    Bureau of Reclamation: An Assessment of the Environmental Impact
    Statement on the Operations of the Glen Canyon Dam (Chapter Report,
    10/02/96, GAO/RCED-97-12).

    Since the Glen Canyon Dam, located in northern Arizona, was completed by
    the Bureau of Reclamation in 1963, it has been used to generate power
    during periods of high demand--commonly known as peaking power. The
    fluctuating releases of water associated with the dam's peaking power
    operations have raised concerns about the harmful effects such flows
    have on downstream areas, particularly the Grand Canyon. In 1989, the
    Bureau of Reclamation was directed to prepare an environmental impact
    statement that would reevaluate the Glen Canyon Dam's operations. The
    purpose of the reevaluation was to determine options for operating the
    dam that would minimize the harmful effects on the downstream
    environmental and recreational resources, as well as on Native American
    interests in the Glen and Grand canyons, while still allowing the dam to
    produce hydropower. The Bureau issued its final environmental impact
    statement in March 1995. This report examines (1) whether the Bureau's
    impact determinations were reasonable and (2) what concerns still exist
    about the Glen Canyon Dam's final environmental impact statement.

    --------------------------- Indexing Terms -----------------------------

     REPORTNUM:  RCED-97-12
         TITLE:  Bureau of Reclamation: An Assessment of the Environmental
                 Impact Statement on the Operations of the Glen
                 Canyon Dam
          DATE:  10/02/96
       SUBJECT:  Dams
                 Endangered species
                 Environmental impact statements
                 Flood control
                 Fishes
                 Wildlife conservation
                 Environmental research
                 Environmental policies
                 Hydroelectric energy
                 Water supply management
    IDENTIFIER:  Grand Canyon National Park (AZ)
                 Colorado
                 Colorado River Basin
                 Colorado River Storage Project
                 Bureau of Reclamation Adaptive Management Program
                 Wyoming
                 Salt River Project (AZ)
                 Lake Powell (AZ/NV)
                 Bureau of Reclamation Colorado River Simulation System
                 Glen Canyon Dam (AZ)
                 Arizona
                 Nevada
                 New Mexico
                 Utah
                 California
                 Glen Canyon National Recreation Area (AZ)

    ******************************************************************
    ** This file contains an ASCII representation of the text of a  **
    ** GAO report.  Delineations within the text indicating chapter **
    ** titles, headings, and bullets are preserved.  Major          **
    ** divisions and subdivisions of the text, such as Chapters,    **
    ** Sections, and Appendixes, are identified by double and       **
    ** single lines.  The numbers on the right end of these lines   **
    ** indicate the position of each of the subsections in the      **
    ** document outline.  These numbers do NOT correspond with the  **
    ** page numbers of the printed product.                         **
    **                                                              **
    ** No attempt has been made to display graphic images, although **
    ** figure captions are reproduced.  Tables are included, but    **
    ** may not resemble those in the printed version.               **
    **                                                              **
    ** Please see the PDF (Portable Document Format) file, when     **
    ** available, for a complete electronic file of the printed     **
    ** document's contents.                                         **
    **                                                              **
    ** A printed copy of this report may be obtained from the GAO   **
    ** Document Distribution Center.  For further details, please   **
    ** send an e-mail message to:                                   **
    **                                                              **
    **                                            **
    **                                                              **
    ** with the message 'info' in the body.                         **
    ******************************************************************

    Cover
    ================================================================ COVER

    Report to Congressional Committees

    October 1996

    BUREAU OF RECLAMATION - AN
    ASSESSMENT OF THE ENVIRONMENTAL
    IMPACT STATEMENT ON THE OPERATIONS
    OF THE GLEN CANYON DAM

    GAO/RCED-97-12

    Glen Canyon Dam's Environmental Impact Statement

    (140896)

    Abbreviations
    =============================================================== ABBREV

      ABT - Aquatic Biology Team
      cfs - cubic feet per second
      CROD - Contract Rate of Delivery
      CRSP - Colorado River Storage Project
      CRSS - Colorado River Simulation System
      CVM - contingent valuation method
      EGEAS - Electronic Generation Expansion Analysis System
      EIS - environmental impact statement
      Elfin - Electric Utility Financial and Production Cost Model
      EPA - U.S.  Environmental Protection Agency
      FWCA - Fish and Wildlife Coordination Act
      FWS - U.S.  Fish and Wildlife Service
      GCES - Glen Canyon Environmental Studies
      NEPA - National Environmental Policy Act
      NOAA - National Oceanic and Atmospheric Administration
      SLCA/IP - Salt Lake City Area/Integrated Projects
      WAPA - Western Area Power Administration

    Letter
    =============================================================== LETTER

    B-272927

    October 2, 1996

    The Honorable Frank Murkowski
    Chairman
    The Honorable J.  Bennett Johnston
    Ranking Minority Member
    Committee on Energy and Natural Resources
    United States Senate

    The Honorable Don Young
    Chairman
    The Honorable George Miller
    Ranking Minority Member
    Committee on Resources
    House of Representatives

    This report responds to subsection 1804(b) of the Grand Canyon
    Protection Act of 1992 (title XVIII of P.L.  102-575), which required
    GAO to audit the Bureau of Reclamation's final environmental impact
    statement on the operations of the Glen Canyon Dam.  The report
    discusses (1) whether Reclamation's determination of the impact of
    various dam-operating alternatives on selected resources was
    reasonable and (2) what, if any, concerns still exist on the part of
    key interested parties about the final impact statement.

    We are providing a copy of this report to the Secretary of the
    Interior, the Assistant Secretary for Water and Power, and the
    Commissioner of the Bureau of Reclamation.  We will also make copies
    available to others upon request.

    This report was prepared under the direction of Victor S.  Rezendes,
    Director, Energy, Resources, and Science Issues, who can be reached
    at (202) 512-3841 if you or your staff have any questions.  Major
    contributors to this report are listed in appendix XIII.

    Keith O.  Fultz
    Assistant Comptroller General

    EXECUTIVE SUMMARY
    ============================================================ Chapter 0

       PURPOSE
    ---------------------------------------------------------- Chapter 0:1

    Since the Glen Canyon Dam, located in Page, Arizona, was completed by
    the Bureau of Reclamation in 1963, it has been used to generate power
    during periods of high demand, commonly known as peaking power.  The
    fluctuating releases of water associated with the dam's peaking power
    operations have caused concerns about the detrimental effects such
    flows have on downstream resources, particularly those located in the
    Grand Canyon.  In response to these concerns, the Secretary of the
    Interior, in July 1989, directed the Bureau of Reclamation to prepare
    an environmental impact statement that would reevaluate the Glen
    Canyon Dam's operations.  The purpose of the reevaluation was to
    determine specific options for operating the dam that could minimize
    the adverse impacts on the downstream environmental and recreational
    resources, as well as on Native American interests in the Glen and
    Grand canyons, while still producing hydropower.

       Figure 1:  Location of the Glen
       Canyon Dam

       (See figure in printed
       edition.)

    Source:  Bureau of Reclamation.

    In October 1992, the Congress enacted the Grand Canyon Protection Act
    of 1992 (title XVIII of P.L.  102-575), which required the Secretary
    of the Interior to complete the environmental impact statement by
    October 30, 1994.  The act also required that GAO audit the costs and
    benefits of the various operating alternatives identified in the
    final environmental impact statement.  In preparing the statement,
    Reclamation studied the potential impact of various flow alternatives
    on selected resources.  Reclamation reported the results of these
    studies in the final environmental impact statement on March 21,
    1995.  As discussed with the responsible congressional committees,
    for the purpose of this audit, GAO examined (1) whether Reclamation's
    impact determinations were reasonable and (2) what, if any, concerns
    still exist about the Glen Canyon Dam's final environmental impact
    statement.  The act also requires that on the basis of the findings,
    conclusions, and recommendations made in the environmental impact
    statement and the GAO audit report, the Secretary is to adopt
    criteria and operating plans for the dam.

       BACKGROUND
    ---------------------------------------------------------- Chapter 0:2

    Before the construction of the Glen Canyon Dam, the Colorado River's
    sediment-laden flows fluctuated dramatically during different seasons
    of the year.  Annual daily flows of greater than 80,000 cubic feet
    per second were common during the spring runoff.  In contrast, flows
    of less than 3,000 cubic feet per second were typical throughout the
    late summer, fall, and winter.  Water temperatures ranged from near
    freezing in the winter to more than 80 degrees Fahrenheit in the
    summer.  The construction of the Glen Canyon Dam altered the natural
    dynamics of the Colorado River corridor through the Glen and Grand
    canyons.  The dam replaced the dramatic seasonal flow variations with
    significant daily fluctuations, greatly reduced the amount of
    sediment in the water, and resulted in nearly constant water release
    temperatures of about 46 degrees Fahrenheit.

    As early as 1982, the Secretary of the Interior initiated the Glen
    Canyon Environmental Studies of the effects of the dam.  These
    studies were led by Reclamation and conducted by a number of
    different agencies.  In 1989, the Secretary designated Reclamation as
    the lead agency in preparing an environmental impact statement.
    Other agencies and individuals participated in these efforts,
    including federal and state resource agencies, Indian tribes, private
    consultants, universities, and river guides.  To protect the
    downstream resources until the completion of the impact statement and
    the adoption of a new operating plan for the dam, in November 1991
    Reclamation implemented interim operating criteria.  The interim
    operating criteria reduced the maximum peak releases and daily
    fluctuations.  With the passage of the Grand Canyon Protection Act of
    1992, the Congress required that the Glen Canyon Dam be operated to
    protect and restore the downstream resources of the Grand Canyon
    National Park and the Glen Canyon National Recreational Area.

    The National Environmental Policy Act of 1969 (42 U.S.C.  4321 et
    seq.) requires that a detailed environmental impact statement be
    prepared for every major federal action that may significantly affect
    the quality of the human environment.  The act and its implementing
    regulations set forth the requirements for preparing an impact
    statement.  Among other things, a statement must (1) address the
    purpose of and need for the action, (2) describe the environment that
    will be affected, (3) identify alternatives to the proposed action,
    (4) present the environmental impacts of the proposed action
    (including the direct, indirect, and cumulative impacts), and (5)
    identify the agency's preferred alternative.  The act does not
    require, and Reclamation did not perform, a cost and benefit analysis
    of the proposed action.

    In preparing the environmental impact statement for the operation of
    the Glen Canyon Dam, Reclamation identified 11 resources affected by
    the dam's operations to be analyzed in detail:  water, sediment,
    fish, vegetation, wildlife and habitat, endangered and other
    special-status species, cultural resources, air quality, recreation,
    hydropower, and non-use value.  (Non-use values have been defined as
    those values that people may receive from the knowledge that such
    things as rare plants and unspoiled natural environments exist, even
    if people do not consume or use these goods directly.)

    In addition, the impact statement identified nine alternative
    operational scenarios to be studied in detail.  These alternatives
    can be divided into three descriptive categories:  unrestricted
    fluctuating flows (two alternatives, including the no-action
    alternative); restricted fluctuating flows (four alternatives); and
    steady flows (three alternatives).

    In the final impact statement, Reclamation recommended the Modified
    Low Fluctuating Flow as the preferred alternative.  This alternative
    was developed to reduce daily flow fluctuations well below the dam's
    previous operating levels and to provide periodic high, steady
    releases of short duration; the goal of this alternative was to
    protect or enhance downstream resources while allowing limited
    flexibility for power operations.

       RESULTS IN BRIEF
    ---------------------------------------------------------- Chapter 0:3

    In general, Reclamation used appropriate methodologies and the best
    available information in determining the potential impact of the
    dam's various flow alternatives on selected resources.  GAO
    identified some shortcomings and controversy in Reclamation's
    application of certain methodologies, and some of the data that
    Reclamation used in making its impact determinations were dated,
    preliminary, or incomplete.  These limitations, combined with the
    inherent uncertainty associated with making forecasts, reduces the
    precision of the impacts contained in the statement, and some
    uncertainty, such as the impact of steady flows on fish resources,
    remains.  Nonetheless, according to GAO's analysis and the opinions
    of experts, these limitations are not significant enough to alter the
    relative ranking of the flow alternatives nor render the final
    environmental impact statement unusable as a decision-making
    document.  Furthermore, Reclamation recognizes that uncertainties
    still exist.  To address these concerns, Reclamation intends to
    initiate a process of "adaptive management" that would provide for
    long-term monitoring and research to measure the actual effects of
    the selected alternative.  The results of this effort would form the
    basis for possible future modifications of the dam's operations.

    Many of the key interested parties affected by the Glen Canyon Dam's
    environmental impact statement support the process used by
    Reclamation to develop the impact statement as well as the
    implementation of the preferred alternative.  However, while
    expressing their support, some interested parties raised specific
    concerns that still exist about the final environmental impact
    statement, including (1) the manner in which compliance with the
    Endangered Species Act will be achieved, (2) the economic impact of
    reducing the Glen Canyon Dam's hydroelectric power capacity, (3) the
    consideration of other possible causes of adverse downstream impacts,
    (4) the difficulties in measuring the impact of changes in the dam's
    operations, (5) the adequacy of the measures for reducing the
    frequency of unscheduled floods, (6) the need for installing
    multilevel water intake structures (selective withdrawal structures)
    on the dam to raise the downstream water temperature, and (7) the
    implementation of the Adaptive Management Program.

       PRINCIPAL FINDINGS
    ---------------------------------------------------------- Chapter 0:4

          IMPACT DETERMINATIONS ARE
          USABLE FOR DECISION-MAKING
    -------------------------------------------------------- Chapter 0:4.1

    In preparing the environmental impact statement, Reclamation used a
    variety of methodologies and data sources to study the impact of the
    various dam flow alternatives on hydropower, non-use values and other
    resources located below the dam.  Generally, GAO found the
    methodologies used to be reasonable and appropriate.  For example,
    the power analysis was conducted by a committee of specialists
    representing the federal government, the utility industry, private
    contractors, and the environmental community.  This committee used
    utility-specific data and state-of-the-art simulation models to
    estimate the economic impact of the alternative dam flows on large
    regional utilities.

    In assessing Reclamation's implementation of the various
    methodologies, GAO did note several shortcomings and controversy over
    the methodology used to estimate non-use values.  For example, in the
    hydropower analysis, Reclamation's assumptions do not explicitly
    include the mitigating effect of higher electricity prices on
    electricity demand (price elasticity).  GAO also found that
    Reclamation's assumptions about future natural gas prices were
    relatively high and that two computational errors were made during
    the third phase of the power analysis.  These limitations suggest
    that the estimated economic impacts for power are subject to
    uncertainty.  However, Reclamation and many experts associated with
    the process do not believe that these limitations make the results of
    the analysis unusable.  For example, an association that represents
    the affected power utilities, which has maintained throughout the
    power studies process that the impact statement understates the costs
    to the power system, does not believe that Reclamation's cost
    estimate is understated by a large magnitude.  To quantify the impact
    of various dam flow alternatives on recreation and non-use value,
    Reclamation used a methodology called contingent valuation.  The use
    of contingent valuation studies, which rely on surveys to elicit
    information from consumers to estimate how much they would be willing
    to pay for something is controversial.  Although contingent valuation
    is currently the only known approach for estimating non-use values,
    some prominent economists question whether this methodology can
    accurately elicit the value consumers place on non-use goods.
    However, many economists and survey researchers working in the
    natural resource and environmental areas have developed and used this
    methodology.  Although these shortcomings affect the estimates for
    the alternatives, it is unlikely that they would alter the relative
    ranking of the fluctuating and steady flow alternatives.

    GAO also found that Reclamation generally used the best available
    data in making its impact determinations.  For example, for
    information on cultural resources and properties, Reclamation went
    beyond the federal requirements for the development of an impact
    statement by performing assessments of all previously identified
    archeological sites within the Colorado River corridor in the Glen
    and Grand canyons.  According to many experts, when completed, this
    effort generated the best and most current scientific information
    available.  However, GAO also found some limitations in the data used
    in the development of the impact statement.  Specifically, some of
    the information was dated, some was preliminary, and some was
    incomplete.  For example, to assess the economic impact of the
    alternative flows on recreational activities, Reclamation used a 1985
    survey of a sample of anglers, day-rafters, and white-water boaters
    that asked about their experiences on the Colorado River and what
    effect, if any, different streamflows would have on their
    recreational experiences.  Although Reclamation updated some of the
    data to 1991, it acknowledges that the survey information is
    generally dated.  The National Research Council generally found the
    analysis to be adequate.

    Many of the results of the sediment studies at Glen Canyon were
    preliminary, were in draft form, and had not been published at the
    time that the draft or even the final impact statement was written.
    However, according to the researchers that GAO interviewed, no new or
    additional information on sediment impacts has been obtained that
    would alter the information or conclusions presented in the final
    impact statement.

    Finally, the information on some resources is incomplete, as is the
    knowledge of how changes in the Glen Canyon Dam's operations will
    affect those resources.  For example, in part because of incomplete
    data, the experts' opinions vary on the interactions between native
    and nonnative fish and how operational changes would affect these
    interactions and, ultimately, fish populations.  In its final
    biological opinion, the U.  S.  Fish and Wildlife Service stated that
    Reclamation's preferred alternative for the dam's future operations,
    the Modified Low Fluctuating Flow alternative, is likely to
    jeopardize the existence of two native endangered fish species (the
    humpback chub and the razorback sucker).  The Service identified
    actions that would modify the preferred alternative with seasonally
    adjusted steady flows.  The Service and Reclamation agreed to
    categorize these flows as experimental, or research flows.  The
    purpose of this research is to study the effects of steady flows on
    endangered and native fish.

    Reclamation recognizes that many uncertainties about the actual
    impact of the various flow alternatives still exist.  To address such
    concerns, Reclamation intends to initiate a process of "adaptive
    management" that would provide for long-term monitoring, research,
    and measurement of the effects of the selected alternative.  The
    results of this effort would form the basis for future modifications
    of the dam's operations.

          MOST KEY PARTIES SUPPORT THE
          PREFERRED ALTERNATIVE, BUT
          SOME CONCERNS REMAIN
    -------------------------------------------------------- Chapter 0:4.2

    The process for selecting a preferred alternative for the future
    operations of the Glen Canyon Dam considered many factors, such as
    protecting natural and cultural resources and maintaining hydropower
    generating capability, and involved many parties with diverse
    interests.  Reclamation's goal was to select an alternative
    dam-operating plan that would permit downstream resources to recover
    to acceptable long-term management levels while maintaining some
    level of hydropower flexibility.  Reclamation believes that it
    accomplished this goal by selecting the Modified Low Fluctuating Flow
    as the preferred alternative.  According to Reclamation, this flow
    alternative was developed to reduce daily flow fluctuations well
    below the dam's historic operations and to provide periodic high,
    steady water releases of short duration with the goal of protecting
    or enhancing the downstream resources while allowing limited
    flexibility for power operations.  This alternative has the same
    annual and essentially the same monthly water releases as the dam's
    historic operations but would restrict daily and hourly water
    releases more than previously.

    GAO judgmentally selected 37 key interested parties and surveyed them
    on whether they supported Reclamation's preferred alternative and
    whether they have any remaining concerns about implementing this
    alternative as the future operating plan for the Glen Canyon Dam.
    GAO's judgmental sample consisted of all of the organizations and
    individuals that Reclamation identified as providing significant
    comments on the draft impact statement, any organizations that were
    considered cooperating agencies in the impact statement's development
    process, and other key interested parties.  Over 83 percent (25 of
    30) of the respondents to GAO's survey supported the preferred
    alternative, and many expressed support for the process used by
    Reclamation to develop the impact statement.  Of the five remaining
    respondents, three stated that they had no position on the issue,
    while two, the San Juan Southern Paiute Tribe and the Grand Canyon
    River Guides, believed that the current interim operating criteria
    would be more protective of resources and, therefore, more consistent
    with the intent of the Grand Canyon Protection Act.

    Other interested parties, although supporting the preferred
    alternative, believed that several areas of concern still remain.
    For example, one organization stated that the final impact statement
    assumes that the dam's operations are the only cause of the impacts
    on downstream resources and, therefore, that changing the dam's
    operations is the only technique available for managing and enhancing
    those resources.  The organization noted other causes of downstream
    impacts, including the introduction of nonnative fish and human
    usage.  Still other organizations believed that there is a potential
    for negative impacts that will be difficult to measure because,
    between the draft and the final impact statement, Reclamation revised
    the preferred alternative to simultaneously increase two of the dam's
    operating parameters:  the maximum daily peak releases and the upramp
    rate (the hourly rate of increase).  Others stated that they were
    concerned about flood protection measures.  Also, concerns were
    expressed about the future implementation of Reclamation's Adaptive
    Management Program, including its continued monitoring and research
    efforts.

       RECOMMENDATIONS
    ---------------------------------------------------------- Chapter 0:5

    GAO is making no recommendations in this report.

       AGENCY COMMENTS
    ---------------------------------------------------------- Chapter 0:6

    GAO provided copies of a draft of this report to the Department of
    the Interior for its review and comment.  Interior generally agreed
    with the information presented in the report and stated that they
    were impressed with the quality of the product developed by the audit
    team.  Interior also provided several technical clarifications to the
    draft, which have been incorporated into the report as appropriate.
    Interior's comments and GAO's responses are included in appendix XII.

