitat, and other Grand Canyon resources.  U.S. Fish & Wildlife's 1994 Biological Opinion determined that MLFF dam operations jeopardize the humpback chub, destroy its critical habitat in the Grand Canyon, and impede the chub's recovery.

Changes in the Colorado River Basin

Recent changes in the Colorado River basin - severe drought combined with burgeoning growth - have put intense pressure on the Colorado River and its canyons, species, habitats and communities.  But the changing dynamics have also have created an unexpected benefit: a broad vista of new possibilities for restoring health to the Grand Canyon.  With Colorado River reservoir levels falling temporarily to historic lows, changes in river management and reconsideration of the operations and utility of dams and diversions have become imperative. Carefully crafted, the solutions for sustainable living in the basin can also revive the river and provide the pathway to restored health for Grand Canyon.  Solutions never thought achievable before are now eclipsing the “possible” and becoming necessary.

For millions of years, the Colorado River carved its way through the Colorado Plateau, persisting through ice ages, diving underground when necessary to survive, changing course to adapt to continental shift, and burrowing through molten lava dams and walls of granite.  According to geologist James L. Powell, “…the Colorado River has triumphed over solid rock of every type.” The Colorado brought life to the ancient civilizations of the canyons; made possible the early European settlements of the Southwest; and finally was captured to create today’s dense urban Sunbelt.  Now, 30 million people, 13 Native American tribes, innumerable species and thousands of acres of increasingly rare habitat are dependent on it.  But after 15 million years of triumph and generosity, the Grand Canyon’s ecosystem has begun to weaken under the river’s heavy burden.

Resource Declines in Grand Canyon

Here is some of what we know:

• Ninety-five percent of the nutrient-rich sediment that would normally deposit in Grand Canyon has accumulated behind the dam, eliminating food for native species and sand for beaches.
• Cold water released from the depths of Lake Powell into the Grand Canyon has eliminated reproductive triggers for native species and spawned large populations of nonnative species that prey on the vulnerable natives.
• Natural periodic high flows necessary to build beachesfor native plants and animals and to trigger seed germination have been eliminated in favor of a near static flow regime, destructive to an ecosystem that is dependent upon dynamic annual recharge.

These changes in river morphology have resulted in extirpation of native species including river otters, muskrats, and four of the eight Colorado River fish. Two of the remaining four native fish species are in steep decline, and native vegetation is disappearing from the high water zone due to lack of nutrients and the invasion of competing non-native plants. 

The Grand Canyon Trust has identified four areas of resource decline on the Colorado River in Grand Canyon that must be improved in order to restore the river to a healthy condition.  These are: native fish, native riparian communities, sediment, and archaeological resources.

The humpback chub, an endangered four-million-year-old fish found only in the Colorado River, is down from 1989 population levels of 9,300 to 6,000 currently.  Other native fish have suffered similar declines.  Dramatic habitat changes created by Glen Canyon Dam and the proliferation of nonnative fish are the primary suspects in the disturbing decline of the humpback chub population in Grand Canyon.  Releases of cold, clear water from the dam continue to create unfavorable habitat conditions for the humpback chub and favorable habitat conditions for the chub’s nonnative predators.

Media Bakery

Native riparian communities are also in decline.  The sand beach community, composed mostly of grasses and forbs, historically occurred in a wide band adjacent to the river that is now being overrun by the nonnative tamarisk tree.  Above the sand beach community is another narrow band of long-lived trees and shrubs that run parallel to the river.  Known as the “old high water zone” community, it is being degraded by the invasion of nonnative species and lack of recruitment of new individuals to balance mortality.

Sediment measurements in the river and on beaches show continuing, long-term declines.  This is disastrous because river sediment supports habitat for aquatic and riparian species, provides recreational camping sites, and is critical for protecting cultural resources.  No longer is there sufficient input and sediment storage to balance the natural loss through erosion.  Grand Canyon now only receives sediment inputs from its tributaries—about five percent of the amount of sediment that historically entered Grand Canyon each year.

Because sediment flow is diminished, cultural sites are also in decline.  Intermittent flows in tributary drainages create destructive gullies and erode archaeological resources.  Before the dam was constructed, flood flows quickly refilled gullies with transported sediment.

Glen Canyon Dam Adaptive Management Program

In 1988, the Grand Canyon Trust (together with the Western River Guides Association, the National Wildlife Federation, and American Rivers) successfully sued the Western Area Power Association (a federal agency that markets power from Glen Canyon Dam) on the basis that dam releases for hydropower generation were degrading the Colorado River through Grand Canyon. Subsequently, the Trust became actively involved in passing the Grand Canyon Protection Act (GCPA).

