National Park Service Is Under an Environmental Assessment focusing on Non-Native Aquatic Species Management

Comments by Trout Unlimited and International Federation of Fly Fishers

Since 1964, with the completion of the Glen Canyon Dam, the Lees Ferry tailwater has hosted a recreational trout fishery that has grown in importance and reputation locally, regionally, nationally, and internationally.  Anglers from around the world travel to Lees Ferry to fish for high quality rainbow trout in the large, clear, swift-flowing Colorado River as it winds its way through the lower, scenic segment of Glen Canyon. This blue ribbon recreational sport fishery has also become a financial and economic mainstay for the small community of Marble Canyon and Coconino County, supporting fishing guide services, hotels, restaurants, fishing and outdoor recreation equipment and supplies, and visitor services.  

Lees Ferry EntranceWe the undersigned are writing to provide comments on the on the National Park Service’s (NPS) Environmental Assessment (EA) for an Expanded Non‐native Aquatic Species Management Plan in Grand Canyon National Park and Glen Canyon National Recreation Area below Glen Canyon Dam.

 In September 2017, based on a unanimous recommendation from the Glen Canyon Dam Adaptive Management Work Group, a Brown Trout Workshop was conducted specifically to inform the scope and direction of brown trout control and management in the Colorado River below Glen Canyon Dam.  The final workshop report has yet to be finalized and made available to help inform our comments on the appropriate scope of the EA.  We understand that the report is scheduled for finalization in January 2018.  As such, scoping comment on the EA should be extended until the results of the workshop are finalized and available to stakeholders and the public for review.  

January 8, 2016 public review draft of the Glen Canyon Dam Long Term Experimental and Management Plan EIS have been coordinated with the recreational fishing representatives on the Glen Canyon Dam Adaptive Management Work Group who will be providing separate, more detailed comments and recommendations.

As the recreational fishing stakeholder representatives for the Glen Canyon Dam (GCD) Adaptive Management Program we appreciate the opportunity to comment on the October 2016 Glen Canyon Dam Long Term Experimental and Management Plan (LTEMP) Final Environmental Impact Statement (FEIS).   We understand that these comments will not be incorporated into the FEIS, but will be made part of the public record and considered in the preparation of the Record of Decision.

Decisions in the LTEMP FEIS will have a determinative impact on the quality of the Lee Ferry trout fishery, the welfare of the local community, and the regional economic benefits tied to the fishery.  Presently the fishery is struggling with depressed catch rates and declining angler use and satisfaction.  The best available science suggests the quality and stability of the Lees Ferry trout fishery and the viability of local businesses is directly related to GCD operations.

All of the comments below were submitted previously in our comments on the draft EIS but were not addressed in the FEIS.  Please note that these comments and concerns are supported by scores of angling and sportsman groups (representing hundreds of thousands of members), and local businesses and fishing guides.  

Lees Ferry & River Map1.    We appreciate the inclusion of food base enhance flows in the FEIS.  Given that an improved aquatic food base will benefit a variety of biological resources (e.g., native fish, riparian dependent wildlife species, the Lees Ferry trout fishery) priority should be given in the Record of Decision to testing of the food base enhancement flows very early in the 20-year implementation process.

2.    The Arizona Game and Fish Department (AGFD) is the management agency with primary statutory responsibility for resident fish and wildlife in the State of Arizona.  In September 2015, AGFD approved its Fisheries Management Plan, Colorado River-Lees Ferry 2015-2025 (Plan). The goal of the Plan is to maintain and enhance a Blue Ribbon rainbow trout fishery at Lees Ferry that does not adversely affect the native aquatic community in Grand Canyon National Park.  We find it unacceptable that relevant objectives and adaptive management strategies from the Plan were not included in the FEIS.  

3.    Of all the resources values affected by Glen Canyon Dam operations, the FEIS gives priority consideration to just three:  maintaining or enhancing hydropower, further enhancing native fish (even though native fish, including the humpback chub, are currently thriving), and sand conservation/beach building.  Overall, while we appreciate that some of our recommended language was adopted, the FEIS continues to treat the in Lees Ferry trout fishery primarily as a problem for native fish that must be addressed, not as a valued resource.  For example, FEIS states that high flow experiments are being carried out exclusively to conserve sand and build beaches.  The use of high flows as a tool to restore ecosystem processes and benefit the trout fish, the aquatic food base, and riparian habitats is largely ignored. We believe the HFE protocol should be designed to achieve multiple resource objectives, not just build beaches.

Lake Powell Inflow4.    We recognize that over recruitment of young rainbow trout, which has been observed in the past, can adversely impact the quality and stability of the Lees Ferry trout fishery and may increase downstream migration of trout.  As such, we support the testing of Trout Management Flows (TMF) as provided for in the FEIS.  However, the FEIS provides almost no discussion of how TMFs will be used as a tool to help improve the quality and stability of the trout fishery.  We support testing of TMF’s only when there is an observed over-abundance of young of the year rainbow trout in Lee Ferry.  We strongly object to language in the FEIS that allows for initial testing the TMF early in the implementation process even if the Lees Ferry trout fishery is suffering or there is not an observed over-abundance of young rainbow trout in the river (see FEIS pages 2-63/64).

5.    At a time when the effects of repeated fall high flow experiments (HFE) on the aquatic food base and the Lees Ferry trout fishery are inconclusive, we believe it is inappropriate to extend the duration fall HFE’s from 4 up to 10 days in length until the impacts to the aquatic food base, native fish, rainbow trout, and invasive species in both Glen and Marble canyons are more fully understood.

Lees Ferry anglers, guides, and businesses are fully united in their support of these comments on the FEIS.  Our sincere hope and expectation is that these comments and concerns will be addressed in the Record of Decision.

Thank you.  
Sincerely,

John Jordan                        
AMWG Representative, TU and IFFF

John Hamill
AMWG alternate, TU, IFFF, and the
Theodore Roosevelt Conservation Partnership

Chris Budwig
TWG Representative, TU and IFFF

Joe Miller
TWG alternate, TU and IFFF

cc      Secretary’s Designee, GCD AMP
Superintendent, Grand Canyon National Park
Superintendent, Glen Canyon National Recreation Area
Regional Director, Upper Colorado River Region, Bureau of Reclamation
Director, Arizona Game and Fish Department
Senator Jeff Flake
Senator John McCain
Congresswoman Ann Kirkpartick

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