    INTRODUCTION
    ============================================================ Chapter 1

    The Glen Canyon Dam was completed by the Bureau of Reclamation in
    1963 as a multipurpose facility.  It is the key feature and major
    storage unit of the Colorado River Storage Project.  The Colorado
    River Storage Project was authorized in 1956 to develop and use the
    water resources in the Upper Colorado River Basin.  The operations of
    the Glen Canyon Dam and its reservoir, Lake Powell, enable the
    Colorado River Storage Project to fulfill the downstream water
    release requirements while the runoff from the Upper Basin is stored
    and used for irrigation, recreation, and municipal and industrial
    purposes.

    The powerplant at the Glen Canyon Dam has been used primarily for
    generating power during high-demand periods (peaking power).  The
    fluctuating releases of water associated with peaking power
    operations have caused concern among federal, state, and tribal
    resource management agencies; river users who fish in Glen Canyon or
    take white-water raft trips in the Grand Canyon; and Native American
    and environmental groups, in connection with the detrimental effects
    that such water releases have on the cultural resources and the
    downstream plants, animals, and their habitats.

       OPERATION OF THE GLEN CANYON
       DAM'S POWERPLANT
    ---------------------------------------------------------- Chapter 1:1

    The Glen Canyon Dam powerplant has eight generators with a maximum
    combined capacity of 1,288,000 kilowatts at a 95-percent power
    factor.  The maximum combined discharge capacity of the eight
    turbines is approximately 33,200 cubic feet per second (cfs) when
    Lake Powell is full; however, Reclamation has limited such releases
    to 31,500 cfs.  Fluctuations within a day have typically ranged from
    12,000 cfs in October to about 16,000 cfs in January and August.
    Although water can be released from the dam through the powerplant,
    the outlet works, or the spillways, discharging water through the
    powerplant's turbines is the preferred method because electricity and
    its associated revenue can be produced.  The power generated by the
    Glen Canyon Dam is marketed principally in a six-state area--Arizona,
    Colorado, Nevada, New Mexico, Utah, and Wyoming.  Figure 1.1 shows
    the various release capacities for the Glen Canyon Dam.

       Figure 1.1:  Water Release
       Capacities of the Glen Canyon
       Dam's Powerplant, Outlet Works,
       and Spillways

       (See figure in printed
       edition.)

    Source:  Bureau of Reclamation.

    Historically, the Glen Canyon Dam, as part of the Colorado River
    Storage Project, was operated to produce the greatest amount of firm
    capacity and energy practicable while adhering to the releases
    required under the "Law of the River." The Law of the River--a
    collection of federal and state statutes, compacts, court decisions
    and decrees, federal contracts, a treaty with Mexico, and formally
    determined long-range operating criteria--defines the operation and
    management of the Colorado River.  The operating criteria for the dam
    were established under the "Criteria for Coordinated Long-Range
    Operation of Colorado River Reservoirs" (Long-Range Operating
    Criteria), which include the criteria for annual operations.  The
    Annual Operating Plan, which is prepared under the Long-Range
    Operating Criteria, addresses monthly operations while interagency
    agreements control the dam's hourly operations.

    The annual volume of releases from the dam is based on the water
    inflow to Lake Powell and the remaining space in Lake Powell and Lake
    Mead.  The annual release volumes vary greatly, but all adhere to the
    Long-Range Operating Criteria's objectives of an
    8.23-million-acre-feet\1 minimum annual release and equalized storage
    between the two reservoirs.  From 1968 to 1989, the annual releases
    ranged from 8.23 million acre-feet to 20.4 million acre-feet.  Annual
    releases greater than the minimum were permitted to avoid anticipated
    spills (excess annual releases that cannot be used for project
    purposes) and to equalize storage.  The minimum release occurred in
    about half the years.

    The volume of water released from Lake Powell each month depends on
    the forecasted inflow, existing storage level, monthly storage
    targets, and annual release requirements.  Demands for electrical
    energy, fish and wildlife needs, and recreation needs are also
    considered and accommodated as long as the risk of spilling and
    storage equalization between Lakes Powell and Mead are not affected.
    Power demand is highest during the winter and summer months, and
    recreation needs are highest during the summer.  Therefore,
    higher-volume releases are scheduled during these months whenever
    possible.  Each month during the inflow forecast season (January to
    July), the volume of water to be released for the rest of the year is
    recomputed on the basis of updated streamflow forecast information.
    The Scheduled releases for the remaining months are adjusted to avoid
    anticipated spills and maintain conservation storage in accordance
    with the Long-Range Operating Criteria.

    Hourly releases from the dam are set to reach monthly release
    volumes, to maintain established minimum flow rates, and to follow
    energy demand.  Hourly power operations are most flexible during
    those months with moderate release volumes.  The need to maintain
    minimum flows in the months with low release volumes limits the
    flexibility to accommodate changing hourly power demands.  If the
    reservoir is nearly full and the inflow is extremely high, the
    monthly releases are scheduled at or near the maximum capacity most
    of the time, again leaving little flexibility for the hourly releases
    to change in response to power demand.

    To the extent possible, the Glen Canyon Dam follows these guidelines
    in producing hydropower:

      -- Maximize water releases during the peak energy demand periods,
         generally Monday through Saturday between 7 a.m.  and 11 p.m.,

      -- Maximize water releases during peak energy demand months and
         minimize during low demand months,

      -- Minimize and, to the extent possible, eliminate powerplant
         bypasses.

    --------------------
    \1 An acre-foot is the amount of water needed to cover 1 acre of land
    to a depth of 1 foot--or about 326,000 gallons.

       GLEN CANYON'S ENVIRONMENTAL
       STUDIES AND ENVIRONMENTAL
       IMPACT STATEMENT
    ---------------------------------------------------------- Chapter 1:2

    Before the construction of the Glen Canyon Dam, the Colorado River's
    sediment-laden flows fluctuated dramatically during different seasons
    of the year.  Flows of greater than 80,000 cfs were common during the
    spring runoff.  In contrast, flows of less than 3,000 cfs were
    typical throughout the late summer, fall, and winter.  Water
    temperatures ranged from near freezing in the winter to more than 80
    degrees Fahrenheit in the summer.  The construction of the Glen
    Canyon Dam altered the natural dynamics of the Colorado River.  The
    dam replaced seasonal flow variations with daily fluctuations,
    greatly reduced the amount of sediment in the river, and resulted in
    nearly constant water release temperatures of about 46 degrees
    Fahrenheit.

    In response to the concerns of federal, state, and tribal agencies
    and the public about the negative effects of the dam's operations, in
    December 1982 the Secretary of the Interior directed Reclamation to
    initiate a series of interagency scientific studies.  These studies
    were to examine the short- and long-term effects of the dam's
    historic, current, and alternative operations on the environmental
    and recreational resources of the Glen and Grand canyons.  The
    studies became known as phase I of the Glen Canyon Environmental
    Studies.  From 1982 through 1987, 39 technical reports were prepared
    evaluating terrestrial biology, aquatic biology, sediment and
    hydrology, recreation, and the dam's operations.  However, no studies
    were conducted on the economic impact to hydropower from changes in
    the dam's operations.  According to Reclamation, of primary
    importance in the Glen Canyon Environmental Studies was the research
    connected with endangered fish.  The existence and operations of the
    dam were believed to be important factors involved in the extinction
    of two fish species (the Colorado squawfish and bonytails) from the
    river corridor.  The dam and its operations were also considered to
    present survival problems for the existing populations of the
    humpback chub and razorback sucker as well as other native fish
    species.  Therefore, according to Reclamation, the biological opinion
    issued by the U.S.  Fish and Wildlife Service in 1994 was an
    important factor in the ultimate formulation of the preferred
    alternative in the environmental impact statement (EIS).

    The Glen Canyon Environmental Studies technical reports were
    concurrently reviewed by the National Research Council and the
    Executive Review Committee.  The Executive Review Committee was made
    up of policy-level representatives from Reclamation, the National
    Park Service, the U.S.  Fish and Wildlife Service, the Department of
    the Interior's Office of Environmental Policy and Compliance, and the
    Western Area Power Administration.  This Committee then prepared a
    report\2 in January 1988 on the findings and conclusions of phase I
    of the Glen Canyon Environmental Studies and made recommendations and
    suggested options for revising the dam's operations.

    In June 1988, phase II of the Glen Canyon Environmental Studies was
    initiated to gather additional data over a 4- to 5-year period on the
    dam's specific operational elements.  Phase II was to further define
    the impacts on the natural environment, public uses associated with
    recreation, cultural resources, and power-generation economics.  At
    the urging of the National Research Council, an entity of the
    National Academy of Sciences, non-use values were incorporated into
    the studies.  "Non-use value" is the term used to describe the
    monetary value that non-users place on the status of the environment.
    For example, the values that people may receive from the knowledge
    that such things as rare plants, animals, and unspoiled natural
    environments exist are defined as non-use values.  A number of
    federal and state resource agencies, Indian tribes, private
    consultants, universities, and river guides participated in phase II
    of the Glen Canyon Environmental Studies.\3 Funding for these studies
    was provided mainly from the revenue derived from the sale of
    electricity generated by the Glen Canyon Dam.

    In July 1989, the Secretary of the Interior decided that Reclamation
    should prepare an environmental impact statement to reevaluate the
    operations of the Glen Canyon Dam.  The purpose of the EIS was to
    determine specific options for operating the dam that could minimize
    the adverse impacts on the downstream environmental and cultural
    resources, as well as on the Native American interests in the Glen
    and Grand canyons, while still producing hydropower.  Reclamation was
    designated by the Secretary to be the lead agency responsible for
    preparing the EIS; other participants were the following cooperating
    agencies:  the Bureau of Indian Affairs, the National Park Service,
    the U.S.  Fish and Wildlife Service, the Western Area Power
    Administration, and the Arizona Game and Fish Department.  In 1989,
    after the EIS process started, Reclamation also made the following
    Native American tribes cooperating agencies:  the Hopi Tribe, the
    Hualapai Tribe, the Navajo Nation, the Pueblo of Zuni, the San Juan
    Southern Paiute Tribe, and the Southern Paiute Consortium.  Officials
    from many of these same agencies and tribes participated in the Glen
    Canyon Environmental Studies, which formed the basis for the analyses
    of alternatives for the EIS.

    The EIS was designed primarily to focus on the Colorado River
    corridor from the Glen Canyon Dam in northwestern Arizona, southward
    through the Glen and Marble canyons and westward through the Grand
    Canyon to Lake Mead.  The map in figure 1.2 shows the area of study
    under the Glen Canyon Environmental Studies and the EIS for the Glen
    Canyon Dam.

       Figure 1.2:  Map of the Study
       Area of the Glen Canyon Dam's
       Environmental Studies and
       Environmental Impact Statement

       (See figure in printed
       edition.)

    Note:  RM - River Mile.

    Source:  Bureau of Reclamation.

    The requirement to prepare an EIS accelerated the scheduled
    completion of the research studies in phase II of the Glen Canyon
    Environmental Studies to provide more timely data for the EIS.  This
    acceleration was accomplished by designing special "research flows,"
    a series of carefully designed discharges of water and data
    collection programs conducted in June 1990 through July 1991.  Each
    research flow lasted 14 days and included 3 days of steady 5,000 cfs
    flows and 11 days of either steady or fluctuating flows.  The
    research flows provided a means to evaluate the short-term responses
    of certain resources to a variety of discharge parameters, including
    minimum and maximum flows, the rate of change in flow, and the range
    of daily fluctuations.

    To protect downstream resources until the completion of the EIS and
    the formal adoption of new operating criteria for the Glen Canyon
    Dam, Reclamation implemented the interim dam operations on November
    1, 1991.  The interim operating criteria were purposely designed to
    be conservative for the protection of natural and cultural resources.
    Specifically, the interim criteria reduced peak water releases from
    the approved maximum of 31,500 cfs to 20,000 cfs; restricted daily
    fluctuations in releases to between 5,000 cfs and 8,000 cfs; and
    restricted the rate of change in releases (ramp rates) to 2,500 cfs
    per hour when increasing and to 1,500 cfs per hour when decreasing.
    While these limitations were imposed, the interim criteria met the
    minimum annual release of 8.23 million acre-feet in accordance with
    the 1970 Long-Range Operating Criteria.  Although the interim
    operating criteria could be modified on the basis of new information,
    they were to remain in effect until the EIS and the Secretary's
    Record of Decision for new operating criteria for the dam were
    completed.

    --------------------
    \2 The Glen Canyon Environmental Studies Final Report, U.S.
    Department of the Interior, 1988.

    \3 Agencies participating in phase II of the Glen Canyon
    Environmental Studies included Reclamation, the National Park
    Service, the Western Area Power Administration, the U.S.  Geological
    Survey, the U.S.  Fish and Wildlife Service, the Hopi Tribe, the
    Hualapai Tribe, the Navajo Nation, the Pueblo of Zuni, the San Juan
    Southern Paiute Tribe, the Southern Paiute Consortium, and the
    Arizona Game and Fish Department.

       GRAND CANYON PROTECTION ACT OF
       1992
    ---------------------------------------------------------- Chapter 1:3

    Subsequent to Reclamation's initiation of the EIS process, on October
    30, 1992, the Congress enacted the Grand Canyon Protection Act of
    1992 (title XVIII of P.L.  102-575).  The act addresses the
    protection of the Grand Canyon National Park, the Glen Canyon
    National Recreational Area, the interim operating criteria for the
    dam until the EIS is completed, long-term monitoring and research,
    and the replacement of lost power from any changes to the dam's
    operation.  The act requires that the Glen Canyon Dam be operated to
    protect, mitigate adverse impacts to, and improve the downstream
    resources of the Grand Canyon National Park and the Glen Canyon
    National Recreational Area.  The act also required the Secretary of
    the Interior to complete a final environmental impact statement for
    the Glen Canyon Dam's operations by October 30, 1994.  Furthermore,
    the act required GAO to audit the costs and benefits of the various
    operating alternatives identified in the final environmental impact
    statement.  On the basis of the findings, conclusions, and
    recommendations made in the EIS, other relevant information, and our
    audit report, the Secretary is to issue a Record of Decision adopting
    future operating criteria and operating plans for the Glen Canyon
    Dam.

       NATIONAL ENVIRONMENTAL POLICY
       ACT
    ---------------------------------------------------------- Chapter 1:4

    The National Environmental Policy Act of 1969 (NEPA) (42 U.S.C.  4321
    et seq.) establishes the national environmental policy and goals for
    protecting, maintaining, and enhancing the environment, and it
    provides a process for implementing these goals within federal
    agencies.  The act requires, among other things, that the applicable
    federal agency prepare a detailed EIS for every major federal action
    that may significantly affect the quality of the human environment.
    The EIS is designed to ensure that important environmental impacts
    will not be overlooked or underestimated before the government
    commits to a proposed action.  The act also established the Council
    on Environmental Quality, which oversees the NEPA process.

    The Council on Environmental Quality's Regulations for Implementing
    the Procedural Provisions of the National Environmental Policy Act
    (40 C.F.R.  1502.4) provide federal agencies with a process for
    determining whether or not to prepare an EIS.  If it is determined
    that an EIS is necessary, regulations require, among other things,
    that the EIS must (1) address the purpose of and need for the action,
    (2) describe the environment that will be affected, (3) identify
    alternatives to the proposed action, (4) present the environmental
    impacts of the proposed action (including the direct, indirect, and
    cumulative impacts), (5) identify any adverse environmental impacts
    that cannot be avoided should the proposed action be implemented, and
    (6) identify any irreversible and irretrievable commitment of
    resources that would occur should the proposed action be implemented.
    The regulations also require each federal agency to identify the
    agency's preferred alternative or alternatives, if one or more
    exists, in the draft and the final EIS.  In addition, before making a
    decision, the responsible agency must solicit comments from the
    public and from other government agencies that may have jurisdiction
    by law or expertise with respect to any environmental impacts.

    Under section 309 of the Clean Air Act, the Environmental Protection
    Agency (EPA) is required to review and publicly comment on the
    environmental impacts of major federal actions, including actions
    that are the subject of a draft or final EIS.  EPA reviews and
    comments on both the adequacy of the analyses and the environmental
    impacts of the proposed action.  If the Administrator, EPA,
    determines that the action is environmentally unsatisfactory from the
    standpoint of the public's health or welfare or environmental
    quality, this determination shall be published and the matter will be
    referred to the Council on Environmental Quality.  If the action
    involves a federal project located at a specific site, the
    appropriate EPA regional office has the jurisdiction and delegated
    responsibility for carrying out the section 309 review and working
    with the proposing federal agency to resolve any problems.  EPA's
    Region IX in San Francisco, California, was the region responsible
    for reviewing the draft and final EIS for the operation of the Glen
    Canyon Dam.

       RECLAMATION'S PROCESS FOR
       COMPLETING THE GLEN CANYON
       DAM'S EIS
    ---------------------------------------------------------- Chapter 1:5

    The preparation of the Operation of Glen Canyon Dam Final
    Environmental Impact Statement was a cooperative effort involving
    Reclamation, the cooperating agencies, the participants in the Glen
    Canyon Environmental Studies program, and the representatives of an
    interagency EIS team.  Although Reclamation was designated to be the
    lead agency responsible for preparing the EIS, its objective was to
    obtain substantial input from these organizations during the
    decision-making process, and its goal was to build a consensus for
    the ultimate decision of recommending a preferred alternative in the
    EIS.

    The group of cooperating agencies, which prior to the development of
    the formal EIS included only federal agencies, was established in
    July 1989.  This group ultimately included representatives from
    Reclamation, the Bureau of Indian Affairs, the Environmental
    Protection Agency, the National Park Service, the U.S.  Fish and
    Wildlife Service, the Western Area Power Administration, the Arizona
    Game and Fish Department, the Hopi Tribe, the Hualapai Tribe, the
    Navajo Nation, the San Juan Southern Paiute Tribe, the Southern
    Paiute Consortium, and the Pueblo of Zuni.  The EIS team was
    established in mid-1990 and included representatives from
    Reclamation, the National Park Service, the U.S.  Fish and Wildlife
    Service, the Western Area Power Administration, the U.S.  Geological
    Survey, the Arizona Game and Fish Department, the Hopi and Hualapai
    Tribes, the Navajo Nation, and a private consulting firm.
    Reclamation charged the EIS team with formulating alternatives for
    operating the dam and assessing their impacts on the environment.
    For resources that were to be studied in detail, subteams were formed
    to make the impact determinations, document their findings, and draft
    that particular section of the EIS.  For the other resources,
    individuals with expertise in a particular field were assigned the
    responsibility for determining the impacts and preparing the
    documentation.  Figure 1.3 shows some of the key dates in the
    preparation of the Glen Canyon Environmental Studies and the EIS.

       Figure 1.3:  Key Dates in the
       Environmental Studies and the
       Environmental Impact Statement
       Processes for the Glen Canyon
       Dam

       (See figure in printed
       edition.)

    Source:  GAO's presentation of the Bureau of Reclamation's data.

       SCOPING PHASE
    ---------------------------------------------------------- Chapter 1:6

    The initial step in preparing an EIS involves a scoping phase that
    provides for the early identification and consideration of
    environmental issues and alternatives.  In February 1990, Reclamation
    published a notice in the Federal Register announcing the opening of
    the scoping phase of the Glen Canyon Dam's EIS.  This phase included
    environmental scoping meetings to obtain public comments and
    determine the appropriate scope of the EIS.  The comment period,
    initially established for March 12 through April 16, 1990, was
    extended to May 4, 1990, in response to comments by the public.
    Reclamation provided opportunities for public participation in the
    scoping phase through news releases, mailings, legal notices, and
    contacts with media, organizations, and individuals.  Throughout the
    process, the EIS team periodically reported the results of its
    analyses to the cooperating agencies and the public.  The cooperating
    agencies acted as a steering committee and provided input to
    Reclamation on both the EIS process and the EIS document after a
    period of review and discussion.

    More than 17,000 comments were received during the scoping period.
    Numerous comments were received about suggested alternatives and
    factors to be considered in the development of alternatives.  These
    comments ranged from general suggestions about the management of the
    dam to specific flow release recommendations.  As a result of the
    analyses and the categorization of the oral and written scoping
    comments by a Reclamation contractor, the EIS team consolidated and
    refined the public's issues of concern.  The following resources were
    identified to be analyzed in detail in the EIS:  water, sediment,
    fish, vegetation, wildlife and their habitat, endangered and other
    special-status species, cultural resources, air quality, recreation,
    hydropower, and non-use value.

    In July 1990, representatives from the cooperating agencies and
    various interest groups participated in a "brainstorming" workshop to
    fully consider all concepts and suggestions in formulating
    alternatives for the dam's operations.  On the basis of the results
    of the workshop, scoping comments, and the Glen Canyon Environmental
    Studies phase I report, the interdisciplinary EIS team formulated 10
    preliminary alternative flow scenarios.  Some of these alternatives
    would provide for warmer water release temperatures in the summer,
    add sediment to the river below the dam, or reregulate releases to
    provide steady flows downstream.  The EIS team presented these
    alternatives to the cooperating agencies and, following their
    approval, presented them to the public in March 1991.