Following passage of the GCPA in 1992, the Trust became oneof the original stakeholders in the newly created Glen Canyon Dam Adaptive Management Program (AMP), a 25-interestholder collaborative process that advises the Secretary of the Interior to implement actions that improve Colorado River.
                                                                                                                                                 

Photo courtesy of USGS                                                                                                               Glen Canyon Dam March 2008

Grand Canyon Protection Act

The Grand Canyon Protection Act (GCPA) was signed into law on October 30, 1992.  The GCPA states: “The Secretary shall operate Glen Canyon Dam in accordance with the additional criteria and operating plans specified in section 1804 and exercise other authorities under existing law in such a manner as to protect, mitigate adverse impacts to, and improve the values for which Grand Canyon National Park and Glen Canyon National Recreation area were established, including, but not limited to natural and cultural resources and visitor use.”

The intent of the GCPA is unambiguous: to operate the dam in a manner that protects park resources and values.  On the floor of the Senate, Senator John McCain stated: “The erratic release of water from the dam to meet peak electric power demands [has] destroyed Colorado River beaches, and harmed other natural, cultural, and recreational resources.  Somewhere along the line, we forgot our obligation to the canyon and to [t]he future generations for whom we hold it in trust.  In response, I introduced the Grand Canyon Protection Act to reorder those priorities—to stop the damage and legally require the dam to be operated in a manner which will protect park resources.”  [Senate Congressional Record]

Making clear Congress’ intent to prioritize Grand canyon resources over power generation, Senator McCain had the following exchange with Senator Bill Bradley on the floor of Congress.  Senator McCain asked, “Is it the Senator’s understanding that the Grand Canyon Protection Act rejects the policy that power generation has any priority or primacy over protection of downstream environmental, recreation, or cultural values?”

Senator Bradley replied, “Yes,” and clarified by stating, “Under the Grand Canyon Protection Act, all aspects of Glen canyon Dam operations should be governed by the goal of protecting the downstream r4esources so long as those operations do not interfere with the allocation, apportionment, and deliveries provided for in the Colorado River compact resources.”  [Senate Congressional Record]

Modified Low Fluctuating Flows Are Destructive

Completion of the Environmental Impact Statement (EIS) on the Operations of Glen Canyon Dam was mandated by the GCPA, and the Record of Decision (ROD) was signed in October 1996.  The ROD was intended to implement: “an alternative dam operating plan that would permit recovery and long-term sustainability of downstream resources while limiting hydropower capability and flexibility only to the extent necessary to achieve recovery and long-term sustainability.”

Research and monitoring during the last decade of ROD operations clearly demonstrate that the current ROD flows—Modified Low Fluctuating Flows—do not meet the intent of the GCPA. 

MLFF has been run since 1996, and throughout this time there has been a large number of research and monitoring projects and numerous independent and in-house reviews and assessments that conclude thatcurrent dam operations are damaging Grand Canyon resources.

High-Flow Test                                                              

In March of this year, the Bureau of Reclamation ran a 60-hour high-flow test through Glen Canyon Dam to help replenish lost sediment in the river system below the dam.  Maintaining sediment, the foundation for the Colorado River ecosystem in Grand Canyon, is problematic because about 87 percent of the sediment volume that was once transported to Grand Canyon every year is now trapped in Lake Powell. The only possibility for maintaining beaches and nearshore habitats in Grand Canyon is by responding to significant sediment inputs from tributaries with high flows from Glen Canyon Dam.

Photos courtesy of USGS                                                                                                   4 open jets at Glen Canyon Dam  March 2008

Scientists monitoring river conditions following the high flows have already concluded that the experiment was a success, building beaches at numerous places in Grand Canyon.  But unfortunately, Reclamation has caved into powerful hydropower interests and immediately begun again releasing erosive fluctuating flows from the dam.  These erosive flows are part of Reclamation’s five-year Experimental Plan which fails to include another high-flow test (which sediment scientists say needs to be done every 12-18 months).  The Experimental Plan also fails to include the steady flows needed to conserve sediment in the system and provide stable shoreline habitat for the endangered humpback chub.

Bureau of Reclamation's Damaging Experiments

Reclamation has chosen dam operations that maximize the production of cheap peaking power at the expense of Grand Canyon resources.  Their Experimental Plan lacks both future high flows and sufficient steady flows.  It violates federal law and runs counter to recommendations made by numerous scientists. 

Reclamation’s proposals ignore clearly stated opposition from the National Park Service, which has the authority and responsibility to protect the Park against any destructive federal activity, such activity technically called an “impairment.”

Describing the present impairment by Reclamation’s Experimental Assessment and Plan, Superintendent of Grand Canyon National Park Steve Martin stated in his public comments:

Analysis of [Reclamation’s] Environmental Assessment and proposed action (including strict limitations on future flows, a short-duration steady flow regime in the latter part of the monsoonal period, and other key factors) indicates these measures would likely result in impairment of the resources of Grand Canyon National Park.

