A plan by the U.S. Bureau of Reclamation to send a flood through the Grand Canyon has drawn numerous questions from Grand Canyon National Park officials, who fear the flooding as proposed would impair park resources.

Next week's staged flood out of the Glen Canyon Dam -- which is proposed to be coupled with higher fall flows out of the dam -- is intended to mimic seasonal surges of the Colorado River that occurred before the dam went into service in 1963. During the proposed high-flow experiment, BuRec would release water from both the power plant and the bypass tubes to a maximum amount of approximately 41,000 cubic feet per second for about 60 hours.

The proposed March 5 flooding would be conducted just once under the current scenario, while the September-October "steady" flows would be repeated for five years.

But strongly worded opposition from both park officials and the Grand Canyon Trust question how carefully BuRec officials developed their flooding strategy and whether it really is intended to benefit the canyon's natural resources. Indeed, Trust officials contend the staged flood is aimed to benefit downstream water users and hydropower interests, not natural resources.

Park Superintendent Steve Martin tells me park researchers support the flooding proposed for next week, but don't believe BuRec should be locking itself into one scenario for the next five years and that their plan should be more science-based. He says he'd prefer a situation where flooding is allowed in the spring on a more regular basis, perhaps every one or two years, depending on sediment conditions.

"The science is saying, if we want to protect the resources of the Grand Canyon, we need to do regular high flows every time the sediment targets are met in the canyon," says Superintendent Martin. "Our concern with the document in the way that it is written, it pretty much locks in this being the only (spring) flow and the only experiment for the next four to six years, and it's just inconsistent with the science and we feel inconsistent with the Grand Canyon Protection Act."

There also seem to be inconsistencies with BuRec's approach to the flooding studies. Even though the Colorado River flows through the heart and soul of the national park, the park was not designated as a "cooperating agency" that would work side-by-side with BuRec in designing the experiments.

"We tried to be included throughout the process but were unable to, so we had to comment during the public comment period as opposed to what would have been a more traditional way of doing it would be for all of us to work together and do it right the first time," said the superintendent. "The only thing that we
can fully understand is that there's concern over including Grand Canyon's resources into the consideration of how the dam is operated.

"This is one of the biggest science programs that's ever been run in a national park, and for them to not include that, when you have a law (the Grand Canyon Protection Act) that's basically compelling you to do it...."

Not only did BuRec not make the park a cooperating agency, but it sent copies of the draft environmental assessment analyzing the proposed flooding to Superintendent Martin on February 7, with a comment deadline of noon the next day. Compounding that problem, BuRec emailed the materials to Superintendent Martin personally, and on February 7 he was on the canyon's West Rim and unable to receive email. As a result, the park's formal comments weren't delivered until February 19.

Randy Peterson, BuRec's contact person for the Upper Colorado Region, did not immediately return a phone call Wednesday for comment on the mounting controversy.

In his comments, which spanned 7 pages (attached below), Superintendent Martin lists nearly a dozen "key concerns" with BuRec's plan. He then picks it apart section by section.

"Analysis of the draft Environmental Assessment and proposed action indicates these measures would likely result in impairment of resources of Grand Canyon National Park," writes the superintendent. "The EA as written appears to conflict with NPS 2006 Management Policies, may not be consistent with CEQ (Council of Environmental Quality) guidelines, and is significantly in conflict with our understanding of the science and inconsistent with the intent of the grand Canyon Protection Act and the 1996 ROD (Record of Decision on operation of the Glen Canyon Dam)."

Later in his letter Superintendent Martin claims that "the EA does not clearly express the purpose and need, proposed action, or how the addition of steady flow periods articulates with the science plan."

Grand Canyon Trust officials (see attachment below) claim the EA is "deficient in many ways" and violates the National Environmental Policy Act. "... the EA itself is incomplete, inaccurate, self-contradictory, and poorly supported," the group charges in its comments on the EA.

The Grand Canyon Protection Act passed by Congress in 1992 directed the Interior Department to protect the resources of the canyon by ensuring that operation of the dam be "secondary to the health of the Grand Canyon ecosystem." The problem, you see, is that the dam traps sand that normally would be pushed downstream during seasonal runoff and form sandbars and bolster beaches.

With hopes of remedying that problem federal officials turned to staging floods -- first in 1996 and again in 2004 -- through the canyon to see if Mother Nature could be copied. Benefiting from this would be the river's native fishes, particularly the humpback chub, whose young rely on calm pools that sandbars would create. (According to the Glen Canyon Institute, "the Colorado Pikeminnow, and the Bonytail Chub have been wiped out of the Colorado River in the Grand Canyon because of Glen Canyon Dam.")

Which brings us to the latest flooding of the canyon. Some scientists believe this year's flood will be more beneficial than either of the previous two because there's more sand in the river corridor now than there was previously. Sand supplies in the river, they say, are at a 10-year high with a volume about three times greater than the volume available in 2004 due to tributary inflows below the dam over the past 16 months.

But park and Grand Canyon Trust officials and researchers say BuRec did not clearly think out its flooding scenario and its impact on the river's fisheries.

"Given that one of the primary concerns of the experimental flows was to provide further evidence and understanding of protected aquatic resources, the preferred alternative must address how the action will address Endangered Species Act concerns, most specifically the biological assessment/opinion for the humpback chub," wrote Superintendent Martin. "The plan should state how the actions are being instituted to improve conditions for the chub in the system and how the conservation measures will be incorporated into the DOI (Department of Interior) decision. There needs to be a commitment as part of the implementation of this 5-year program to fund the conservation measures as part of the experimental program.

"The plan should include targets or desired future conditions so that measurements can be made through the research and science program on the effectiveness of the action," he added. "Nowhere in the document are measures of success (or failure) articulated. These conditions need to be clearly stated so that the (Interior) Secretary will know the value of his action."

At the Trust, analysts questioned why BuRec planned high releases from the dam in September and October as opposed to August.

"We find the comments in the EA regarding the timing of the steady flows to be misleading. The EA states, 'The timing of fall steady flows follows young-of-the-year emergence of humpback chub from the Little Colorado River into the mainstream.' However, to test the effects of steady flows on rearing habitat for young-of-the-year humpback chub, (BuRec) must provide the needed habitat conditions when young-of-year are emerging from the Little Colorado River, not following their emergence," the group said.

"By September, it is likely that the vast majority of young-of-year from the Little Colorado River will have already migrated into the mainstream and perished in the cold, fluctuating water. Because the majority of post-larval humpback chub probably migrate into the mainstream during monsoonal floods in August, a legitimate test of the effects of steady flows on humpback chub rearing must begin by August at the very latest."

At the park's science center, Martha Hahn believes enough flooding experiments have been done and it's time to arrive at a plan for regulating flows through the canyon to reflect the river's life before the dam went in.

"At some point we're going to have to draw a line in the sand and say this is the best way to manage the dam and manage resources in the Grand Canyon," Ranger Hahn told the Arizona Republic in a story that ran earlier this week. "We can't continue to go on and on just researching. We have to make a decision. We really are losing valuable resources."

To that point, Superintendent Martin questions whether research conducted during the past decade even played a role in BuRec's proposed flood strategy.

"Results of research over the past 10 years need to be utilized and cited to support the creation of action alternatives and impact analyses," he wrote. "The citations in the EA are limited and dated, and personal communications should not be the basis for such important decisions. It is not apparent where the $80 million in research, conducted over the last 10 years, has been used in this decision-making process. Our analysis shows that this document is not consistent with current best information."