    The public was asked to comment on the range of preliminary
    alternatives as part of the EIS scoping process.  The predominant
    public comment was the need to separately consider alternatives that
    deal with the operations of the dam from those considering changes to
    the structure of the dam.  Using the additional input received from
    the public, professional judgment, and analysis of interim flows, the
    EIS team reviewed and revised the preliminary alternatives.  Seven
    alternatives were then identified for detailed analysis.  Later, to
    present a full range of reasonable operations for study in the EIS,
    two more alternatives were formulated.  These included the Maximum
    Powerplant Capacity alternative, which was developed to allow use of
    the powerplant's maximum discharge capacity of 33,200 cfs, and the
    eventual preferred alternative--the Modified Low Fluctuating Flow
    alternative.  The Modified Low Fluctuating Flow alternative was
    similar to the Interim Flow but included a habitat maintenance flow.
    Habitat maintenance flows are high, steady releases of water within
    the powerplant's capacity for 1 or 2 weeks in the spring.  The
    purpose of these flows is to reform and rejuvenate backwaters and
    maintain sandbars, which are important for native fish habitat.
    Table 1.1 presents the nine alternative flows studied in detail in
    the Glen Canyon Dam's environmental impact statement.  These
    alternatives can be categorized as follows:  unrestricted fluctuating
    flows, restricted fluctuating flows, and steady flows.

                                            Table 1.1

                             Alternative Operating Procedures Studied
                                   in the Glen Canyon Dam's EIS

    ---------------------------------------  ------------------------------------------------
    Unrestricted fluctuating flows           The two unrestricted fluctuating flow
                                             alternatives would allow flows to vary, as
                                             necessary, for power generation purposes.

    No-Action                                Maintain historic fluctuating releases the same
                                             as they were from 1964, when the dam was placed
                                             in hydropower operation, until the research
                                             flows began in June 1990. The maximum allowable
                                             discharge during these fluctuations would be
                                             31,500 cfs.

    Maximum Powerplant Capacity              Permits use of full powerplant capacity (33,200
                                             cfs).

    Restricted fluctuating flows             The four restricted fluctuating flow
                                             alternatives would provide a range of downstream
                                             resource-protection measures, while offering
                                             varying amounts of flexibility for power
                                             operations.

    High                                     Slightly reduce daily fluctuations from historic
                                             no-action levels.

    Moderate                                 Moderately reduce daily fluctuations from
                                             historic no-action levels; includes habitat
                                             maintenance flows, which are short-duration high
                                             releases during the spring that allow sand to be
                                             transported and deposited for maintaining
                                             camping beaches and fish and wildlife habitat.

    Modified Low (preferred alternative)     Substantially reduce daily fluctuations from
                                             historic no-action levels; includes habitat
                                             maintenance flows.

    Interim Low                              Substantially reduce daily fluctuations from
                                             historic no-action levels; same as interim
                                             operations.

    Steady flows                             The three steady flow alternatives would provide
                                             a range of downstream resource-protection
                                             measures by minimizing daily release
                                             fluctuations. Flows would be steady on either a
                                             monthly, seasonal, or year-round basis.

    Existing Monthly Volume                  Provide steady flows that use historic monthly
                                             release strategies.

    Seasonally Adjusted                      Provide steady flows on a seasonal or monthly
                                             basis; includes habitat maintenance flows.

    Year-Round                               Provide steady flows throughout the year.
    -----------------------------------------------------------------------------------------

       RESOURCE PROTECTION MEASURES
       (COMMON ELEMENTS)
    ---------------------------------------------------------- Chapter 1:7

    All of the restricted fluctuating flow and steady flow alternatives
    include elements designed to provide additional resource protection
    or enhancement.  Since these elements were common to all such
    alternatives, they became known as the "common elements." Each impact
    analysis includes these common elements.  The common elements include
    adaptive management, monitoring and protecting cultural resources,
    flood frequency reduction measures, beach/habitat-building flows,
    further study of selective withdrawal structures, measures to
    increase populations of an endangered fish--the humpback chub,\4 and
    emergency operating exception criteria.

    --------------------
    \4 Measures to provide protection for, or enhancement of, populations
    of the razorback sucker are not specifically included as a common
    element because currently very few of the species exist in the
    mainstream Colorado River and no reproduction is known to occur.

             ADAPTIVE MANAGEMENT
    ------------------------------------------------------ Chapter 1:7.0.1

    The concept of adaptive management is based on the recognized need
    for operational flexibility to respond to future monitoring and
    research findings and varying resource conditions.  The purpose of
    the Adaptive Management Program would be to develop future
    modifications to the dam's operating criteria if monitoring and/or
    research results indicate a need for change.  Long-term monitoring
    and research would measure how well the selected alternative meets
    the resource management objectives.  The basis for any decision would
    be linked to the response of the resources to the operations of the
    dam.  (Further details on the Adaptive Management Program are
    provided in ch.  2.)

             MONITORING AND PROTECTING
             CULTURAL RESOURCES
    ------------------------------------------------------ Chapter 1:7.0.2

    The existence and operation of Glen Canyon Dam has had an effect on
    the historic properties within the Colorado River corridor of the
    Glen and Grand canyons.  These properties include prehistoric and
    historic archeological sites and Native American traditional cultural
    properties and resources.  Impacts are likely to occur to some of
    these historic properties regardless of the EIS alternative chosen
    for implementation.  The National Historic Preservation Act, as
    amended in 1992, instructs federal agencies to develop measures to
    avoid or minimize the loss of historic properties resulting from
    their actions.

             FLOOD FREQUENCY REDUCTION
             MEASURES
    ------------------------------------------------------ Chapter 1:7.0.3

    Under this common element, the frequency of unscheduled flood flows
    greater than 45,000 cfs would be reduced to no more than once in 100
    years as a long-term average.  This would allow management of certain
    other common elements--habitat maintenance flows and
    beach/habitat-building flows.

    The two separate methods of reducing flood frequency that were
    identified include (1) increasing the capacity of Lake Powell by
    raising the height of the spillway gates by 4.5 feet and (2) reducing
    the volume of the lake by 1 million acre-feet from its current
    capacity in the spring until the runoff peak has clearly passed.

             BEACH/HABITAT-BUILDING
             FLOWS
    ------------------------------------------------------ Chapter 1:7.0.4

    Sandbars above the river's normal peak stage will continue to erode,
    and backwater habitat within the river's flow will tend to fill with
    sediment under any EIS alternative.  Beach/habitat-building flows
    involve controlled high releases of water greater than the
    powerplant's capacity for a short duration; they are designed to
    rebuild high-elevation sandbars, recycle nutrients, restore backwater
    channels, and provide some of the dynamics of a natural system.

             FURTHER STUDY OF
             SELECTIVE WITHDRAWAL
             STRUCTURES
    ------------------------------------------------------ Chapter 1:7.0.5

    Reclamation would perform a study to determine if structures that
    would allow the withdrawal of water from various depths of the
    reservoir should be installed at the Glen Canyon Dam.  Currently,
    water released from the dam to produce hydropower is withdrawn from
    the cold depths of Lake Powell, averaging 230 feet below the water's
    surface when the reservoir is full.  This withdrawal process is
    accomplished by a series of eight 15-foot-diameter intake pipes that
    provide the water directly to the dam's eight turbines.  This water
    withdrawal process results in the river water temperature downstream
    of the dam being a nearly constant year-round average of about 46
    degrees Fahrenheit.  Many native fish species cannot reproduce and
    survive in these constant cold temperature conditions.  Increasing
    mainstream water temperatures by means of selective withdrawal
    structures offers the greatest potential for creating new spawning
    populations of humpback chub and other native fish in the Grand
    Canyon.  Multilevel intake structures (a means of selective
    withdrawal) could be built at Glen Canyon Dam to provide seasonal
    variation in the water temperature.  A structure would be attached to
    each of the eight existing intake pipes to withdraw warmer water from
    the upper levels of the reservoir.  However, the cost of installing
    multilevel intake structures at the Glen Canyon Dam has been
    estimated at $60 million.

             NEW POPULATION OF
             HUMPBACK CHUB
    ------------------------------------------------------ Chapter 1:7.0.6

    With the assistance of the U.S.  Fish and Wildlife Service, the
    National Park Service, the Arizona Game and Fish Department, and
    other land management entities, such as the Havasupai Tribe,
    Reclamation would make every effort--through funding, facilitating,
    and technical support--to establish a new population of humpback chub
    within the Grand Canyon.  The humpback chub is currently a listed
    species under the federal Endangered Species Act of 1973 (16 U.S.C.
    1532 et seq.) and is one of the native fish species that faces
    continued ecological health problems due to the cold water
    temperatures of the Colorado River.  Such cold temperatures are not
    conducive to the humpback chubs' spawning or the survival of eggs and
    young.

             EMERGENCY EXCEPTION
             CRITERIA
    ------------------------------------------------------ Chapter 1:7.0.7

    Normal operations described under any alternative could be altered
    temporarily to respond to power and water emergencies, such as
    insufficient generating capacity, the restoration of the electrical
    system, or search and rescue operations.  These changes in operations
    would be of short duration (usually less than 4 hours) and would be
    the result of emergencies at the dam, downstream, or within the
    interconnected electrical system.

       DRAFT EIS AND PUBLIC COMMENTS
    ---------------------------------------------------------- Chapter 1:8

    On January 4, 1994, Reclamation filed a draft EIS with EPA.  The
    Draft EIS presented the impacts of the nine flow alternatives,
    including the No-Action alternative (historic operations) that
    provided a baseline for comparison, on the 11 resources that could be
    affected by the various dam-operating regimes.  Over 33,000 written
    comments were received on the draft EIS.  More than 2,300 separate
    issues and concerns were extracted from an analysis of the comments.

    EPA's Region IX supported the preferred alternative (Modified Low
    Fluctuating Flow) selected by Reclamation in the draft EIS.  However,
    EPA gave the draft EIS a qualified rating based on insufficient
    information on two issues.  First, EPA expressed concern about the
    lack of information on the impacts of raising the dam's spillway
    gates as a flood frequency reduction measure and recommended that the
    final EIS include a more thorough evaluation of the flood frequency
    reduction options.  Second, EPA recommended that the final EIS
    contain further discussion of Reclamation's Adaptive Management
    Program and how it plans to implement beach/habitat-building flows.

       PRELIMINARY FINAL EIS
    ---------------------------------------------------------- Chapter 1:9

    Reclamation issued a preliminary final EIS for the operations of the
    Glen Canyon Dam in December 1994.  The preliminary final EIS also
    took into consideration the discussions with the U.S.  Fish and
    Wildlife Service (FWS) in connection with the consultation
    requirements of the Endangered Species Act and with the provisions of
    the Fish and Wildlife Coordination Act.  Section 7 of the Endangered
    Species Act, as amended (16 U.S.C.  1536), requires federal agencies
    to consult with FWS to ensure that the actions they authorize, fund,
    or carry out are not likely to jeopardize the continued existence of
    a species listed under the act as endangered or threatened.  If the
    action would jeopardize a listed species, FWS suggests a reasonable
    and prudent alternative that the federal agency can implement to
    minimize and/or mitigate the activity's impact on the species or
    their critical habitat.  The Fish and Wildlife Coordination Act of
    1958 (16 U.S.C.  661 et seq.) was enacted to ensure that fish and
    wildlife receive equal consideration during the planning and
    construction of federal water projects.  FWS prepares a Fish and
    Wildlife Coordination Act report that contains nonbinding
    recommendations for actions that would be beneficial to fish and
    wildlife.  The cooperating agencies and the EIS team reviewed the
    preliminary final EIS, and additional changes were made to the EIS on
    the basis of that review.

       FINAL EIS
    --------------------------------------------------------- Chapter 1:10

    On March 21, 1995, Reclamation filed the final EIS with EPA.  In June
    1995, EPA informed Reclamation that it continues to support the
    preferred alternative and was pleased that Reclamation had addressed
    EPA's concerns about the draft EIS.  Specifically, the final EIS
    states that Reclamation will conduct a detailed evaluation of the
    flood frequency reduction measures before a decision is made and
    provides more information on the approach that Reclamation will use
    to implement an Adaptive Management Program and conduct
    beach/habitat-building flows.  EPA applauded the efforts made by all
    of the agencies, tribes, organizations, and individuals involved in
    the research, scoping, and preparation of the EIS.  EPA summarized
    that the dedication to sound science and cooperative relations was
    critical to developing a preferred alternative (including adaptive
    management), which it believes will protect and enhance the
    environmental and cultural resources downstream from the Glen Canyon
    Dam.

       RECLAMATION'S PREFERRED
       ALTERNATIVE FOR FUTURE
       OPERATIONS OF THE GLEN CANYON
       DAM
    --------------------------------------------------------- Chapter 1:11

    In the Glen Canyon Dam's final environmental impact statement,
    Reclamation recommends the Modified Low Fluctuating Flow as the
    preferred method for the future operations of the Glen Canyon Dam.
    According to the final EIS, the Modified Low Fluctuating Flow
    alternative was developed to reduce daily flow fluctuations well
    below no-action levels and to provide periodic high, steady releases
    of short duration, with the goal of protecting or enhancing
    downstream resources while allowing limited flexibility for power
    operations.  This alternative would have the same annual and
    essentially the same monthly operating plan as under the No-Action
    alternative but would restrict daily and hourly water releases.
    Specifically, minimum flows would be no less than 8,000 cfs between 7
    a.m.  and 7 p.m.  and 5,000 cfs at night.  The maximum rate of
    release would be limited to 25,000 cfs during fluctuating hourly
    releases.  Ramp rates would be limited to 4,000 cfs per hour for
    increasing flows and 1,500 cfs per hour for decreasing flows.  Daily
    fluctuations would be limited to 5,000, 6,000, or 8,000 cfs depending
    on the monthly release volume.

    The preferred alternative also included periodic habitat maintenance
    flows, which are steady high releases within the powerplant's
    capacity for 1 to 2 weeks in the spring.  The purpose of these flows
    is to rejuvenate backwater channels that are important to fish
    habitat and maintain sandbars that are important for camping.
    Habitat maintenance flows differ from beach/habitat-building flows in
    that they would be within the powerplant's capacity and would occur
    nearly every year when the reservoir's volume is low.  According to
    Reclamation, when the reservoir is low, water flows normally would
    not exceed about 22,000 cfs, and the probability of an unscheduled
    spill is small.  Therefore, the habitat maintenance flows would be
    scheduled in those years.  Habitat maintenance flows would not occur
    in years when a beach/habitat-building flow is scheduled.
    Beach/habitat-building flows are controlled floods with scheduled
    high releases of water greater than the powerplant's capacity for a
    short duration, designed to rebuild high elevation sandbars, deposit
    nutrients, restore backwater channels, and provide some of the
    dynamics of a natural river system.

    According to Reclamation, instead of conducting the beach/habitat
    building flows in years in which Lake Powell storage is low on
    January 1, it has been agreed to modify the preferred alternative in
    the Record of Decision to accomplish the flows in high reservoir
    years when bypassing the powerplant would be necessary for safety
    purposes at the dam.  In the spring of 1996, Reclamation conducted
    its first experiment of the controlled flood concept.  The controlled
    experiment commenced with 4 days of constant flows at 8,000 cfs.
    Flows began to increase incrementally on March 26, 1996, until they
    reached a maximum of 45,000 cfs, where they remained for 7 days.
    After 7 days of high flows, the releases were reduced, gradually, to
    a constant flow of 8,000 cfs for 4 days of evaluation.  According to
    Reclamation, the preliminary results indicate that the release
    increased sandbars in the Glen and the Grand canyons by as much as 30
    percent and also created numerous backwaters for fish.

       OBJECTIVES, SCOPE, AND
       METHODOLOGY
    --------------------------------------------------------- Chapter 1:12

    Subsection 1804(b) of the Grand Canyon Protection Act states that the
    Comptroller General shall (1) audit the costs and benefits to water
    and power users and to natural, recreational, and cultural resources
    resulting from the management policies and dam operations identified
    pursuant to the environmental impact statement and (2) report the
    results of the audit to the Secretary of the Interior and the
    Congress.

    While the act states that GAO should audit the "costs and benefits"
    of various alternative dam operations identified in the EIS, the
    National Environmental Policy Act does not require, and Reclamation
    did not perform, a cost and benefit analysis.  In preparing the
    impact statement, Reclamation studied the impact of nine
    dam-operating alternatives on 11 resources.  In the absence of a cost
    and benefit analysis, we determined that the statute does not require
    us to conduct our own cost and benefit analysis.  As discussed with
    the staff of the Majority and Ranking Minority members of the Senate
    and House committees having jurisdiction over these matters, to
    fulfill the requirements of the act, we examined

      -- whether Reclamation's determination of the impact of various
         flow alternatives on selected resources was reasonable and

      -- what, if any, concerns still exist on the part of key interested
         parties about the final EIS.

    To assess whether Reclamation's impact determinations were
    reasonable, we assessed for each resource, the methodologies and data
    used to make the impact determinations, how the methodologies were
    implemented, and the results achieved.  The details of our analysis,
    and a comprehensive list of individuals contacted and key studies
    identified, are contained in appendixes I through X of this report.
    The title of each appendix is the designation (name) of the resource,
    and they are numbered in alphabetical order.  We combined our
    analysis of the vegetation and wildlife/habitat impact determinations
    into one appendix--appendix IX.  We made this choice because (1)
    similar indicators were studied in making the impact determinations
    for these resources, (2) the riparian vegetation that developed along
    the Colorado River corridor plays an important role as habitat to
    support the diversity of wildlife within the Glen and the Grand
    canyons, and (3) the same EIS team member was responsible for the
    impact determinations of both resources.

    For three resources--hydropower, recreation, and non-use
    values--Reclamation quantified the economic impact of the cost or
    benefit that the various flow alternatives would have on the
    resource.  For these resources, we also reviewed the documentation on
    the modeling techniques and economic assumptions used to make the
    impact determinations.  For example, for Reclamation's power
    methodology, we reviewed key economic assumptions, results, and
    documentation, including reports entitled Power System Impacts of
    Potential Changes in Glen Canyon Power Plant Operations, [Phase II]
    Final Report, October 1993, and Power System Impacts of Potential
    Changes in Glen Canyon Power Plant Operations, Phase III Final
    Report, July 1995.  These reports were prepared by the Power
    Resources Committee, a subgroup of the EIS team which included
    experts from the federal government, the utility industry, and the
    environmental community.  This committee was charged with determining
    the impact of the nine flow alternatives on hydropower.

    We interviewed members of the Power Resources Committee, including
    the Reclamation officials who served as Chairman and economist, and
    representatives from the Western Area Power Administration, the
    Colorado River Energy Distributors Association, the Environmental
    Defense Fund, and the Reclamation contractor that conducted the
    studies.

    In addition, to assess the methodology used, economic assumptions,
    and results, we reviewed federal guidance on water resource projects
    entitled Economic and Environmental Principles and Guidelines for
    Water and Related Land Resources Implementation Studies, U.S.  Water
    Resources Council, March 10, 1983; public comments on the draft and
    final EIS, and comments provided by three energy consultants retained
    by HBRS, Inc.  to review the power analysis.  HBRS, Inc.  (now called
    Hagler Bailly Consulting), was Reclamation's primary contractor for
    conducting the power analysis.  Also, we reviewed the comments
    provided by the National Research Council on the power analyses in
    the draft and final EIS.  We used standard microeconomic principles
    to assess the reasonableness of key economic assumptions.  Our
    assessment of the reasonableness of Reclamation's methodology was
    limited to a review of the general analytical framework and an
    assessment of the reasonableness of the key assumptions and data.  We
    did not evaluate the Power Resources Committee's calibration of the
    power simulation models used or the spreadsheet models used, nor did
    we verify the accuracy of all data inputs.

    For both the recreation and non-use methodologies, we reviewed the
    literature and research principles on the contingent valuation method
    to assess the reasonableness of the methodology, assumptions used,
    and results in conjunction with standard economic principles.
    Economists and survey researchers working in the natural resource and
    environmental areas have developed the theory and practice of
    contingent valuation to estimate non-use values.

    To gain an understanding of Reclamation's recreational methodology,
    key assumptions, and results, we reviewed documentation that
    describes these in detail, including the EIS.  We also interviewed
    members of the Recreation subgroup, including Reclamation officials
    and their contractors, as well as representatives from the National
    Park Service and the Arizona Game and Fish Department.  In addition,
    we interviewed academic experts in the field and a member of the
    National Academy of Sciences' team that reviewed the EIS.

    To gain an understanding of Reclamation's non-use value study
    methodology and results, we reviewed the final report entitled GCES
    Non-Use Value Study, dated September 8, 1995.  We interviewed
    Reclamation officials responsible for the preparation of the report,
    and a Senior Associate at Hagler Bailly Consulting, who was a primary
    contributor to the development of the report.  To evaluate
    Reclamation's non-use study, we made use of some general guidelines
    that focus on the quality of a contingent valuation study and on the
    underlying survey research.  Specifically, to assess the contingent
    valuation study, we relied on general guidelines developed by a panel
    of prominent researchers convened by the National Oceanic and
    Atmospheric Administration.  The panel's report was published in the
    Federal Register on January 15, 1993.  To assess the total design
    method for conducting mail surveys used by Reclamation in the non-use
    study we used the most widely accepted written standards for mail
    questionnaires published by Don A.  Dillman in 1978.  We also
    interviewed a number of the Non-Use Value Committee members to obtain
    their opinion of the methodologies and data used and the results
    achieved.  The Committee included members from the power industry,
    environmental groups, Native American tribes, and federal agencies.
    The Committee was tasked to consider interim study results and
    provide input to the study process.