The [Plan] as written appears to be in conflict with NPS 2006 Management Policies, may not be consistent with CEQ guidelines, and is significantly in conflict with our understanding of the science and inconsistent with the intent of the Grand Canyon Protection Act . . .  

Reclamation Not Cooperating with National Park Service

Even though the Park Service has the responsibility to protect the Park from illegal and damaging federal activities, Reclamation has refused to include the Park Service as a cooperator.

Senior officials at the Department of Interior, including Assistant Deputy Secretary Jim Cason, Solicitor David Bernhardt, and Staff Attorney Bob Snow, continue their misguided mission to strip the National Park Service of its authority and responsibility to protect Grand Canyon National Park.  The Department of the Interior is knowingly supporting dam operations that violate federal law and go against $80 million worth of agency science. 

Endangered Humpback Chub  

The endangered humpback chub has survived in the lower basin of the Colorado

River and the Grand Canyon for three- to five-million years.  Yet in just the last 45 years, Glen Canyon Dam and its operation have caused the chub to become threatened with extinction on the lower Colorado River.  The U.S. Fish and Wildlife Service (FWS) concluded in their 1994 Biological Opinion that Reclamation's operations of the dam are jeopardizing the chub and adversely modifying its critical habitat in violation of the Endangered Species Act (ESA).

  Photo courtesy of USFWS                                                  Adult Humpback Chub

Reclamation could operate the Dam in a manner that complies with the law and limits the adverse impacts to the chub and its critical habitat, but chooses instead to provide cheap peaking power to hydropower customers.  Reclamation refuses to comply with the ESA and the National Environmental Policy Act (NEPA) and operate the dam in a way that ensures the humpback chub's survival and recovery.

Grand Canyon Trust Litigation  

On March 17, 2008, the Grand Canyon Trust filed in federal court a legal complaint containing eight claims, including ESA, NEPA, and Grand Canyon Protection Act claims.

ESA Section 7(a)(2) mandates that Reclamation's Glen Canyon Dam operations neither jeopardize the endangered humpback chub in the Colorado River nor destroy or adversely modify the chub's designated critical habitat in the Grand Canyon. In its Biological Opinion, FWS determined that Reclamation's existing dam operations, which involve water releases under a "Modified Low Fluctuating Flow" regime, violate these ESA section 7(a)(2) prohibitions.

Moreover, Reclamation has not implemented the seven-month water release program called "Seasonally-Adjusted Steady Flows," as FWS required in the Biological Opinion. The result: Reclamation's operations are adversely impacting river flows, sediment loads, and temperatures, which, in turn, harm the chub and degrade its habitat by eliminating seasonal flows, destroying shoreline habitats, and preventing river warming.

As stated earlier, Reclamation adopted an Experimental Plan for Glen Canyon Dam that damages Grand Canyon resources and violates federal law.  The Trust’s sixth through eighth claims challenge this 2008 Experimental Plan on the grounds that it violates NEPA, the Grand Canyon Protection Act, the ESA, and the AdministrativeProcedure Act (APA).

Reclamation prepared an environmental assessment and issued a Finding of No Significant Impact (FONSI) for the 2008 Experimental Plan. The EA/FONSI violates several federal laws. Reclamation failed to provide adequate notice and public comment for the EA/FONSI.  Reclamation's assessment of impacts and conclusion violated NEPA.  Reclamation failed to adequately consider the NEPA significance factors.  Reclamation ignored impacts to Grand Canyon Park's natural, cultural and recreational resources, and impacts to the humpback chub and its critical habitat.

The Grand Canyon Trust and the National Park Service urged Reclamation to consider a Seasonally-AdjustedSteady Flow alternative that complied with and implemented the legal requirement set forth in the 1994 Biological Opinion. In violation of law, Reclamation did not consider a Seasonally-Adjusted Steady Flow alternative that comported with the 1994 Biological Opinion. 

Litigation - Summary of Claims  

Eight claims exist in Grand Canyon Trust’s lawsuit against the Bureau of Reclamation and the U.S. Fish and Wildlife Service. The first three claims stem from Reclamation's failure to adhere to the requirements of FWS's 1995 Biological Opinion and the resulting violations of the ESA.

Claims 1-3:  ESA Section 7(a)(2) mandates that Reclamation's Glen Canyon Dam operations neither jeopardize the endangered humpback chub in the Colorado River nor adversely modify the chub's designated critical habitat in the Grand Canyon.  In its 1995 Biological Opinion, FWS determined that Reclamation's existing Dam operations, which involve water releases under a "Modified Low Fluctuating Flow" regime, violate these ESA section 7(a)(2) prohibitions.  Reclamation has not implemented the seven-month water release program called "Seasonally-Adjusted Steady Flows," as required in the Biological Opinion.  As a result, Reclamation's operations are adversely impacting river flows, sediment loads, and temperatures, which in turn, harm the chub and degrade its habitat by eliminating seasonal flows, destroying shoreline habitats, and preventing river warming.

Claims 4 and 5:  Reclamation failed to follow mandatory procedures in preparing Annual Operating Plans for Glen Canyon Dam.  ESA section 7(a)(2) requires Reclamation to consult with FWS on all agency actions, including Annual Operating Plans, that impact endangered species. NEPA requires Reclamation to evaluate and disclose to the public the environmental impacts of its Annual Operating Plans. Reclamation has ignored both environmental review processes prior to issuing its Annual Operating Plans despite impacts to the chub, its habitat, and other Grand Canyon resources.

Claims 6 – 8:  On February 29, 2008, Reclamation adopted an Experimental Plan for Glen Canyon Dam that Superintendent Steve Martin determined would damage Grand Canyon resources.  Reclamation’s Experimental Plan involves two components: a one-time high-flow release – or Beach-Habitat Building Flow – and five years of steady releases for the months of September and October.  The Trust’s sixth through eighth claims challenge this 2008 Experimental Plan on the grounds that it violates NEPA, the Grand Canyon Protection Act, the ESA, and the Administrative Procedure Act (APA).

Intervenors:  The Colorado River basin states (Wyoming, Colorado, Utah, Arizona, New Mexico, Nevada, and California) have intervened in the Trust’s lawsuit.  The  Colorado River Energy Distributors Association (CREDA), Central Arizona Project, and California’s Imperial Irrigation District have also intervened.

Glen Canyon Dam Hydropower Economics

The Trust has commissioned expert energy economist David Marcus to produce a report analyzing the costs of releasing short high-flow events in combination with running steady flows from Glen Canyon Dam into Grand Canyon.  In short, we want to know the economic effect to run steady flows versus the current regime, known as Modified Low Fluctuating Flows.  Modified Low Fluctuating Flows help generate cheap peaking power, but as described above, are damaging to Grand Canyon resources.  In contrast, regular high-flow events coupled with Seasonally-Adjusted Steady Flows (SASF) build beaches, create stable shoreline habitat for endangered fish, and provide support for archaeological sites.

Preliminary Conclusions:

Expert energy economist David Marcus has calculated how the impacts of changing to SASF (between a $3.8 million cost reduction and a $9.5 million cost increase) would affect the average residential household in the 6-state area. Assuming cost changes were spread evenly to all customers in proportion to their energy use, 66.2% of retail customers would see no impact. The other 33.8% would face rate changes ranging from -0.07 percent to +0.17 percent, or from -$0.05/Mwh to +$0.13/Mwh. The impact on the average residential household’s monthly bill would range from -5 cents per month to +13 cents/month in Arizona, the state with the highest residential electricity consumption, and would be lower elsewhere. Averaged across all 6 states, the average residential customer bill impact would be between -4 cents per month and +11 cents per month. In round numbers, changing to SASF might save the average residential customer a nickel a month, or it might cost them just over a dime per month.

As described in the 1995 FEIS, about two thirds of the electricity sold in the 6-state area goes to customers who would be unaffected by changes in Glen Canyon Dam operations. Taking those customers into account, the average impact of changing to SASF for all residential customers in the 6-state area would be between a 1.5 cent per month gain and a 3.7 cent per month loss.

Conclusion 

The Grand Canyon Protection Act requires the Secretary of the Interior and Interior agencies, including Reclamation, “to protect, mitigate adverse impacts to, and improve the values for which Grand Canyon National Park and Glen Canyon National Recreation Area were established, including, but not limited to natural and cultural values and visitor use."  

The Bureau of Reclamation’s current activities violate federal law, but, more importantly, are destroying one of the most cherished national parks in our country.

For more information:

          Grand Canyon Protection Act (pdf)

          Hartford Courant editorial on dam release experiment (pdf)

          Associated Press story on intimidation of NPS (pdf)

          Grand Canyon Trust scoping comments on the Long-term Experimental Plan EIS  (pdf)

          Glen Canyon Dam Adaptive Management Program - Strategic Plan   (pdf)

          Re-opening Glen Canyon's floodgates, High Country News, 7/8/02

          Land Letter News Story on ESA litigation   (Microsoft Word Doc)

          Grand Canyon Trust's full CRMP comment letter to GCNP Superintendent Alston (10/30/2002) (pdf)

          Comments on Final EIS for the Colorado River Management Plan (Microsoft Word Doc)

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