    For the eight resources whose impact determinations were not
    economically quantified, to determine the methodology and data used
    to make an impact determination, we obtained and reviewed the
    following documents:  the draft EIS and associated appendixes, the
    preliminary final EIS, the final EIS, public comments on the draft
    EIS, Reclamation's analysis of and responses to these comments,
    copies of the minutes of EIS team meetings, summaries of the
    cooperating agency meetings, and Reclamation's newsletters on the EIS
    process.  We also obtained and reviewed the U.S.  Fish and Wildlife
    Service's draft biological opinion and final biological opinion on
    the Glen Canyon Dam's EIS, Reclamation's comments and responses to
    the biological opinions, and the U.S.  Fish and Wildlife Service's
    report required by the Fish and Wildlife Coordination Act.  Also, we
    reviewed numerous scientific studies related to each of the resources
    that were identified by EIS team members as the most useful in
    developing the impact determinations for the respective resources.

    To obtain a better understanding of other issues related to the EIS
    process, we also reviewed the Colorado River Simulation System
    Overview, the Final Analysis Report on Scoping Comments, and the Glen
    Canyon Dam EIS Preliminary Alternatives Report.  Other documents
    reviewed included the draft and final environmental assessment of the
    spring 1996 beach/habitat-building test flow and papers presented at
    a 1991 National Research Council Symposium on the Glen Canyon
    Environmental Studies.

    Because certain parameters included in the preferred alternative were
    changed, we reviewed a document entitled "Assessment of Changes to
    the Glen Canyon Dam Environmental Impact Statement Preferred
    Alternative from Draft to Final EIS," issued by Reclamation in
    October 1995.  This paper explained the background and scientific
    basis of the changes to the preferred alternative between the draft
    and final EIS.  A comprehensive list of the documents we reviewed is
    contained in the discussion of each of the 11 resources in appendixes
    I through X (vegetation and wildlife/habitat are both discussed in
    appendix IX).

    To assess the reasonableness of the impact determinations for the
    eight resources that were not economically quantified, we interviewed
    the EIS team members and/or subgroup members who had the primary
    responsibility for making the impact determinations, writing sections
    of the draft EIS, and revising the EIS following the receipt of
    public comments.  We also spoke with scientists identified by EIS
    team members and members of EIS subgroups who commented on issues in
    their area of expertise.  Finally, we interviewed other agency
    officials with information on the EIS and Glen Canyon Environmental
    Studies processes.  For each of these resources, we obtained his or
    her views on the reasonableness of the methodology and data used in
    making the impact determinations, how well the methodologies were
    implemented, and the reasonableness of the results achieved.

    To obtain information on what, if any, concerns still exist on the
    part of key interested parties about the final impact statement,
    including how many supported the preferred alternative, we surveyed
    37 key organizations and individuals knowledgeable about the EIS and
    its development.  Our judgmental sample included officials of federal
    agencies, state agencies, Indian tribes, environmental organizations,
    water and power suppliers and users, and individuals involved in the
    development of the EIS.  Specifically, among the 37 organizations and
    individuals we asked to respond to our survey, 23 were organizations
    and individuals that provided what Reclamation considered to be the
    most substantive comments on the draft EIS.  These agencies and
    individuals include the Navajo Nation, Hualapai Tribe, Hopi Tribe,
    Bureau of Indian Affairs, National Park Service, Arizona Game and
    Fish Department, U.S.  Fish and Wildlife Service, Western Area Power
    Administration, Plains Electric Generation and Transmission Coop,
    Inc., Environmental Protection Agency, Environmental Defense Fund,
    National Research Council, Upper Colorado River Commission,
    Department of the Interior's Office of Environmental Policy and
    Compliance, Salt River Project, Colorado River Energy Distributors
    Association, Grand Canyon Trust, American Rivers, Sierra Club Legal
    Defense Fund, American Fisheries Society, Grand Canyon River Guides,
    and Dr.  Larry Stevens.  Dr.  Stevens is considered by many to be the
    leading authority on vegetation in the Grand Canyon region.  He was a
    major contributor of research on both the vegetation and
    wildlife/habitat resources for the EIS.  We also contacted Mr.  David
    Marcus, whom Reclamation stated also provided substantive comments on
    the draft EIS.  However, Mr.  Marcus stated that he worked as a
    consultant for American Rivers and that he preferred to provide us
    with his comments through that organization, not as an individual.
    As such, we did not include Mr.  Marcus as part of our survey
    universe.

    We also contacted the three cooperating agencies (Pueblo of Zuni,
    Southern Paiute Tribe, and Southern Paiute Consortium) that were not
    among the 22 above.  Furthermore, the seven Colorado River Basin
    states (Arizona, California, Colorado, Nevada, New Mexico, Utah, and
    Wyoming) were asked to respond to our survey.  In addition, another
    five environmental groups with interests in the Glen Canyon Dam area
    (Sierra Club, Arizona Flycasters, Friends of the River, America
    Outdoors, and Trout Unlimited) were also contacted.  We received
    responses from 30 of the 37 (81 percent) organizations and
    individuals we contacted.  The seven nonrespondents did not represent
    any particular interest group.  Specifics on how the 37 organizations
    and individuals responded to our survey are provided in chapter 3 of
    this report.

    We conducted our work from January 1995 through September 1996 in
    accordance with generally accepted government auditing standards.

    We provided copies of a draft of this report to the Department of the
    Interior for its review and comment.  Interior generally agreed with
    the information presented in the report and stated that they were
    impressed with the quality of the product developed by the audit
    team.  Interior also provided several technical clarifications to the
    draft, which have been incorporated into the report as appropriate.
    Interior's comments and our responses are included in appendix XII.

    RECLAMATION'S IMPACT
    DETERMINATIONS ARE USABLE FOR
    DECISION-MAKING
    ============================================================ Chapter 2

    In preparing the Glen Canyon Dam's environmental impact statement,
    Reclamation studied the impact of the dam's various flow alternatives
    on hydropower, non-use values, and other selected resources located
    below the dam.  To make these impact determinations, Reclamation used
    a variety of methodologies and data sources.  Generally, we believe
    the methodologies used to be reasonable and appropriate and the data
    used to be the best available at the time.  Some prominent
    economists, however, question the credibility of results obtained
    from the methodology Reclamation used to derive non-use values.  We
    also noted some shortcomings in some of Reclamation's economic
    assumptions and its application of certain methodologies.  In
    addition, we found that some of the data used in the resource
    analyses were dated, preliminary, or incomplete.  Overall, these
    limitations reduce the precision of the estimated impacts contained
    in the EIS.  In addition, there is general agreement that as a result
    of incomplete information, the impact of steady flow alternatives on
    fish resources remains uncertain.  Nonetheless, our work disclosed no
    evidence that these limitations would alter the relative ranking of
    the fluctuating and steady flow alternatives.  Therefore, we believe
    that these limitations are not significant enough to render the final
    impact statement unusable to the Secretary of the Interior as a
    decision-making document.

    Generally, Reclamation and other experts associated with the
    development of the Glen Canyon Dam's environmental impact statement
    believe that the impact determinations are reasonable.  At the same
    time, they recognize that there are limitations to the EIS.  However,
    they believe that these limitations are not significant enough to
    make the results unusable.  Furthermore, Reclamation recognizes that
    many uncertainties still exist.  To address these uncertainties,
    Reclamation intends to initiate a process of "adaptive management"
    that would provide for long-term monitoring and research to measure
    the actual effects of the selected alternative.  The results of this
    effort would form the basis for possible future modifications of the
    dam's operations.

       METHODOLOGIES USED TO MAKE
       IMPACT DETERMINATIONS WERE
       GENERALLY REASONABLE
    ---------------------------------------------------------- Chapter 2:1

    We found that, in general, the variety of methodologies and research
    techniques used by Reclamation to make impact determinations were
    reasonable and appropriate.  For most resource assessments,
    Reclamation relied on multidisciplinary subteams consisting of
    experts representing federal and state governments, tribal interests,
    academic and scientific communities, the electric utility industry,
    environmental organizations, and the recreation industry.  The exact
    makeup of each team depended on the resource and the area of concern.
    In addition, for each resource, the subteam assessed, either
    quantitatively, qualitatively or both, how alternative flows would
    affect the resource relative to a No-Action (base case) flow.  The
    EIS teams generally used state-of-the-art modeling techniques and/or
    the latest scientific research to make the impact determinations.
    Furthermore, the methods used and results achieved were reviewed by
    peers and outside experts, including the Glen Canyon Environmental
    Studies Review Team and the National Academy of Sciences.

    To conduct the impact analyses of various flows on hydropower,
    Reclamation established the Power Resources Committee--a group of
    electricity and modeling experts from Reclamation, the Western Area
    Power Administration, the electric utility industry, private
    contractors, and the environmental community.  Using a 50-year
    analysis period (1991-2040) and the No-Action Flow alternative
    (historic operations) as the base case, the Committee assessed how
    various flow alternatives would affect hydropower production and then
    projected the subsequent economic costs that would be incurred by
    regional utilities and end-users to replace the dam's forgone power
    production.  The Committee considered the fixed costs associated with
    the existing generating capacity in the region to be "sunk" costs
    and, hence, excluded them from the economic cost calculations.  The
    Committee also used two state-of-the-art modeling techniques and
    detailed utility-specific data to quantify the economic impacts.  In
    addition, the Committee used sensitivity analysis to test the impact
    of changes in key economic assumptions.  The results of the power
    study were then incorporated into the draft EIS for public comment.
    The Committee solicited and received an independent review of the
    power study from three energy experts.  On the basis of the comments
    received from the public and outside experts, the Committee partially
    revised its initial power study.  For example, the Committee updated
    the projected costs of building gas-combustion powerplants, revised
    its retail rate analysis, and conducted additional sensitivity
    analyses.  The results of both power studies were incorporated into
    the final EIS.  (See app.  V for details on the results of the power
    study.)

    For fish resources, numerous public comments were received by
    Reclamation expressing concern about the impact determinations
    presented in the draft EIS.  To respond to these concerns,
    Reclamation formed an Aquatic Biology Team workgroup.  This work
    group consisted of EIS team members representing Reclamation, the
    U.S.  Fish and Wildlife Service, the Arizona Game and Fish
    Department, and two Indian tribes.  The workgroup was tasked to
    respond to comments and to reorganize and rewrite the fish section of
    the final EIS.  Individual workgroup members were given specific
    assignments, interactive discussions were held, and decisions were
    made through consensus.  As a result of this effort, several major
    changes were made to the final EIS, including more explicit
    recognition of the uncertainty and disagreement that exist among
    scientists about the response of fish to the steady flow
    alternatives.  (See app.  IV for details on the results of the fish
    impact determinations.)

    To assess the impact of various flow alternatives on water and
    sediment, Reclamation's EIS team used the Colorado River Simulation
    System (CRSS) to project the long-term (50 years) and short-term (20
    years) impacts on annual and monthly streamflows, floodflows and
    other water spills, water storage, water allocation deliveries, and
    Upper Colorado River Basin yields.  CRSS is a package of computer
    programs and databases designed to assist water resource managers in
    performing comprehensive long-range planning and operations studies
    that arise from proposed changes in the Colorado River's operations,
    proposed development of the Colorado River Basin, or changes in
    present water use throughout the basin.  The development of CRSS took
    place over a 10-year period and stemmed from the need for a
    comprehensive model of the Colorado River Basin that would
    incorporate all areas of interest, including legislative
    requirements.  According to Reclamation and other experts, CRSS is
    the most comprehensive and detailed simulation of the Colorado River
    system that exists.  (See app.  VIII and app.  X for details on the
    results of the sediment and water analyses, respectively.)

    To quantify the economic impact of the dam's various flow
    alternatives on non-use values and recreation, Reclamation primarily
    relied on a methodology called contingent valuation.  Social
    scientists and economists have long acknowledged the existence of
    non-use values--the monetary value placed on the status of the
    environment by people who never visit or otherwise use these
    features.  Contingent valuation relies on public surveys to elicit
    information from consumers and estimate how much they would be
    willing to pay for a non-use good.  For valuing most goods and
    services, economists are able to rely on people's actual purchases of
    goods in markets.  However, by definition people do not purchase
    non-use goods, and some prominent economists question whether the
    contingent valuation method can accurately elicit the values
    consumers place on non-use goods.  For example, Peter A.  Diamond and
    Jerry A.  Hausman state, "We believe that contingent valuation is a
    deeply flawed methodology for measuring non-use values, one that does
    not estimate what its proponents claim to be estimating."\1 Still
    many economists and survey researchers working in the natural
    resource and environmental areas have developed and used this
    methodology, and it is currently the only known approach for
    estimating non-use values.  (See app.  VI for details on the results
    of the non-use value study.) Economists generally have fewer
    questions about the application of the contingent valuation
    methodology in measuring the value of goods and services that
    consumers actually purchase.  Therefore, there are fewer questions
    about the usefulness of this approach for measuring the values
    associated with recreational activities.  (See app.  VII for details
    on the results of the recreation studies.)

    --------------------
    \1 Peter A.  Diamond and Jerry A.  Hausman, "Contingent Valuation:
    Is Some Number Better than No Number?" Journal of Economic
    Perspectives, 8(4), Fall 1994, pp.  45-64.  (quotation on p.  62).

          SHORTCOMINGS NOTED IN
          RECLAMATION'S ECONOMIC
          ASSUMPTIONS AND
          IMPLEMENTATION OF CERTAIN
          METHODOLOGIES
    -------------------------------------------------------- Chapter 2:1.1

    In light of the results of our work and the opinions of the experts
    we contacted, we believe the methodologies used by Reclamation and
    its EIS teams to make impact determinations were generally
    reasonable.  We did note, however, some shortcomings in the economic
    assumptions used in the hydropower analysis and in Reclamation's
    implementation of certain methodologies.  Specifically, in the
    hydropower analysis, the assumptions used do not explicitly include
    the mitigating effect that higher electricity prices would have in
    reducing the demand for electricity (that is, price elasticity).  For
    example, the Power Resources Committee assumed that both the demand
    for and price of electricity would continue to rise over the planning
    period.  However, we believe the rise in the price of electricity
    would likely induce some electricity consumers (both wholesalers and
    end-users) to consume less electricity or switch to cheaper
    alternative suppliers, which is not taken into account in the
    analysis.  Consequently, fewer resources would be needed to replace
    forgone power at the Glen Canyon Dam, and the subsequent economic
    impacts would be lower than estimated (all else being the same).

    In addition, the Committee's assumptions about future natural gas
    prices are relatively high.  The Committee assumed that the average
    gas price would increase annually by 8 percent from 1991 through
    2010.  In 1994, industry forecasters projected that the price of
    natural gas would increase by about 6 percent for the same time
    period, and in 1995, forecasts assumed that prices will rise by only
    5 percent.  The higher escalation rates could affect the power
    analysis by overstating the economic cost of replacing the Glen
    Canyon Dam's power.

    We also found that Reclamation's staff made two computational errors
    during the revision of the initial power analysis.  The Power
    Resources Committee acknowledged these errors in its final report and
    stated that the errors affected the results in opposite directions,
    that is, one error may have overstated costs while the other error
    may have understated costs.  The Committee was unable to correct the
    errors in the report because of time and funding constraints.

    These shortcomings, combined with the inherent uncertainty in making
    economic forecasts, reduce the precision of the estimated economic
    impacts.  However, an association that represents the affected power
    utilities, while maintaining that the costs to the power system are
    understated, does not believe that Reclamation's analysis is
    inaccurate by a large magnitude.  Furthermore, because these
    shortcomings affect the estimated economic impact of all alternatives
    equally, we believe that addressing these shortcomings would not
    alter the relative ranking of the fluctuating and steady flow
    alternatives.

    Although we believe the recreation impacts methodology is generally
    reasonable, we noted several limitations.  For example, the survey
    data used as the basis of the analysis were gathered during an
    unusually high-water year; therefore, some respondents may not have
    actually experienced how various alternative flows would have
    affected their recreational experience, which is what they were being
    asked to value.  In addition, the survey was designed well before the
    flow alternatives to be studied in the Glen Canyon Dam's EIS were
    finalized.  As a result, the survey scenarios do not systematically
    correspond to the flow alternatives presented in the EIS.  Finally,
    although researchers tested proposed questions to determine which
    ones offered the highest response rate, they did not adequately
    pretest some survey instruments to detect wording, construction, and
    presentation defects or other inadequacies.  Because the recreation
    economic model used the results of these survey instruments as a
    basis for the analysis, the estimated dollar value of the benefits
    may not be very precise.  Reclamation and National Park Service
    officials involved in the process acknowledged that the recreation
    analysis has limitations but stated that these limitations would not
    affect the ranking of the alternatives.  They also noted that the
    estimated recreation benefits identified by this research were not a
    key element in the selection of the preferred alternative.

    In addition to the shortcomings in the hydropower and recreation
    analyses, we also noted that there was no formal opportunity for
    affected parties as well as the general public to offer comments on
    the Glen Canyon non-use value study.  Although the final EIS notes
    that the non-use value is positive and significant, the actual
    quantified results are not included in the final EIS.  Reclamation
    did not include the non-use value study results because they were not
    available when the final EIS was published.  The non-use study was
    completed as a separate Glen Canyon Environmental Studies report and,
    according to Reclamation, will be attached to the Record of Decision
    package sent to the Secretary of the Interior.  In that way, it will
    become part of the final decision-making process.  Reclamation noted
    that although the non-use study did not go through the public comment
    process, the study team solicited and received peer review at various
    key decision points and that the final results of the non-use value
    study received a positive review by the National Academy of Sciences
    and the Office of Management and Budget.  Reclamation also noted that
    interests likely to be affected by any changes in the operations of
    the Glen Canyon Dam, such as power groups and environmental groups,
    were involved in the non-use value study process.  In addition, there
    were scoping sessions and focus groups that were derived from members
    of the general public.  The results of these sessions were used to
    assist in the development of the content of the survey and the
    relevant issues to be addressed.

       DATA USED IN IMPACT
       DETERMINATIONS WERE THE BEST
       AVAILABLE
    ---------------------------------------------------------- Chapter 2:2

    Reclamation's National Environmental Policy Act Handbook requires
    that all EIS analyses be based on the best reasonably obtainable
    scientific information.  According to Reclamation and other experts
    who developed the Glen Canyon Dam's environmental impact statement,
    the data used to make the impact determinations were the best
    available at the time.  For example, for the impact of various flow
    alternatives on nonfish endangered species, one researcher said the
    terrestrial and bird-related research used as a basis for making
    impact determinations was "top notch." Another researcher who worked
    on endangered species stated that when they were clarifying
    information or needed data to fill gaps, the EIS team contacted
    researchers directly to get the latest available data.  For
    information on cultural resources and properties, members of that
    resource team believe that Reclamation went beyond federal
    requirements for the development of an impact statement by performing
    assessments of all previously identified archeological sites within
    the Colorado River corridor in the Glen and Grand canyons.  According
    to many experts, when completed, this effort generated the best and
    most current scientific information available.

    For some resources, we found that although the data were the best
    available, they had limitations.  Some of the data used in making the
    impact determinations were dated, preliminary, or incomplete.  For
    example, Reclamation used survey data collected in 1985 to assess the
    economic impact of alternative dam flows on recreational activities.
    Reclamation's contractor surveyed a sample of anglers, day-rafters,
    and white-water boaters about their recreational experiences on the
    Colorado River and what effect, if any, different streamflows would
    have on their recreational experiences.  However, because the survey
    was undertaken in 1985, it may not represent more recent trends in
    recreational experiences.  For example, the number of angling trips
    on the Colorado River more than doubled between 1985 and 1991 (the
    base year used by Reclamation in preparing the draft EIS), which may
    influence the value of each trip.  Reclamation updated some of the
    data to 1991 but acknowledges that the survey data were generally
    dated.  Reclamation stated, however, that the recreation analysis was
    adequate to present a good picture of the potential impact of
    alternative flows on various recreational experiences and that
    because of the limited impact of alternative flows on recreation,
    limited research funds could be better used to improve other
    analyses.  The National Research Council generally found the
    recreation analysis to be adequate.

    In addition, the estimated non-use values for the steady flow
    alternatives could be overstated because of new information that was
    not available at the time the survey instruments were developed.  The
    non-use value surveys described the environmental impacts based on
    information that was the best available at the time.  This
    information indicated that improvements would be obtained for fish
    resources under fluctuating and steady flow alternatives.  However,
    after the development of the survey instruments, the fish section of
    the EIS was revised to recognize the uncertainty that exists about
    the impact of steady flow alternatives.  To the extent that the
    non-use value surveys did not capture this degree of uncertainty, the
    precision of the non-use value estimates could be reduced.

    Many of the results of the Glen Canyon sediment studies were
    preliminary, in draft form, and had not been published at the time
    that the draft impact statement or the final impact statement was
    written.  In addition, in some cases definitive information on the
    impact of a specific flow alternative was not available.  Therefore,
    the EIS team had to extrapolate from the existing data using their
    professional judgment to estimate the potential impact of a specific
    alternative.  The EIS team told us that they always verified the
    reasonableness of their conclusions and extrapolations with the
    researchers.  However, they believed that if finalized data had been
    available, the reasons for the selection of the preferred alternative
    would have been more clearly supported.  These researchers added that
    no new or additional information on sediment impacts has been
    obtained that would alter the information or conclusions presented in
    the final impact statement.

    Finally, information on some resources is incomplete, as is the
    knowledge of how changes in the Glen Canyon Dam's operations will
    affect those resources.  For example, the experts' opinions vary, in
    part because of incomplete data, on how native and nonnative fish
    interact and how changes to the dam's operations would affect these
    interactions.  Many researchers and EIS team members we interviewed
    expressed regret about the lack of coordinated time frames between
    the completion of the Glen Canyon Environmental Studies and the
    development of the Glen Canyon Dam EIS.  The leader of the workgroup
    responsible for developing the EIS impact determinations for fish
    stated that this difference in time frames was especially problematic
    when the preferred alternative was selected.  At that point,
    decisions had to be made, but data and analyses were not complete.

    Reclamation explicitly acknowledges the uncertainty that exists about
    the impact of the steady flow alternatives on fish resources in the
    final EIS.  In its final biological opinion, the U.S.  Fish and
    Wildlife Service stated that Reclamation's preferred alternative is
    likely to jeopardize the existence of two native endangered fish
    species (the humpback chub and the razorback sucker).  In general,
    the biological opinion's "reasonable and prudent alternative" would
    modify the preferred alternative by including seasonally adjusted
    steady flows.  The U.S.  Fish and Wildlife Service and Reclamation
    have agreed to categorize these flows as experimental and include
    them as part of the Adaptive Management Program.

       THE RESULTS OF THE GLEN CANYON
       DAM'S EIS ARE GENERALLY
       REASONABLE, BUT FUTURE STUDIES
       WILL BE NEEDED
    ---------------------------------------------------------- Chapter 2:3

    Reclamation and other experts associated with the development of the
    Glen Canyon Dam's EIS generally believe that the impact
    determinations presented in the final EIS are reasonable.  (A summary
    of Reclamation's comparison of alternatives and impacts is presented
    in app.  XI of this report.) They recognize that there are
    limitations to the results, but they believe that these limitations
    are not significant enough to make the impact determinations unusable
    for the Secretary's decision-making.  For example, one EIS team
    member stressed that in the process of scientific decision-making and
    economic forecasting, complete and certain information is never
    available.  Furthermore, Reclamation noted that the Congress had
    mandated that the final EIS be issued within a certain time frame;
    therefore, decisions had to be made on the basis of the best
    information available at the time.

    Reclamation recognizes that uncertainties still exist about the
    impact of the various flow alternatives on resources.  To address
    these uncertainties, Reclamation intends to initiate a process of
    "adaptive management."

          IMPACT DETERMINATIONS IN THE
          GLEN CANYON DAM'S EIS ARE
          GENERALLY REASONABLE
    -------------------------------------------------------- Chapter 2:3.1

    We discussed the results of the impact determinations for each
    resource with Reclamation and other experts involved in the
    development of the Glen Canyon Dam's EIS.  Although these individuals
    recognized that there were some shortcomings in the analyses, they
    generally agreed that the results of the impact determinations as
    presented in the Glen Canyon Dam's final EIS were reasonable.  For
    example, although some researchers described the model used (the
    sand-mass balance model) to determine the impact of various flows on
    sediment as "simplistic" compared with models that are currently
    being developed by U.S.  Geological Survey researchers, none of the
    preliminary results from the new models contradict the conclusions
    reached by the sand-mass balance model.  Another researcher who
    worked on the vegetation and wildlife resources told us that although
    the EIS may have been based on incomplete information, subsequent
    science supports it.  The researcher further added that the results
    of the EIS were right on track with the best scientific evidence
    available at the time.

    The results of some impacts, however, such as how steady flows will
    affect fish, are still uncertain.  The individual responsible for
    leading the fish impact determinations process stated that the lack
    of final results from the fish research studies was frustrating and
    that the limited data allowed differences of opinion and scientific
    interpretation to arise about the impacts on fish resources.
    However, he added that he believed that if final data had been
    available, they would have refined the EIS team's conclusions but
    would not have changed the impact determinations or the preferred
    alternative.

    Although there is general agreement that the results of the Glen
    Canyon Dam's EIS are reasonable, there is also general agreement that
    additional research is needed to further refine or, in the case of
    fish resources, define the impact on resources of changes to the
    dam's operations.  For example, impacts to some archeological and
    cultural properties are bound to occur regardless of the flow
    alternative chosen.  To avoid or minimize the loss of historic
    properties and comply with the requirements of the National Historic
    Preservation Act, Reclamation developed a programmatic agreement
    between federal and state agencies as well as affected Native
    American tribes.  Implemented in 1994, the agreement led to numerous
    monitoring trips and site-stabilization efforts, but all parties
    involved believe that more research is needed to understand how water
    flow affects cultural resources.  Furthermore, several sediment
    researchers we interviewed stated that they supported the impact
    determinations and the preferred alternative.  However, one stated
    that as more information is obtained about the various systems in the
    canyon, the preferred alternative may become less restrictive in
    terms of the allowed water releases for hydropower use.

          RECLAMATION'S PROPOSED
          ADAPTIVE MANAGEMENT PROGRAM
    -------------------------------------------------------- Chapter 2:3.2

    Reclamation recognizes that uncertainties exist about the downstream
    impacts of water releases from the Glen Canyon Dam.  To address these
    uncertainties, Reclamation plans to initiate an Adaptive Management
    Program.  The concept of adaptive management is based on the
    recognized need for ongoing operational flexibility to respond to
    future monitoring and research findings and varying resource
    conditions.  The objective of the Adaptive Management Program is to
    establish and implement long-term monitoring programs that will
    ensure that the Glen Canyon Dam is operated, consistent with existing
    law, in a manner that will protect, mitigate adverse impacts to, and
    improve the values for which the Glen Canyon National Recreational
    Area and the Grand Canyon National Park were established.  According
    to Reclamation, long-term monitoring and research are essential to
    adaptive management.  Reclamation believes that such an effort is
    needed to measure the performance of any selected EIS alternative.
    In this way, managers can determine whether the alternative is
    actually meeting resource management objectives and obtain an
    additional understanding of the resources' responses to the dam's
    operations.

    Under Reclamation's current proposal, the Adaptive Management
    Program, which would be under the direction of the Secretary of the
    Interior, would be facilitated through an Adaptive Management Work
    Group.  The Adaptive Management Work Group, chartered under the
    Federal Advisory Committee Act, would include representatives from
    each of the EIS cooperating agencies, the basin states,\2 contractors
    for the purchase of federal power, recreation interests, and
    environmental organizations.  The work group would:

      -- develop proposals for (1) modifying the operating criteria,
         (2)research under the long-term monitoring program, and (3)
         other mitigation actions as appropriate and

      -- facilitate technical coordination and input from interested
         parties.

    The Adaptive Management Work Group would be supported by a monitoring
    and research center and a technical work group.  The Monitoring and
    Research Center would manage and coordinate monitoring activities,
    research, and inventory programs and maintain a scientific
    information database.  The technical work group would include
    technical representatives from federal, state, and tribal governments
    and their contractors.  This work group would translate the policy
    and goals of the Adaptive Management Work Group into resource
    management objectives and establish criteria and standards for
    long-term monitoring and research.  The independent scientific review
    panel would include scientific experts not otherwise participating in
    the long-term monitoring and research studies.  The responsibilities
    of this review panel would include reviewing scientific study plans,
    resource reports, and scientific logic and protocols.

    --------------------
    \2 The basin states consist of Arizona, California, Colorado, Nevada,
    New Mexico, Utah, and Wyoming.

    MOST KEY INTERESTED PARTIES
    SUPPORT RECLAMATION'S PREFERRED
    ALTERNATIVE FOR THE DAM'S
    OPERATIONS, BUT SOME CONCERNS
    REMAIN
    ============================================================ Chapter 3

    Since December 1982, Reclamation has been studying the effects of the
    Glen Canyon Dam on various resources within the Glen and the Grand
    canyons.  According to Reclamation, during this 14-year period, over
    $75 million was spent initially on the Glen Canyon Environmental
    Studies and then on the Glen Canyon Dam's EIS.  This research and
    analysis was aimed at providing sufficient information to recommend
    an operating plan for the dam that would permit the recovery of
    downstream resources while maintaining some level of hydropower
    flexibility.  Still, after all this time and money, the process of
    selecting a preferred alternative involved not only scientific
    evidence but also trade-offs and compromise.  This occurred because
    no one alternative could maximize benefits to all resources and
    because the impacts of some of the flow alternatives remain
    uncertain.  Nevertheless, over 83 percent of the key interested
    parties who responded to our survey support Reclamation's preferred
    alternative as a good starting point for the future operations of the
    Glen Canyon Dam.  In addition, many respondents supported the process
    used to develop the Glen Canyon Dam's EIS.  However, while expressing
    their support, some organizations still had concerns about the final
    EIS.

       RECLAMATION'S PROCESS FOR
       SELECTING A PREFERRED
       ALTERNATIVE
    ---------------------------------------------------------- Chapter 3:1

    The selection of a preferred alternative for the future operation of
    the Glen Canyon Dam involved a repetitive sequence of comparisons of
    the effects that each of the nine flow alternatives would have on the
    11 resources studied in the EIS.  All resources were evaluated in
    terms of whether each flow alternative had a positive or an adverse
    effect.  Reclamation's goal was to find an alternative dam-operating
    plan that would permit downstream resources to be maintained and if
    possible recover to acceptable long-term management levels while
    maintaining some flexibility in hydroelectric power capability.  The
    EIS team, which included up to 25 individuals representing 11 of the
    cooperating agencies, the U.S.  Geological Survey, and a private
    consultant, was primarily responsible for initially recommending a
    preferred alternative to the cooperating agencies.  This team, which
    also had been responsible for the scientific and technical
    development of the resource impact determinations, realized very
    early in the process that they would have to make trade-offs in the
    selection of a preferred alternative.  None of the alternatives could
    maximize potential benefits to all of the resources.  The Grand
    Canyon Trust environmental organization told us that

         "The Glen Canyon Dam EIS was a lengthy, complex process with
         many individuals and interests involved.  It is safe to say that
         the preferred alternative will not completely satisfy any one
         group, however it represents a balance of interests and a
         reasonable starting point for future dam operations."

    Another factor that the EIS team considered was that some affected
    resources were renewable, while others were viewed as nonrenewable.
    They avoided recommending an alternative dam-operating procedure that
    would result in significant loss of any existing nonrenewable
    resource and tried to minimize the adverse impacts to most renewable
    resources.  They eliminated the No-Action, Maximum Powerplant
    Capacity, and High Fluctuating Flow alternatives from consideration
    as a preferred alternative because the data indicated that while
    these alternatives were beneficial to hydropower, they would either
    increase or maintain conditions that result in adverse impacts to
    nonrenewable downstream resources.

    The EIS team also eliminated the Year-Round Steady Flow alternative
    from consideration as the preferred alternative.  This alternative
    exhibited the highest probability for net gain in riverbed sand, had
    the largest potential for expanding riparian vegetation, and received
    the highest ranking among all alternatives for white-water boating
    safety benefits.  However, the EIS team believed that the alternative
    probably exceeded sediment protection requirements for long-term
    management and would result in the lowest-elevation sandbars.  The
    team was also concerned that a completely stable flow alternative
    would permit vegetation to adversely affect camping beaches and over
    time reduce the value of wildlife habitat.  In addition, a stable
    flow may increase the negative interaction between native fish and
    predator and competitor nonnative fish.  Finally, the team eliminated
    this alternative because they believed that it did not provide
    benefits that could not be provided by other alternatives, yet it
    would cause large adverse effects to hydroelectric power generation.

    Of the remaining alternatives, the Existing Monthly Volume Steady
    Flow alternative was eliminated for reasons similar to those
    discussed for the Year-Round Steady Flow alternative.  The Low
    Fluctuating Flow alternative was eliminated to reduce
    redundancy--Reclamation considered the Modified Low Fluctuating Flow
    alternative an improved version of the Low Fluctuating Flow
    alternative.

    The EIS team considered the impacts associated with the three
    remaining alternatives (Moderate Fluctuating Flow, Modified Low
    Fluctuating Flow, and Seasonally Adjusted Steady Flow), although they
    were substantially different from the effect of the No-Action
    alternative, to be very similar in their assumed benefits to most
    downstream resources.  Reclamation's former NEPA Manager for the Glen
    Canyon Dam's EIS advised us that from an ecosystem perspective,
    sediment was identified as the key resource in the selection of a
    preferred alternative.  Riverbed sand and sandbars were the sediment
    resources of primary interest affected by riverflows below the dam.
    For sandbars to exist, sufficient amounts of sand must be stored on
    the riverbed.  Because the dam traps 90 percent of the sediment, the
    sand supply is currently limited to whatever is contributed by
    downstream tributaries and hundreds of side canyons.  Of equal
    concern is the river's capacity to transport sediment.  Riverflows
    must be large enough to move and deposit sediment but not so large as
    to carry the sediment out of the canyon ecosystem.  Frequent high
    flows, either from floods or large daily fluctuations, can transport
    greater amounts of sand than are contributed, causing a net decrease
    in both the amount of stored riverbed sand and the size of sandbars.
    Water release patterns modify the natural process of sandbar
    deposition and erosion.  Rapid drops in the level of the river drain
    groundwater from sandbars, thus accelerating sandbar erosion.  The
    EIS team concluded that any of these three alternatives were very
    similar in their assumed benefits to most downstream resources.

    The effects on native fish did, however, vary among the three
    remaining alternatives.  The Moderate Fluctuating Flow alternative
    provides potential minor benefits to native fish over no-action
    conditions.  The benefits from the Seasonally Adjusted Steady Flow
    alternative were uncertain given the improvement in habitat
    conditions that this alternative would provide for predator and
    competitor nonnative fish.  The team also determined that seasonally
    adjusted steady flows would create conditions significantly different
    from those under which the current aquatic ecosystem had developed
    since the construction of the dam.  Finally, for hydropower, the team
    determined that the Seasonally Adjusted Steady Flow alternative would
    have the highest economic cost of any alternative, estimated at about
    $124 million annually.  Ultimately, the EIS team decided to recommend
    the Modified Low Fluctuating Flow for the preferred alternative in
    the draft EIS.  The members believed that this alternative would
    create conditions that permit the recovery of downstream resources to
    acceptable management levels while maintaining a level of
    hydroelectric power flexibility.  The EIS team presented this
    recommendation to the cooperating agencies.  Most cooperating
    agencies concurred, and the group recommended that this alternative
    be adopted by Reclamation.  The draft EIS was issued by Reclamation
    in January 1994 with the Modified Low Fluctuating Flow identified as
    the preferred alternative.

    After the draft EIS was provided for public comment but before the
    issuance of the final EIS, Reclamation changed two parameters of the
    preferred alternative.  Specifically, the draft EIS' preferred
    alternative had a maximum release level of 20,000 cfs and a maximum
    upramp rate of 2,500 cfs per hour.  In the final EIS, Reclamation
    modified the preferred alternative to provide a maximum release level
    of 25,000 cfs and a maximum upramp rate of 4,000 cfs per hour.  The
    primary reason for these changes was to benefit hydropower.  The
    preferred alternative presented in the draft EIS had the same maximum
    release rate and upramp rate as the interim operating criteria.
    Reclamation stated that the interim operating criteria were based on
    the results of phase I of the Glen Canyon Environmental Studies and
    professional judgment and were designed to be environmentally
    conservative over the interim period.  With the benefit of the
    additional phase II results of the Glen Canyon Environmental Studies
    and EIS impact analyses, Reclamation stated that the upramp rate and
    maximum flow criteria were found to be overly conservative for the
    long term and that the two changes would not cause adverse impacts to
    downstream resources.  As a result, with the concurrence of the
    cooperating agencies, the preferred alternative was modified in the
    final EIS.

    In July 1995, Reclamation issued a document entitled Flow
    Modifications to the Glen Canyon Dam Environmental Impact Statement
    Preferred Alternative.  Those who commented on that document
    expressed concern that no studies on the specific upramp and maximum
    flow criteria had been conducted.  In October 1995, Reclamation
    issued a new report entitled Assessment of Changes to the Glen Canyon
    Dam Environmental Impact Statement Preferred Alternative from Draft
    to Final EIS.  This report provided a more detailed and focused
    assessment of the impacts associated with the increased upramp rate
    and maximum flow criteria.  While acknowledging that no new studies
    were conducted, Reclamation pointed out that the same was true for
    the parameters of the interim flows when they were selected and
    implemented.  Furthermore, Reclamation stated it was possible to
    determine the effects of these changes by using the extensive amount
    of knowledge gained from both phase I and phase II of the Glen Canyon
    Environmental Studies.  Reclamation concluded that the analyses were
    fully adequate to justify the change.

       SUPPORT FOR PREFERRED
       ALTERNATIVE IS SIGNIFICANT
    ---------------------------------------------------------- Chapter 3:2

    The respondents to our survey of key parties interested in the Glen
    Canyon Dam's EIS overwhelmingly supported Reclamation's preferred
    alternative--the Modified Low Fluctuating Flow operating regime.  We
    surveyed 37 key organizations and individuals about whether they
    support the preferred alternative and what, if any, remaining
    concerns they may have about implementing this alternative as the
    future operating plan for the Glen Canyon Dam.  Our judgmental sample
    included federal and state resource agencies, American Indian tribes,
    water and power suppliers and users, and environmental groups.
    Specifically, Reclamation identified 23 of these organizations and
    individuals as providing the most substantive comments on the draft
    EIS.  We excluded David Marcus from our survey analysis because he
    had commented on the draft EIS as a consultant to American Rivers and
    preferred to provide us with his comments through that organization.
    In addition, we surveyed any other organizations that were considered
    to be cooperating agencies in the development of the impact statement
    as well as other key interested parties.  We also queried the seven
    Colorado River Basin states:  Arizona, California, Colorado, Nevada,
    New Mexico, Utah, and Wyoming.

    Over 83 percent (25 of 30) of the respondents to our survey supported
    the preferred alternative.  Of the five remaining respondents, three
    organizations stated that they had no position on the issue, while
    two, the San Juan Southern Paiute Tribe and the Grand Canyon River
    Guides, believe that the current interim flows would be more
    protective of resources and, as such, consistent with the intent of
    the Grand Canyon Protection Act.  Table 3.1 provides details on whom
    we surveyed and their response, if any.

                                        Table 3.1

                           Key Interested Parties' Responses on
                           Support of the Preferred Alternative

                               Support preferred          Other alternative
    Respondents                alternative                supported
    -------------------------  -------------------------  --------------------------
    Federal agencies
    --------------------------------------------------------------------------------
    U.S. Fish and Wildlife     Yes                        Modified Low Fluctuating
    Service                                               Flow as modified by the
                                                          reasonable and prudent
                                                          alternative

    Environmental Protection   Yes                        None
    Agency

    National Park Service      Yes                        None

    Department of the          No position
    Interior -Office of
    Environmental Policy and
    Compliance

    Bureau of Indian Affairs   Yes                        Interim Low Fluctuating
                                                          Flow and Seasonally
                                                          Adjusted Steady Flow

    National Research Council  Nonrespondent

    Western Area Power         Yes                        None
    Administration

    State agencies

    Arizona Game and Fish      Yes                        None
    Department

    Colorado River Board of    No position
    California

    Colorado River Commission  Nonrespondent
    of Nevada

    Arizona Department of      Yes                        None
    Water Resources

    New Mexico Interstate      Yes                        Modified Low Fluctuating
    Stream Commission                                     Flow as modified by
                                                          adaptive management

    Colorado Department of     No position
    Natural Resources

    Utah Division of Water     Yes                        None
    Resources

    Wyoming State Engineer's   Yes                        None
    Office

    Indian tribes

    Hopi Tribe                 Yes                        None

    Hualapai Tribe             Nonrespondent

    Navajo Nation              Yes                        None

    San Juan Southern Paiute   No                         Interim Low Fluctuating
    Tribe                                                 Flow

    Pueblo of Zuni             Yes                        None

    Southern Paiute            Yes                        None
    Consortium

    Water and power
    suppliers, users,
    associations, etc.

    Colorado River Energy      Yes                        None
    Distributors Association

    Plains Electric            Nonrespondent
    Generation and
    Transmission Coop, Inc.

    Salt River Project         Yes                        None

    Upper Colorado River       Yes                        Modified Low Fluctuating
    Commission                                            Flow as modified by
                                                          adaptive management

    Interest groups

    America Outdoors           Yes                        Seasonally Adjusted Steady
                                                          Flow

    American Fisheries         Nonrespondent
    Society

    Arizona Flycasters         Nonrespondent

    American Rivers            Yes                        None

    Environmental Defense      Yes                        None
    Fund

    Trout Unlimited (Arizona   Yes                        None
    Council)

    Friends of the River       Nonrespondent

    Grand Canyon River Guides  No                         Interim Low Fluctuating
                                                          Flow

    Grand Canyon Trust         Yes                        None

    Sierra Club Legal Defense  Yes                        None
    Fund

    Sierra Club                Yes                        None

    Individual

    Dr. Larry Stevens          Yes                        None
    --------------------------------------------------------------------------------

       RESPONDENTS ALSO SUPPORT
       RECLAMATION'S EIS PROCESS
    ---------------------------------------------------------- Chapter 3:3

    Many respondents to our survey supported the process used by
    Reclamation to complete the EIS.  In fact, many respondents commended
    Reclamation for its efforts to produce a comprehensive EIS.  For
    example, the National Park Service stated that the EIS process was
    directed very well by Reclamation and that alternatives for the
    operation of the dam were fully explored.  American Rivers, an
    environmental interest group, stated that the EIS is a high-quality
    document that reflects a process that was exemplary in its scope,
    thoroughness, and overall achievement.  The Grand Canyon Trust stated
    that the EIS represents a significant and productive effort to
    understand the complexities of the river's ecosystem below Glen
    Canyon Dam and to include broad participation by the public and
    parties vitally interested in the issue.  They further stated that in
    addition to increasing the scientific understanding of the Colorado
    River system, a great deal of trust and good faith were created
    between traditionally contentious interest groups.  The Navajo Nation
    stated that overall, they were very pleased with the EIS process,
    citing that Native American concerns were taken into account by
    Reclamation and that the affected tribes had real input into the
    development of the EIS.

       SEVERAL CONCERNS REMAIN ABOUT
       THE IMPLEMENTATION OF THE DAM'S
       NEW OPERATING PROCEDURES
    ---------------------------------------------------------- Chapter 3:4

    While respondents to our survey were generally positive about the
    selection of a preferred alternative and the process used by
    Reclamation to develop the EIS, some were still concerned about the
    preferred alternative and the Glen Canyon Dam's final environmental
    impact statement.  These concerns focus on the manner in which
    compliance with the Endangered Species Act will be achieved, the
    economic impact of reducing the Glen Canyon Dam's hydroelectric power
    capacity, the lack of consideration in the EIS of other causes of
    downstream adverse impacts other than water releases from Glen Canyon
    Dam, the simultaneous changing of two of the dam's operating
    parameters very late in the EIS process, the adequacy of the flood
    frequency reduction measures, the need for selective withdrawal
    structures, and issues related to adaptive management, including
    future research and monitoring.

    The U.S.  Fish and Wildlife Service supports the preferred
    alternative as modified by its reasonable and prudent alternative.
    FWS's biological opinion expressed concern that the preferred
    alternative recommended flows would likely jeopardize the continued
    existence of two endangered species, the humpback chub and the
    razorback sucker.  The biological opinion's reasonable and prudent
    alternative would modify the preferred alternative with seasonally
    adjusted steady flows about 25 percent of the time.  FWS and
    Reclamation agreed to categorize these flows as experimental, or
    research flows, so that studies could be conducted to verify an
    effective dam-operating plan and to include those flows with another
    element of the reasonable and prudent alternative, adaptive
    management.  However, there are concerns on the part of the Colorado
    River Energy Distributors Association, which represents over 140
    nonprofit utilities that purchase power from the Western Area Power
    Administration (WAPA), that the implementation of endangered fish
    research flows will proceed regardless of the outcome of the Adaptive
    Management Program.  The association strongly supports the EIS
    preferred alternative as a reasonable point to begin modified dam
    operations and adaptive management.  However, the association also
    believes that an important part of the adaptive management process is
    that if an analysis of a research proposal indicates an inappropriate
    risk to the endangered fish or other resource, the Secretary could
    decide not to pursue this element of the preferred alternative.  As
    such, the association objects to the language in the final EIS and
    the final biological opinion that indicates that the research flows
    will go forward regardless of the outcome of the adaptive management
    research design and risk assessment.

    The Colorado River Energy Distributors Association and the Salt River
    Project, an agricultural improvement district that provides
    electrical service to various counties in the state of Arizona, are
    concerned that the economic cost of reducing the hydroelectric power
    capacity of the Glen Canyon Dam is understated in the EIS.  Both the
    association and the Salt River Project believe that the preferred
    alternative does not adequately address the economic cost to power
    users of research flows.  In addition, the Salt River Project
    believes that the EIS does not analyze the full economic impact of
    the preferred alternative on Salt River and its customers and on WAPA
    and its customers, resulting from WAPA's being unable to fulfill its
    obligations under an exchange agreement.  The exchange agreement
    obligated Salt River to build and operate power generation facilities
    near customers in Colorado and New Mexico and to deliver the power
    produced by those facilities to WAPA to serve those customers.  In
    exchange, WAPA was obligated to deliver a like amount of power to the
    Salt River Project from the Glen Canyon Dam.

    WAPA stated that the EIS assumes that the dam's operations (water
    releases) are the only cause of the adverse impacts on the downstream
    resources and that, therefore, changing the dam's operations is the
    only technique or method available for managing and enhancing those
    resources.  WAPA believes that other causes of downstream impacts
    include lack of sediment, cold water temperatures, nonnative fish
    species, and human usage.  Accordingly, they believe that changing
    the operations at Glen Canyon Dam is not the only, or necessarily the
    best or lowest-cost, means of achieving positive resource changes.
    WAPA believes that a more holistic approach to the management of the
    downstream resources should be taken and supports the investigation
    of both operational and nonoperational management techniques,
    practices, and programs.  Although WAPA supports the preferred
    alternative, it stated that the concepts of pumping sand, protecting
    beaches with native materials, augmenting sediment, managing
    vegetation, restricting human use, restricting raft moorings,
    reducing the competition for native fish, developing new tributary
    habitats for native fish, and using a reregulation dam (build another
    dam below the Glen Canyon Dam to regulate river flow) are all valid
    management techniques that merit detailed investigation and
    consideration.

    Several environmental and recreational organizations, although
    supporting the preferred alternative, were concerned that Reclamation
    changed certain parameters of the preferred alternative very late in
    the EIS process.  Specifically, the draft EIS' preferred alternative
    had a maximum release level of 20,000 cfs and a maximum rate of
    increase (upramp rate) of 2,500 cfs per hour.  In the final EIS,
    Reclamation modified the preferred alternative to allow for a maximum
    release level of 25,000 cfs and a maximum upramp rate of 4,000 cfs
    per hour.  Two basic concerns exist about this change:  (1) the
    higher parameters were substituted in the final EIS without adequate
    scientific evidence that such flows would not negatively affect the
    downstream resources of the Glen and Grand canyons and (2) two
    parameters were changed simultaneously, which could compromise the
    ability to scientifically monitor and assess the future impacts of
    these flow parameters in the proposed adaptive management framework.
    Reclamation believes that it has adequately addressed both of these
    concerns by conducting an assessment of the proposed changes.  Some
    agencies, including the Wyoming State Engineer's Office, America
    Outdoors, American Rivers, and the Sierra Club Legal Defense Fund
    still believe that adequate specific scientific testing was not done
    to fully evaluate the effect of changing these flow parameters.
    However, these groups still support the preferred alternative at this
    time because of Reclamation's proposed Adaptive Management Program.

    The New Mexico Interstate Stream Commission believes that the
    spillway gates on the Glen Canyon Dam must be increased in height by
    about 4.5 feet to add the flexibility to accomplish flood protection
    without reducing the water supply available to the Upper Colorado
    Basin.  The Commission, which supports the preferred alternative,
    also believes that the selective withdrawal outlet proposal for Glen
    Canyon Dam has not been adequately justified; the estimated cost of
    $60 million needs to be arrayed against the resulting benefits; and
    an assessment needs to be made of the potential adverse impacts
    associated with increasing water temperature.

    Future monitoring and research efforts were a concern of several
    groups, including federal agencies, Native American tribes, and an
    environmental group.  For example, American Rivers urged Reclamation
    to do everything in its power to ensure that an effective Adaptive
    Management Program be in place or sufficiently delineated in scope
    and substance and that a specific long-term monitoring program be
    identified that will quantify any impacts before the proposed flow
    changes are implemented.

    AIR QUALITY
    =========================================================== Appendix I

    In the Glen Canyon Dam's environmental impact statement (EIS), air
    quality is identified as an issue for both the immediate vicinity of
    the Grand Canyon and the surrounding six-state area, including parts
    or all of Utah, Wyoming, Colorado, Arizona, New Mexico, and Nevada.
    The power needs of this area are served by the Salt Lake City Area
    Integrated Projects, a group of power generation facilities that
    include the Glen Canyon Dam.  Although the Glen Canyon Dam's
    hydroelectric powerplant does not cause air pollution, a change in
    its operations would affect the regional electrical power system.
    The Glen Canyon Dam has historically been used to generate power
    during periods of high demand for electricity, commonly known as
    peaking power.  The loss or reduction of that capability would mean
    that another source of peaking power would be required.  If that
    alternative source of power used fossil fuel, there would be a net
    change in the power system's emissions.  Fossil fuels contain
    hydrocarbons, whose combustion can result in emissions of such
    atmospheric pollutants as sulfur dioxide and nitrogen oxides.

    Reclamation found that the region's air quality would improve under
    all restricted fluctuating and steady flow alternatives for operating
    the dam.  Generally, this would occur because the sources of
    replacement power would produce less emissions than the sources of
    power used by the current Integrated Projects System.  According to
    Reclamation and the EIS team member who was responsible for the air
    quality impact determination, the process used to come to this
    conclusion was appropriate, the data used were the best scientific
    information available at the time, and the results were reasonable.

       DESCRIPTION OF THE RESOURCE
    --------------------------------------------------------- Appendix I:1

    While the Grand Canyon region enjoys some of the cleanest air in the
    lower 48 states, the visual range is affected by haze.  This haze is
    generally at its worse during the summer months.  Air is carried into
    the Grand Canyon area from the south and west, where it picks up
    pollutants from urban and industrial areas.  As a result, during the
    summer, the average visibility is only 100 miles, and it drops below
    68 miles 10 percent of the time.  Sulfates, which are produced from
    sulfur dioxide, are the major contributors to haze in the Grand
    Canyon.  The Navajo Generating Station near Page, Arizona, has been
    identified as a major source of sulfates in the vicinity of the Grand
    Canyon.

    During the winter, strong cold fronts bring in clean air from
    sparsely populated areas.  The average visibility during these months
    is 158 miles, but it reaches more than 211 miles 10 percent of the
    time.  Between the passages of cold fronts, however, the air
    stagnates, and pollution from local sources sinks into the canyon.
    The pollution can be trapped by strong inversions until another cold
    front again brings in clean air.

       EFFECTS OF PRE- AND POSTDAM
       CONDITIONS ON AIR QUALITY
    --------------------------------------------------------- Appendix I:2

    Although power production at the Glen Canyon Dam has had no direct
    effect on air quality at the Grand Canyon or in the region, an
    analysis of the impacts on air quality was included in the EIS
    because the Glen Canyon hydroelectric facility is part of a regional
    utility system that has some sulfate-producing facilities.  The
    region's air quality is affected by the operation of these
    interconnected powerplants.  For example, the National Park Service
    identified the Navajo Generating Station as a major source of
    sulfates in the Grand Canyon's air.  In response to the Park
    Service's findings, the Environmental Protection Agency mandated
    modifications to reduce the plant's emissions.  Although the Navajo
    Generating Station is independent of the Glen Canyon Dam's operations
    and modifications will be made to it regardless of which EIS
    operating alternative is selected, the air quality in the Grand
    Canyon would likely improve because of the modifications.

    The changes in the operations at the Glen Canyon Dam might indirectly
    affect the region's air quality by forcing reliance on other types of
    power-generating facilities.  For example, if power generated in the
    marketing area served by the Salt Lake City Area Integrated Projects
    were changed from older existing powerplants to new, cleaner-burning
    facilities, there would be less emissions, all else being the same.
    Conversely, if the reductions in power production from hydroelectric
    plants are replaced with power from existing powerplants that burn
    coal, there would be an increase in the amount of sulfur dioxide and
    nitrogen oxide emissions in the region.

       ISSUE
    --------------------------------------------------------- Appendix I:3

    The final EIS considers how the dam's operations affect other
    electricity-producing facilities in the area, including those that
    have impacts on air quality.

       INDICATORS
    --------------------------------------------------------- Appendix I:4

    The resource indicators considered in the EIS were the amount of
    sulfates in the Grand Canyon's air and the tons of sulfur dioxide and
    nitrogen oxides in the region's air.

       METHODOLOGY USED TO MAKE IMPACT
       DETERMINATION
    --------------------------------------------------------- Appendix I:5

    Reclamation assigned the responsibility for the development of the
    air quality section of the EIS to a member of the National Park
    Service, who at the time was assigned to the Grand Canyon National
    Park.  The impacts on the air quality in the Grand Canyon's immediate
    vicinity and across the region served by Salt Lake City Area
    Integrated Projects' power-marketing system were evaluated for each
    of the dam's operating alternatives.  Reclamation used the same
    power-modeling data used to analyze hydropower impacts to determine
    the amount of sulfur dioxide and nitrogen oxide emissions that may
    occur under the dam's various operating scenarios.  (See app.  V of
    this report for details on Reclamation's hydropower analysis).  For
    the final EIS, these studies indicate that the region's air quality
    will improve under the four restricted fluctuating and three steady
    flow alternatives.  Because these emissions analyses included
    assumptions for long-term (50-year) power system expansion plans,
    some of the impacts are based on specific assumptions about power
    generation technology, demand for power, public attitudes, and
    political and economic climates.

    In making the air quality impact determinations, Reclamation made a
    number of key assumptions.  For example, the analysis assumes that
    any loss of power generation at the Glen Canyon Dam will be partly
    absorbed by currently available generation at other plants in the
    region.  The analysis further assumes that, over time, gas combustion
    turbines will be added to the system to replace older, inefficient
    facilities.  Because natural gas is a cleaner-burning energy source
    than coal, emissions will be reduced over the short term.  However,
    as the demand for electric power increases in the future, new
    powerplants will be needed.  These newer plants, it is assumed, will
    produce less emissions than the existing plants because existing
    clean air standards are more stringent than those in effect when the
    older plants were constructed.  There would have to be a relaxing of
    current environmental laws and regulations to invalidate these
    assumptions.

    The air quality impact analyses determined that any one of the steady
    or restricted fluctuating flow alternatives was acceptable.  However,
    the EIS air quality team leader favors the preferred alternative
    because, in his opinion, it has the least detrimental impact when the
    entire ecosystem of the Glen and Grand canyons is considered.

       EFFECTS OF THE FLOW
       ALTERNATIVES ON AIR QUALITY
    --------------------------------------------------------- Appendix I:6

    According to the final EIS, the amount of Glen Canyon Dam hydropower
    that would need to be replaced varies under each of the dam-operating
    alternatives in the EIS.  The net effect on the region's air quality
    under each alternative would be a slight reduction in emissions.
    Under the No-Action alternative, it was anticipated that gas
    combustion turbines, which are cleaner burning than coal-burning
    systems, will soon be added to the regional power system to replace
    older and more inefficient coal facilities.  These additions should
    reduce the system's emissions over the first 5 years of operation.
    The assumptions under the Maximum Powerplant Capacity alternative
    would be essentially the same as those under the No-Action
    alternative.

    Under the restricted fluctuating and steady flow alternatives, the
    amount of electrical energy produced at the dam during the day would
    be reduced, whereas the amount of energy produced at night would
    increase.  Under this scenario, as the demand for electrical energy
    increases, especially during daytime hours, additional powerplants
    would be needed sooner than under the No-Action alternative.  These
    new powerplants would produce less emissions than older,
    less-efficient existing plants because of today's more stringent
    emissions standards and because some of these plants would burn
    natural gas.

       ASSESSMENT OF IMPACT
       DETERMINATIONS
    --------------------------------------------------------- Appendix I:7

    During our review, we did not receive any negative comments about
    Reclamation's air quality impact determinations.  However, the draft
    EIS generated 29 public comments related to concerns about air
    quality.  The comments varied from observations and concerns about
    the analysis methods used, to the need for further details and
    support for some statements.  For example, there was some concern
    that the EIS did not do a good job of identifying as speculative its
    projections of the potential developments in power generation
    technologies, future demand for power, public attitudes, and
    political and economic climates.  Reclamation agrees that forecasts
    over a 50-year period are speculative, but it also believes that the
    results of the hydropower-modeling studies provide the best available
    information on the powerplants' impacts on air quality.

    Another concern expressed was that the lost generating capacity at
    the Glen Canyon Dam would have to be replaced by the use of
    fossil-fueled powerplants or other sources that are more expensive,
    nonrenewable, and polluting.  Reclamation told us that the hydropower
    studies, which looked at all affected utilities, concluded that there
    would be a decline in emissions under several alternatives, including
    the preferred alternative.

    The individual who was responsible for the air quality section of the
    EIS told us that he believed that

      -- the process used in making the air quality impact determinations
         was reasonable,

      -- the methodologies employed in this process were adequate for the
         decision-making process, and

      -- the results of the analysis were reasonable.

    However, he stated that he could not judge the overall quality of the
    data used in the analysis because it was proprietary and he did not
    have access.

       SCOPE AND METHODOLOGY
    --------------------------------------------------------- Appendix I:8

    To identify how Reclamation determined the impact of various flow
    alternatives on air quality, we reviewed the scientific studies and
    research materials that were used by Reclamation in making its impact
    determinations.

          KEY STUDIES IDENTIFIED
    ------------------------------------------------------- Appendix I:8.1

    We identified the following studies as the primary scientific sources
    of the data included in the air quality section of the EIS:

      -- Electric Utility Financial and Production Cost Model (prepared
         by the Environmental Defense Fund).

      -- Material prepared by Mike Roluti, Bureau of Reclamation.

      -- Preliminary Research Findings - Glen Canyon Environmental
         Studies, by Duncan Patten and Dave Wegner, dated September 11,
         1992.

      -- Stone and Webster Power Modeling Reports (prepared for the
         Western Area Power Administration).

    In addition, to determine what, if any, concerns were expressed about
    the air quality analysis presented in the draft EIS, we reviewed the
    Bureau of Reclamation's Operation of Glen Canyon Dam Draft
    Environmental Impact Statement:  Public Comments Analysis Report
    prepared by the Bear West Consulting Team for the Bureau of
    Reclamation.  To determine other concerns that were expressed about
    air quality issues in the preparation of the EIS, we also reviewed
    the Final Analysis Report on Scoping Comments, Bureau of Reclamation,
    dated March 12-May 4, 1990, Bear West Consulting Team.

          OFFICIALS INTERVIEWED
    ------------------------------------------------------- Appendix I:8.2

    In order to assess the methodology used, how well it was implemented,
    the quality of the data used, and the reasonableness of the results
    of the air quality segment of the EIS, we obtained the views of Mr.
    Jerry Mitchell, the official responsible for developing the air
    quality impact determination.  We also spoke with members of the
    Power Resource Committee who performed the hydropower analysis, which
    was the basis for the air quality analysis.  The names of these
    individuals and details on the hydropower analysis are contained in
    appendix V of this report.

    CULTURAL RESOURCES
    ========================================================== Appendix II

    Cultural resources include archeological sites and Native American
    traditional cultural properties and resources.  The affected area
    containing these sites and properties includes a 255-mile section of
    the Colorado River corridor within the Glen and the Grand canyons and
    lands adjacent to the Navajo Nation, the Havasupai and Hualapai
    Reservations, and the Lake Mead National Recreation Area.  The tribes
    that have ancestral claims to the Grand Canyon and that continue to
    use the area today include the Havasupai, the Hopi, the Hualapai, the
    Navajo, the Southern Paiute, and the Zuni.

    The Glen Canyon Dam changed the pattern of sediment deposition,
    erosion, and flooding through the Glen and Grand canyons.  As a
    result, archeological sites that were once protected by sandbars and
    terraces have become increasingly exposed, making them vulnerable to
    erosion, deterioration, and ultimate destruction.  While erosion will
    continue to occur under any operating alternative selected, some flow
    alternatives are more favorable for enhancing the long-term
    preservation of cultural resources than others.

    According to representatives of Native American groups, the
    information used to analyze cultural resources issues was the best
    and most up to date available.  In addition, many researchers and
    representatives of Indian tribes believe that Reclamation went beyond
    the requirements of the National Environmental Policy Act (NEPA) in
    preparing the cultural resource impact determination.  Those involved
    in the process were also highly complimentary of Reclamation's
    efforts to include Native American tribes in making the impact
    determinations.  As a result of the cooperation of all parties
    involved, the cultural resources team was able to reach a consensus
    on the impacts that various flow alternatives would have on the
    resources.  Also, although not tasked to reach a consensus on a
    preferred alternative, the individual cultural resource team members
    each agreed on the Modified Low Fluctuating Flow alternative as the
    preferred dam operating regime.

       DESCRIPTION OF THE RESOURCE
    -------------------------------------------------------- Appendix II:1

    All natural resources are considered sacred by Indian tribes, and
    some resources are considered vital for the continuation of
    traditional cultural practices.  The cultural resources in the EIS
    study area include prehistoric and historic archeological sites,
    traditional cultural properties, and other resources that are
    important to Native Americans in maintaining their cultural heritage,
    lifeways, and practices.  A variety of archeological sites were
    identified--for example, pueblos (habitation sites of four or more
    contiguous rooms); storage sites (granaries or cists); sherd and
    lithic scatter (scatter or concentration of ceramic sherds and debris
    from making stone tools); rock art (pecked, incised, scratched, or
    painted designs, symbols, or figures on rock); and burial sites.
    Many of these sites were determined to be eligible for inclusion on
    the National Register of Historic Places.

    Also, many properties and resources within the Colorado River
    corridor, despite not being archaeologically significant, are
    culturally significant to Native American beliefs and practices.  The
    culturally significant sites include plant-gathering areas,
    landforms, springs, prayer-offering sites (shrines), and mineral
    deposits.  Also significant to some Native American tribes are
    willows, giant reeds, and many birds, including yellow warblers and
    yellow throats.

       EFFECTS OF PRE- AND POSTDAM
       CONDITIONS ON CULTURAL
       RESOURCES
    -------------------------------------------------------- Appendix II:2

    Until the mid-1980s, it was generally thought that cultural resources
    were not affected by the operation of the Glen Canyon Dam.  The
    belief was that archeological remains would not be found below the
    historic high-water mark in the river corridor.  This belief was
    based on two assumptions:  (1) that prehistoric people were aware of
    the river's flood potential and would thus build above the floodplain
    and (2) that any cultural remains close to the river would have been
    washed away over the past thousands of years.

    In 1989, the National Park Service and the U.S.  Geological Survey
    conducted a pilot research project to evaluate erosion at
    archeological sites in the Grand Canyon.  The project's results
    suggested that the operation of the Glen Canyon Dam contributed to
    ongoing site erosion.  The dam affected sediment deposition, erosion,
    and flooding through the Glen and Grand canyons.  As a result,
    river-deposited sandbars and high terraces (the surface form of a
    high sediment deposit having a relatively flat surface and a steep
    slope facing the river) have been eroded and, in some cases,
    destroyed.  The archeological sites once protected by these sediment
    deposits have become increasingly exposed to erosion and ultimate
    destruction.

       ISSUE
    -------------------------------------------------------- Appendix II:3

    The issue presented in the final EIS for cultural resources is how do
    the dam's operations affect the continued existence of cultural
    resources in the Glen and Grand canyons?

       INDICATORS
    -------------------------------------------------------- Appendix II:4

    The indicators studied for cultural resources and listed in the final
    EIS were

      -- the number of archeological sites directly, indirectly, or
         potentially affected and

      -- the number of Native American traditional cultural properties
         and resources directly, indirectly, or potentially affected.

       METHODOLOGY USED TO MAKE IMPACT
       DETERMINATIONS
    -------------------------------------------------------- Appendix II:5

    To provide baseline cultural resource information for inclusion in
    the Glen Canyon Dam's EIS, Reclamation contracted with the National
    Park Service to conduct an archeological inventory in August 1990.
    The inventory, which was conducted by staff from the National Park
    Service and Northern Arizona University, was completed in May 1991.
    The inventory gathered basic information on the numbers, types,
    locations, National Register eligibility, and physical conditions of
    all cultural resources within the area that have been or could be
    affected by the operations of the Glen Canyon Dam.  The inventory
    identified 475 sites in the Colorado River corridor, 336 of which had
    been or could be affected by the existence and operation of the dam.
    The remaining 139 sites did not exhibit any effects from the dam's
    operations and were excluded from further study.  The EIS summarized
    these impacts, as shown in table II.1.

                                   Table II.1

                          Glen Canyon Dam's Impacts on
                              Archeological Sites

    Type of impact                                         Number of sites
    --------------------------------------------------  ------------------
    Direct--site erosion immediately caused by river                    33
     flows
    Indirect--sediment loss at the site or arroyo                      124
     cutting near the site
    Potential--loss of site due to catastrophic event                  179
     such as unexpectedly high flows
    ----------------------------------------------------------------------
    In addition to the 336 sites, many Native American cultural
    properties and resources, especially plant and animal species that
    depend on sandbars and high terraces, have been adversely affected by
    the flows from the Glen Canyon Dam.  According to the cultural
    resource writing team leader, the information on cultural resources
    and properties was obtained from research conducted by the following
    Native American tribes:  Hopi, Hualapai, Southern Paiutes, Navajo,
    and Zuni.

    The National Historic Preservation Act requires that an impact
    determination be made when any action by a federal agency could
    affect sites included in or eligible for the National Register of
    Historic Places.  The process for such determinations is spelled out
    in 36 C.F.R.  800 and requires that a determination of "effect" or
    "no effect" be made.  When there is an effect, a "finding of no
    adverse effect" or "finding of adverse effect" is required.
    Mitigating measures must be taken when there is a "finding of adverse
    effect."

    Because dam-related impacts to archaeological sites would continue
    regardless of the alternative flow patterns, the operations of the
    Glen Canyon Dam were considered to have an adverse effect on cultural
    resources located on the terraces that have formed along the river
    corridor.  However, the rate at which impacts would occur could be
    affected by alternative operations, principally through flood
    frequency reduction measures.

    To assess the impacts of various alternatives on cultural resources,
    Reclamation established a cultural resource team.  The team leader
    was an archeologist with the National Park Service.  The team leader
    was primarily responsible for cultural resource analysis, including
    archeological and tribal issues and compliance with the National
    Historic Preservation Act.  The team members included representatives
    of the Hualapai Tribe, the Navajo Nation, and the Hopi Tribe.

    The team was asked to analyze the archeological data and cultural
    resource issues and determine how various flow alternatives for the
    dam affected these resources.  The team was not required to arrive at
    one specific preferred alternative.

    In addition, tribal representatives from other interested tribes
    would periodically attend various EIS meetings to discuss the
    cultural resources issues.  The cultural resource information for
    tribes that did not have representation on the team was prepared for
    them by the cultural resource team.

       EFFECTS OF THE FLOW
       ALTERNATIVES ON CULTURAL
       RESOURCES
    -------------------------------------------------------- Appendix II:6

    According to the final EIS, the dam's operations influence the rate
    at which archeological sites and cultural resources are affected.
    Flow alternatives that maintain the sand balance and allow for its
    distribution along the river corridor would enhance the long-term
    preservation of cultural resources.  The most favorable operation
    alternatives are those which produce a positive net sand balance in
    the river system while maintaining a higher elevation of sand
    deposits.  Of the nine alternatives, six (Moderate Fluctuating,
    Modified Low Fluctuating, Interim Low Fluctuating, Existing Monthly
    Volume Steady, Seasonally Adjusted Steady, and Year-Round Steady
    flows) cause moderate impacts on the sites but nevertheless allow for
    a net positive sediment balance in the system and potential sediment
    redeposition in areas that would protect cultural resources.  The
    No-Action and the Maximum Powerplant alternatives were shown to have
    major impacts affecting all of the archeological sites, and the High
    Fluctuating Flow alternative was found to have the potential to have
    major adverse impacts on 263 sites.

       NEED FOR CONTINUED STUDIES OF
       CULTURAL RESOURCES
    -------------------------------------------------------- Appendix II:7

    The assessment of impacts on cultural resources will be an ongoing
    endeavor.  The National Historic Preservation Act, as amended in
    1992, requires federal agencies to develop measures to avoid or
    minimize the loss of historic properties resulting from their actions
    and recommends a long-term monitoring program to assess the changing
    conditions of cultural resources.  In addition, long-term monitoring
    is required by the Grand Canyon Protection Act of 1992.

    To comply with these requirements, Reclamation and the National Park
    Service developed a programmatic agreement for the continued
    monitoring of cultural resources and for the mitigation of the
    adverse effects of the dam on threatened cultural resources.  The
    programmatic agreement stipulates that these long-term
    responsibilities will be outlined in a Historic Preservation Plan to
    be developed for cultural resources along the river corridor.  The
    following are signatories to the programmatic agreement.

    Advisory Council on Historic Preservation
    Arizona State Historic Preservation Officer
    Bureau of Reclamation
    Hopi Tribe
    Hualapai Tribe
    Kaibab Paiute Tribe
    National Park Service
    Navajo Nation
    Paiute Indian Tribe of Utah for the Shivwits Paiute Tribe
    San Juan Southern Paiute Tribe
    Zuni Pueblo

    At the time of our review, the Havasupai Tribe was also expected to
    be a signatory to the programmatic agreement.  The agreement was
    officially implemented in February 1994, and numerous
    river-monitoring trips, site-stabilization efforts, and periodic
    meetings among the signatories have already been held.  The agreement
    calls for continued monitoring within the river corridor.

       ASSESSMENT OF IMPACT
       DETERMINATIONS
    -------------------------------------------------------- Appendix II:8

    The cultural resource writing team members and several of the
    representatives from the cooperating agencies who were concerned
    about the cultural resource issues were complimentary of
    Reclamation's effort to solicit information from and include Native
    American tribes in the EIS process.  There was a consensus that the
    data used to address the impacts on the cultural/archeological
    resources were the best and most up to date that were available.

    Several comments commended Reclamation for conducting an open and
    well-researched and well-documented EIS process.  For example, one
    commenter stated that Reclamation went beyond the requirements of
    NEPA by funding new research used to make impact determinations.

    According to the leader and other members of the cultural resource
    team, there was consensus among the members on how to present
    cultural resource issues.  The tribes also presented a unified
    position.  A representative from the Bureau of Indian Affairs noted
    that he was not aware of any disagreement from any tribes about the
    EIS process.  According to most representatives of the Native
    American groups we interviewed, the scientific data used in the
    archeological and cultural resource sections of the EIS were the most
    recent data available.  Furthermore, many representatives stated that
    all relevant information available at the time was sought out and
    used and that the data presented in the EIS are factual and do not
    contradict historical tribal information or other known data.  While
    most of the information used in the cultural resources section of the
    EIS was in draft form, no new or additional data have emerged that
    would change or contradict the information in the EIS.

    The cultural resource team members, as well as most representatives
    from the Native American tribes, support the preferred alternative
    (the Modified Low Fluctuating Flow).

    The cultural resources team leader's overall position was that

      -- the process used in making cultural resource impact
         determinations was reasonable,

      -- the methodologies employed in this process were appropriate,

      -- the data used were the best available, and

      -- new information that had been obtained at the time of our audit
         work did not alter the facts used in arriving at the impact
         determinations in the final EIS.

       SCOPE AND METHODOLOGY
    -------------------------------------------------------- Appendix II:9

    In addition to identifying how Reclamation determined the impact of
    various flow alternatives on cultural resources, we evaluated the
    scientific foundations, the study review process, the EIS work
    groups, and the impact determinations.  We also gathered studies and
    research materials that were instrumental to Reclamation in making
    the EIS decisions.

          KEY STUDIES IDENTIFIED
    ------------------------------------------------------ Appendix II:9.1

    We identified the following studies as the primary scientific
    foundations for the data included in the cultural resources section
    of the EIS:

      -- Big River Canyon:  Southern Paiute Ethnographic Resource
         Inventory and Assessment for Colorado River Corridor, Glen
         Canyon National Recreation Area, Utah and Arizona, and Grand
         Canyon National Park, Arizona, June 1994, and Storied Rocks:
         Southern Paiute Rock Art in the Colorado River Corridor,
         September 1995.  These reports were prepared by the Southern
         Paiute Consortium and the University of Arizona.  According to
         the consortium, research data collected for the studies were
         used in preparing the EIS.  The fieldwork for the ethnographic
         resource study began in July 1992.  We did not obtain data on a
         peer review of the reports.

      -- The Grand Canyon River Corridor Survey Project:  Archeological
         Survey Along the Colorado River Between Glen Canyon Dam and
         Separation Canyon prepared in cooperation with the Glen Canyon
         Environmental Studies Cooperative Agreement No.  9AA-40-07920.
         Although this study was not published until December 1994,
         research conducted for it was used in preparing the EIS.  The
         researchers for the study included professional staff from the
         National Park Service and Northern Arizona University.  The
         fieldwork commenced August 30, 1990, and was completed May 10,
         1991.  Peer review was performed by the Arizona State Historical
         Office, the University of Cincinnati, the University of Arizona,
         the National Park Service regional archeological staff in Denver
         and San Francisco, and affected Native American tribes.

      -- The River of Neverending Life:  Navajo History and Cultural
         Resources of the Grand Canyon and the Colorado River.  Navajo
         Nation Historic Preservation Department.  August 9, 1995.  A
         draft version of the report as well as basic research were used
         in preparing the EIS.  The fieldwork for this report was begun
         in May 1992.  We did not obtain information on a peer review of
         the report.

      -- Surficial Geology, Geomorphology, and Erosion of Archaeologic
         Sites along the Colorado River, Eastern Grand Canyon, Grand
         Canyon National Park, Arizona.  U.S.  Geological Survey,
         Open-File Report 93-517, prepared in cooperation with the Bureau
         of Reclamation-Glen Canyon Environmental Studies.  This report,
         released in 1993, acknowledges a number of individuals for
         critical review and comments.

      -- Zuni and the Grand Canyon:  A Glen Canyon Environmental Studies
         Report, July 21, 1995, Zuni GCES Ethnohistorical Report prepared
         by the Institute of the North American West.  The research data
         on which this report is based were used in the EIS.  The
         research was initiated in 1993.  We did not obtain information
         on a peer review of the report.

    In addition to these studies, which dealt specifically with cultural
    resources, we examined other relevant documents to determine the
    significance of cultural resource concerns expressed or addressed
    prior to the preparation of the EIS.  These other documents included
    the following:

      -- Final Analysis Report on Scoping Comments, prepared by Bear West
         Consulting Team, March 12-May 4, 1990, and

      -- Preliminary Research Findings, Glen Canyon Environmental
         Studies, presented to the Bureau of Reclamation and Western Area
         Power Administration in Denver by Duncan Patten and David
         Wegner, September 11, 1992.

          OFFICIALS INTERVIEWED
    ------------------------------------------------------ Appendix II:9.2

    To assess the procedures followed and obtain views on the quality of
    the data used in preparing the cultural resource issues, we
    interviewed the four members of the cultural resource writing team.
    We asked the team leader for the cultural resources workgroup to
    review our description of the resource impact determination process
    for factual accuracy.  She agreed that the information presented is a
    good summary of the process, methodology, and scientific basis used
    to determine the impacts on the cultural resources from the Glen
    Canyon Dam's operations.  We also contacted representatives of
    several cooperating agencies, primarily Native American tribes, to
    obtain their perspectives on and concerns about the
    archeological/cultural resources addressed in the EIS.  The following
    officials were contacted.

    Roger Anyon, Pueblo of Zuni
    Janet Balsom, National Park Service - Grand Canyon
    Clay Bravo, Hualapai Tribe
    Angelita Bulletts, Southern Paiute Consortium
    Gary Cantley, Bureau of Indian Affairs
    Kurt Dongoske, Hopi Tribe
    Alan Downer, Navajo Nation
    Loretta Jackson, Hualapai Tribe
    Leigh Jenkins, Hopi Tribe
    Signa Larralde, Bureau of Reclamation
    Johnny Lehi, San Juan Southern Paiute Tribe
    Alexa Roberts, Navajo Nation
    John Thomas, Navajo Nation
    Michael Yeats, Hopi Tribe

    Also, members of the following cooperating agencies were involved in
    the analysis and development of the cultural resource issues
    addressed in the EIS:  Bureau of Indian Affairs, National Park
    Service, Hopi Tribe, Hualapai Tribe, Navajo Nation, Pueblo of Zuni,
    San Juan Southern Paiute Tribe, and Southern Paiute Consortium.

    ENDANGERED SPECIES
    ========================================================= Appendix III

    The historic operations of the Glen Canyon Dam have negatively
    affected some wildlife resources while enhancing others.  Among the
    wildlife that inhabit the Glen and Grand canyon river corridor, there
    are seven nonfish endangered species.\6 The impacts of the various
    flow alternatives on these endangered species are mostly indirect and
    were analyzed through linkages to other resources, such as fish and
    vegetation.  The U.S.  Fish and Wildlife Service (FWS) determined
    that the proposed operation of the Glen Canyon Dam under the Modified
    Low Fluctuating Flow preferred alternative, is not likely to
    jeopardize the continued existence of the bald eagle, Kanab
    ambersnail, or peregrine falcon.  The FWS addressed only species that
    were listed as endangered by the federal government.  When the final
    EIS was issued, the southwestern willow flycatcher was only a
    candidate for listing.  It has subsequently been listed as an
    endangered species.  In addition, the bald eagle has been
    reclassified from endangered to threatened.  The belted kingfisher,
    osprey, and southwestern river otter are Arizona species of concern.
    Therefore, they were addressed in the EIS but not by the FWS.  In
    general, nonfish endangered species issues were not controversial in
    the preparation of the Glen Canyon Dam's EIS, and few concerns exist
    about the process used or the data relied upon for making the
    endangered species impact determinations.

    --------------------
    \6 In this appendix, the term "endangered species" is used for all
    special-status species addressed in the final EIS, including
    endangered species, candidate species, and Arizona species of
    concern.  In the final EIS, Reclamation revised the fish section to
    include the discussion of endangered fish species.  This appendix
    follows the same approach.  That is, only nonfish endangered species
    are discussed in this appendix.  Endangered fish species are
    discussed in app.  IV.

       DESCRIPTION OF THE RESOURCE
    ------------------------------------------------------- Appendix III:1

    Wildlife is diverse and abundant along the river corridor through the
    Glen and the Grand canyons.  Riparian (near water) vegetation, which
    developed along the river after the construction of the Glen Canyon
    Dam, plays an important role as habitat to support this diversity and
    abundance.  The variety of animals present in the river corridor,
    their habitats, and how they use their habitats form a complex system
    that is difficult to evaluate in detail.  However, like other
    resources, this system is linked to the river and ultimately to the
    operations of the Glen Canyon Dam.

    Both aquatic and terrestrial endangered species occupy or use the
    river corridor.  The seven nonfish endangered species considered in
    this appendix include five birds, one terrestrial snail, and one
    mammal now presumed extinct.  Specifically, these species are the
    bald eagle, peregrine falcon, southwestern willow flycatcher, belted
    kingfisher, osprey, Kanab ambersnail, and southwestern river otter.
    A brief description of each of these species follows.

          BALD EAGLE
    ----------------------------------------------------- Appendix III:1.1

    The bald eagle was listed as endangered in 1978 but has since been
    reclassified as threatened.  The Colorado River corridor through the
    Grand Canyon is used by migrating bald eagles in the winter.  While
    eagles are capable of taking fish from a river system with
    characteristics identical to those of the Colorado River before the
    construction of the Glen Canyon Dam, they were not often observed in
    the Grand Canyon until after the rainbow trout fishery was
    established.

    The bald eagle's use of the river corridor is opportunistic and
    currently concentrated around Nankoweap Creek, where they use
    winter-spawning trout as a food source.  The use of the river by
    eagles may increase and eventually expand to other locations.  For
    example, bald eagles are regularly located along the river corridor
    above the Little Colorado River and occur around Lake Powell.

          PEREGRINE FALCON
    ----------------------------------------------------- Appendix III:1.2

    Peregrine falcons were listed as endangered in 1970 but have
    generally increased nationwide since the prohibition on the use of
    certain pesticides.  The Grand Canyon and the surrounding areas
    support the largest known breeding population of peregrine falcons in
    the contiguous United States.  The birds using the Grand Canyon
    appear to be part of an increasing peregrine falcon population on the
    Colorado Plateau.

    Although relationships are still under investigation, it is assumed
    that the peregrine falcon's success in the area is at least partially
    due to the abundance of birds and bats.  These prey species are
    plentiful because of large insect populations produced in the clear
    river water.  The relationships between aquatic productivity,
    insects, prey species, and peregrine falcons are largely speculative.
    No specific data are available that refute or confirm the above
    relationships, and no data are available on the activities of
    peregrine falcons in the Grand Canyon before the construction of the
    Glen Canyon Dam.

          SOUTHWESTERN WILLOW
          FLYCATCHER
    ----------------------------------------------------- Appendix III:1.3

    The southwestern willow flycatcher is a riparian bird found in
    Arizona, New Mexico, and southern California.  At the time the final
    EIS was released, this species was a candidate for listing.  It has
    since been listed as an endangered species.

    Southwestern willow flycatchers have always occupied the river
    corridor.  Nesting pairs of this species increased in the Grand
    Canyon following the completion of the Glen Canyon Dam.  Researchers
    attribute this response to increases in riparian vegetation following
    reduced flood discharges.  However, a 1991 survey found only two
    pairs of nesting birds.  The most probable reason for this apparent
    decline is the brown-headed cowbird.  These birds lay their eggs in
    other species' nests, usually at the expense of their hosts' young.

    One researcher speculated that a possible reason for the decline in
    the numbers of this species is habitat fragmentation caused by floods
    and fluctuating river flows.  Fluctuating flows contribute to the
    erosion of terrestrial habitats, resulting in a decrease in the size
    of contiguous vegetation patches.  However, the required patch size
    for nesting southwestern willow flycatchers is not known.  Although
    the southwestern willow flycatcher has traditionally been associated
    with willows and other native vegetation, all of the nests located in
    the Grand Canyon have been located in tamarisk, even though native
    vegetation was available.

          BELTED KINGFISHER
    ----------------------------------------------------- Appendix III:1.4

    The belted kingfisher is considered a candidate species for listing
    by the state of Arizona.  This bird is found in low numbers
    year-round in the Grand Canyon and its tributaries.  This species is
    restricted to habitats with permanent, fish-inhabited waters.

          OSPREY
    ----------------------------------------------------- Appendix III:1.5

    The osprey is a fall, spring, or accidental transient in the Grand
    Canyon and is listed by the state of Arizona as a "state threatened"
    bird species.  Osprey are primarily found in coniferous forests
    around lakes, and it is assumed that they use the river as a travel
    lane to other habitat.

          KANAB AMBERSNAIL
    ----------------------------------------------------- Appendix III:1.6

    Only three populations of this snail are known to exist--two near
    Kanab, Utah, and one in the Grand Canyon.  Since the listing of this
    species as endangered in 1992, one of the Utah populations is now
    believed to be extirpated (extinct in that area).  The Grand Canyon
    population was discovered in 1991 by researchers surveying mollusks
    in conjunction with the Glen Canyon Environmental Studies program.

    Although officially a terrestrial animal, the Kanab ambersnail is
    really an amphibious creature found in wet or moist environments,
    such as marshes and seeps located at the bases of sandstone cliffs.
    Vegetation cover is necessary for this mollusk.  The vegetation in
    the Grand Canyon associated with the Kanab ambersnail is the cardinal
    monkey flower and water cress.  The availability of the cardinal
    monkey flower and other vegetation near the river in the Grand
    Canyon, as well as the presence of rock ledges, influence the
    distribution of the Kanab ambersnail.  Since the implementation of
    the interim flows for the Glen Canyon Dam in 1991, the Kanab
    ambersnail's habitat has become available at lower elevations, closer
    to the river.

          SOUTHWESTERN RIVER OTTER
    ----------------------------------------------------- Appendix III:1.7

    The southwestern river otter is considered an endangered species by
    the state of Arizona.  River otters have always been considered rare
    in the Grand Canyon; the last sighting was reported in 1983.
    Unconfirmed reports of their presence continue to be received from
    several localities, but extensive surveys have not resulted in
    sightings.  The species is generally believed to be extinct.

       EFFECTS OF PRE- AND POSTDAM
       CONDITIONS ON ENDANGERED
       SPECIES
    ------------------------------------------------------- Appendix III:2

    The Grand Canyon ecosystem originally developed in a sediment-laden,
    seasonally fluctuating environment.  The construction of Glen Canyon
    Dam altered the natural dynamics of the Colorado River.  The
    interruption in riverflow and the regulated releases of lake water
    now support aquatic and terrestrial systems that did not exist before
    the Glen Canyon Dam.  The historic operations of the dam negatively
    affected some wildlife resources while enhancing others.  The impacts
    of the dam's operations on the various endangered species also vary.

       ISSUE
    ------------------------------------------------------- Appendix III:3

    As defined in the final EIS, the issue for endangered species is how
    do dam operations affect the populations of endangered and other
    special-status species throughout the Glen and the Grand canyons?

       INDICATORS
    ------------------------------------------------------- Appendix III:4

    Because the seven nonfish endangered species that inhabit the river
    corridor occupy diverse niches in the Grand Canyon ecosystem, no
    single resource could be used as an indicator of impacts for
    endangered species as a whole.  Therefore, the EIS team utilized an
    analytical approach which considered linkages among resources.  The
    team identified the following indicators for individual species:

      -- for the bald eagle:  trout and the aquatic food base;

      -- for the belted kingfisher:  the aquatic food base;

      -- for the southwestern willow flycatcher:  the area of woody
         plants; and

      -- for the Kanab ambersnail:  maximum river flow.

       METHODOLOGY USED TO MAKE IMPACT
       DETERMINATIONS
    ------------------------------------------------------- Appendix III:5

    EIS team members told us that the EIS was developed through a dynamic
    process involving three main groups--the EIS team, Glen Canyon
    Environmental Studies officials and researchers, and representatives
    of the cooperating agencies.  The EIS team was responsible for the
    technical development of alternatives and impact determinations,
    while the cooperating agency group was a policy-level review body.

    The nonfish endangered species impacts and issues were primarily
    developed by two EIS team members assigned to that task on the basis
    of their areas of expertise.  Unlike the groups formed to address
    economic issues, no formal endangered species workgroup existed and
    no formal reports were produced.

    These two team members developed their sections of the EIS through an
    iterative process of drafting, discussions, and formal and informal
    presentations to, and review by, the EIS team, as well as through
    input from key researchers and colleagues with whom they shared their
    work and from whom they solicited feedback.  Additionally, the team
    members presented impact assessments to the cooperating agency group.

    Decisions on endangered species issues were handled through voting;
    the goal was to obtain consensus on the results of the work.  The
    formal minutes of the EIS team meetings were kept as a record of key
    decisions.

    Reclamation received approximately 33,000 public comments on the
    draft EIS, 1,826 of which related to endangered species.  However,
    only 31 comments specifically focused on nonfish endangered species.
    On the basis of new scientific information, the public comments, and
    the comments received from internal reviews, the EIS team as a whole
    made changes to the endangered species section of the EIS.  These
    changes included the addition of a new indicator for the impact
    analysis related to the Kanab ambersnail, changes to the text, and
    modifications to the endangered species impact matrix.  Both minor
    and major changes were made.  An example of a minor modification is
    the change of status in the matrix for the southwestern river otter
    from presumed "extirpated" to presumed "extinct." A more major
    addition/modification pertains to the inclusion of updated
    information on, and an expanded treatment of, the Kanab ambersnail in
    the final EIS.

    According to the principal author of the revised endangered species
    section, new information received after the release of the draft EIS
    indicated that the Kanab ambersnail responded to interim flows at the
    dam by moving into lower elevations than it had inhabited under the
    dam's historic operations.  Kanab ambersnails residing in these
    locations would be affected by flows higher than 20,000 cubic feet
    per second (cfs) and the associated habitat maintenance and
    beach/habitat-building flows.

    Because this population survived the 1983-86 floodflows of about
    90,000 cfs, the EIS team assumed that infrequent flows of about
    45,000 cfs would not jeopardize the continued existence of the
    population.  However, some unavoidable mortality, or "incidental
    take," would occur.  As a result of this information, changes were
    made to the discussion in the text of the Kanab ambersnail, and the
    impact determinations in the associated matrix were modified from "no
    effect" to "some incidental take."

          DATA USED FOR MAKING IMPACT
          DETERMINATIONS
    ----------------------------------------------------- Appendix III:5.1

    The research studies used to support the impact determinations on
    endangered species are listed in the final EIS bibliography.  Because
    of linkages to the fish and vegetation resource areas, the studies
    done in these fields are pertinent to endangered species.  The
    studies include Glen Canyon Environmental Studies phase I and phase
    II research, as well as research developed by various state and
    federal agencies involved in endangered species work.  Those studies
    deemed most useful by a key member of the EIS team who worked on
    endangered species issues are noted later in this appendix.

       EFFECTS OF FLOW ALTERNATIVES ON
       ENDANGERED SPECIES
    ------------------------------------------------------- Appendix III:6

    Details of the anticipated impacts of the nine flow alternatives on
    endangered species are found in the final EIS.  However, the
    following general statements can be made about these impacts:

      -- The Kanab ambersnail is the only species expected to be
         adversely affected by any of the flow alternatives.  Some
         mortality, or "incidental take," would occur under all
         alternatives, although the continued existence of the population
         would not be jeopardized.

      -- Three species will be unaffected by changes in the dam's
         operations--the peregrine falcon, the osprey, and the
         southwestern river otter (which is presumed extinct).

      -- Habitat conditions for the bald eagle and belted kingfisher
         would remain stable or potentially improve under all
         alternatives.

      -- The southwestern willow flycatcher would experience an
         "undetermined increase" in habitat under all alternatives except
         the No-Action and Maximum Powerplant Capacity alternatives.

       U.S.  FISH AND WILDLIFE
       SERVICE'S FINAL BIOLOGICAL
       OPINION
    ------------------------------------------------------- Appendix III:7

    The U.S.  Fish and Wildlife Service's 1994 final biological opinion
    found that the proposed operation of the Glen Canyon Dam under the
    preferred alternative is not likely to jeopardize the continued
    existence of the bald eagle, the peregrine falcon, or the Kanab
    ambersnail.  Few of the researchers and EIS team members we spoke
    with commented on the biological opinion as it related to nonfish
    endangered species.  When asked about this, two EIS team members said
    that the "no jeopardy" finding was key to the lack of controversy on
    endangered species issues in team discussions.  Another EIS team
    member added that the no jeopardy finding probably did allow the team
    to target their discussions and efforts on those endangered fish
    which had a jeopardy finding.  Still, another team member told us
    that the team was not surprised by FWS' no jeopardy finding and knew
    even before the opinion was released that fish would be the primary
    concern.

       ASSESSMENT OF IMPACT
       DETERMINATIONS
    ------------------------------------------------------- Appendix III:8

    Nonfish endangered species were not a controversial issue in the
    preparation of the Glen Canyon Dam's EIS.  This is particularly true
    in comparison to fish, which generated a great deal of controversy
    and difference of opinion.  When asked to comment on "endangered
    species," most researchers we spoke with talked only about endangered
    fish.

    Several EIS team members pointed to the indirect impacts of the dam's
    operations on most endangered species as a key reason for this lack
    of controversy.  A few EIS team members noted that nonfish species
    represent only a small percentage of the endangered species in the
    canyon and that concern about nonfish species was low compared to
    fish because of these small populations.  One EIS team member used as
    an example of this the fact that only two nesting pairs of
    southwestern willow flycatchers are in the affected area.  However,
    another EIS team member disputed the view that the smaller numbers of
    endangered species made them less controversial.  This individual
    stressed that the smaller numbers actually made it even more crucial
    that these species be protected and taken very seriously in the EIS
    process.  One researcher noted that there is a long history of fish
    research in the canyon but that there is no such research history for
    other species.  This individual said that of the nonfish endangered
    species, most interest focused on the Kanab ambersnail and the
    southwestern willow flycatcher.  Another researcher simply stated
    that "the fish drive the system" in the canyon and are more
    politically important than the other species.  Furthermore, he said
    that the connection between fish and the dam's operations can be
    easily seen, while this connection is harder to see with terrestrial
    species.

          REASONABLENESS OF THE
          METHODOLOGY
    ----------------------------------------------------- Appendix III:8.1

    Few concerns exist among the experts we interviewed about the process
    used in making the endangered species impact determinations.  Most
    EIS team members we interviewed were satisfied with the process of
    analyzing the linkages among resources in determining impacts.
    However, one EIS team member noted that analyzing linkages was only
    one way to look at impacts on endangered species.  The member noted
    that while analyzing linkages was an acceptable and reasonable
    approach, it was not necessarily the best or the worst way to
    proceed.

    EIS team members acknowledged that because some linkages were quite
    indirect, professional judgment was important in this process.  They
    stressed, however, that professional judgment was supported by the
    best available data.

    One researcher expressed some dissatisfaction with this process.
    This individual said that, on the basis of his experience in the
    canyon observing the connections among bird species and other
    terrestrial resources, the connections are more direct than they were
    represented in the final EIS.  He felt that although the team claimed
    to have looked at linkages, they did not do as thorough a job as they
    say and looked more at the impacts that could be directly ascribed.

          OPINIONS ON DATA USED FOR
          IMPACT DETERMINATIONS
    ----------------------------------------------------- Appendix III:8.2

    Individuals we interviewed had few concerns about the data used in
    making the impact determinations for nonfish endangered species.  One
    EIS team member told us that with the possible exception of the Kanab
    ambersnail and the southwestern willow flycatcher, endangered species
    were not controversial in terms of the data or the process used in
    making the impact determinations.  In fact, one researcher with whom
    we spoke characterized the terrestrial and bird-related research used
    as a basis for these determinations as "top notch." Nevertheless, one
    EIS team member said that the data used for endangered species were
    even less solid than they were for fish.

    A researcher who was also a member of the EIS team told us that while
    professional judgment played a role in their decision- making, the
    team worked hard to collect all of the information available.  This
    person said that when necessary, to fill in data gaps, the team
    contacted researchers directly and asked them to provide information
    in the form of written communications that could then be cited as
    documentation.

    Another member of the EIS team told us that, in his opinion, the data
    on the bald eagle were "adequate," data on the southwestern willow
    flycatcher were "on the cusp," and much of the new data on the Kanab
    ambersnail became available only after the EIS process was
    substantially complete.  This individual went on to say, however,
    that the data available to the team on most species provided adequate
    information to make informed decisions.  He stressed that complete
    information is never available in the process of scientific
    decision-making.

          RESPONSE TO THE ISSUES
          RAISED
    ----------------------------------------------------- Appendix III:8.3

    The principal author of the endangered species section of the final
    EIS provided us with detailed comments on and responses to each of
    the issues noted above.  He agreed with some statements or positions
    and disagreed with others.  For example, he disagreed that the data
    available on which to base impact determinations were less solid than
    those for fish.  He noted that because impacts based on linkages are
    difficult to quantify, they can give the impression that they are
    less solid.  However, he stressed that linkages are a legitimate and
    useful scientific approach and that they yield useful information.
    Moreover, he agreed that the data available on the various species
    produced reasonable results that were adequate for informed
    decision-making.

       SCOPE AND METHODOLOGY
    ------------------------------------------------------- Appendix III:9

    To determine the data and process used in developing endangered
    species issues, we identified and reviewed the following documents:
    the draft EIS and associated appendixes; the preliminary final EIS;
    the final EIS; public comments on the draft EIS; Reclamation's
    analysis of and the EIS team's responses to these comments; copies of
    the minutes of the EIS team meetings; summaries of the meetings of
    the cooperating agencies; and Reclamation's newsletters on the EIS
    process.  We also obtained and reviewed FWS' draft biological opinion
    and final biological opinion on the operation of Glen Canyon Dam,
    Reclamation's comments on the draft biological opinion and official
    response to the final biological opinion, and FWS' Fish and Wildlife
    Coordination Act report.  (See below for a list of related documents
    and full citations.)

    We obtained a copy of the final EIS bibliography from Reclamation,
    with titles sorted by each resource area.  The endangered species
    bibliography contains 29 titles; however, most of these titles relate
    to endangered fish.  The wildlife and habitat bibliography also
    contains 29 titles, several of which specifically relate to nonfish
    endangered species.  We asked the EIS team member recommended to us,
    as a key initial contact on nonfish endangered species issues, to
    identify those studies which had been the most useful in developing
    the impact determinations.  This individual was also one of the two
    individuals primarily responsible for writing the endangered species
    section of the final EIS.

    To assess the procedures followed and obtain views on the quality of
    the data used in preparing the endangered species impact
    determinations, we interviewed the EIS team members who had primary
    responsibility for writing this section of the draft EIS, as well as
    several other members of the EIS team.  We spoke with several
    scientists identified by team members and others as having done key
    research used by the team in developing the endangered species
    section of the EIS.  We also interviewed other agency officials with
    information on the EIS and the Glen Canyon Environmental Studies
    processes.

    Finally, we asked the principal author to review our description of
    the endangered species impact determination process for factual
    accuracy.  He agreed that our description was generally accurate but
    made some suggestions for changes.  We have incorporated these
    changes into our description of the process.  We also presented him
    with our preliminary findings on endangered species in order to
    provide him an opportunity to comment on and respond to the various
    issues raised through our audit work.  He generally agreed with the
    facts as presented.

          KEY STUDIES IDENTIFIED
    ----------------------------------------------------- Appendix III:9.1

    The following are key titles selected from the endangered species
    bibliography not related to fish.

    "Biological Opinion of the Effects of Glen Canyon Dam on the Colorado
    River as It Affects Endangered Species." Memorandum from Regional
    Director, U.S.  Fish and Wildlife Service, Albuquerque, New Mexico,
    to Acting Regional Director Harl Noble, Bureau of Reclamation.  Salt
    Lake City, Utah:  U.S.  Fish and Wildlife Service, 1978.

    Clarke, A.H., "Kanab Amber Snail--Oxyloma Haydeni Kanabinsis,
    Pilsbry, 1948," Status Survey of Selected Land and Freshwater
    Gastropods in Utah.  Denver, Colorado:  Prepared by Ecosearch, Inc.,
    Portland, Texas, for the U.S.  Fish and Wildlife Service, 1991, pp.
    23-36.

    Handbook of Federally Endangered, Threatened, and Candidate Plants of
    Arizona, S.  Rutman, compiler.  Phoenix, Arizona:  U.S.  Fish and
    Wildlife Service, 1990a.

    Influences of Glen Canyon Dam Fluctuating Flows on Spawning Rainbow
    Trout and Wintering Bald Eagles, With Observations on the Effects of
    Human-Bald Eagle Interactions on the Colorado River in Grand Canyon
    National Park.  Final Report from Northern Arizona University to
    Grand Canyon National Park, National Park Service, 1992.

    Unitt, P.  "Empidonax Trailli Extimus:  An Endangered Species,"
    Western Birds, Vol.  18, No.  3, pp.  137-162, 1987.

    The following titles were selected from the wildlife and habitat
    bibliography related to nonfish endangered species.

    Brown, B.T.  Abundance, Distribution, and Ecology of Nesting
    Peregrine Falcons in Grand Canyon National Park, Arizona.  Final
    report submitted to Grand Canyon National Park, Grand Canyon,
    Arizona, 1991b.

    Brown, B.T.  "Monitoring Bird Population Densities Along the Colorado
    River in Grand Canyon," Glen Canyon Environmental Studies Technical
    Report.  Salt Lake City, Utah:  Bureau of Reclamation, 1987.

    Brown, B.T.  "Status of Nesting Willow Flycatchers Along the Colorado
    River From Glen Canyon Dam to Cardenas Creek, Arizona," Endangered
    Species Report No.  20.  Phoenix, Arizona:  U.S.  Fish and Wildlife
    Service, 1991a.

    Brown, B.T., and R.R.  Johnson.  "The Effects of Fluctuating Flows on
    Breeding Birds," Glen Canyon Environmental Studies Executive
    Summaries of Technical Reports.  Salt Lake City, Utah:  Bureau of
    Reclamation, 1988.

    Brown, B.T., and W.C.  Leibfried.  "The Effect of Fluctuating Flows
    from Glen Canyon Dam on Bald Eagles and Rainbow Trout at Nankoweap
    Creek in Grand Canyon National Park, Arizona," Glen Canyon
    Environmental Studies Phase II Draft Integrated Research Plan, Vol.
    2.  Salt Lake City, Utah:  Bureau of Reclamation, 1990.

    Brown, B.T., R.  Mesta, L.E.  Stevens, and J.  Weisheit.  "Changes in
    Winter Distribution of Bald Eagles Along the Colorado River in Grand
    Canyon, Arizona," Journal of Raptor Research, Vol.  23, No.  3, pp.
    110-113, 1989.

    Brown, B.T., G.S.  Mills, R.L.  Glinski, and S.W.  Hoffman.  "Density
    of Nesting Peregrine Falcons in Grand Canyon National Park, Arizona,"
    Southwestern Naturalist, Vol.  37, No.  2, pp.  188-193, 1992.

    Brown, B.T., and L.E.  Stevens.  Written communication, National Park
    Service, 1991.

    Brown, B.T., and M.W.  Trosset.  "Nesting Habitat Relationships of
    Riparian Birds Along the Colorado River in Grand Canyon, Arizona,"
    Southwestern Naturalist, Vol.  34, No.  2, pp.  20-270, 1989.

    Spamer, E.E., and A.E.  Bogan.  "Mollusca of the Grand Canyon and
    Vicinity, Arizona:  New and Revised Data on Diversity and
    Distributions, With Notes on Pleistocene-Holocene Mollusks of the
    Grand Canyon," Proceedings of the Academy of Natural Sciences in
    Philadelphia, Vol.  144, pp.  21-68, 1993.

    Threatened Native Wildlife in Arizona.  Phoenix, Arizona:  Arizona
    Game and Fish Department, 1988.

    In addition to the studies identified above from the final EIS
    bibliography, other documents are relevant to endangered species
    issues.

    Carothers, S.W., and B.T.  Brown.  The Colorado River Through Grand
    Canyon:  Natural History and Human Change.  Tucson, Arizona:
    University of Arizona Press, 1991.  The coauthors of this book were
    both key researchers identified in our work.  Furthermore, Dr.
    Carothers was a member of the EIS team and the Aquatic Biology Team
    workgroup.  Portions of this book address fish and endangered species
    issues, drawing from Glen Canyon Environmental Studies research.

    Final Biological Opinion:  Operation of Glen Canyon Dam as the
    Modified Low Fluctuating Flow Alternative of the Final Environmental
    Impact Statement, Operation of Glen Canyon Dam.  (2-21-93-F-167) U.S.
    Fish and Wildlife Service, Dec.  21, 1994.  The Final Biological
    Opinion and its related Reasonable and Prudent Alternative were
    developed by FWS in response to Reclamation's request for formal
    consultation under section 7 of the Endangered Species Act.  The
    Final Biological Opinion states that the Modified Low Fluctuating
    Flow preferred alternative is likely to jeopardize the continued
    existence of the humpback chub and razorback sucker but is not likely
    to jeopardize the bald eagle, peregrine falcon, or Kanab ambersnail.

    Glen Canyon Dam:  Beach/Habitat-Building Test Flow, Final
    Environmental Assessment and Finding of No Significant Impact, Bureau
    of Reclamation, Feb.  1996.  This report presents the findings of the
    required environmental assessment prepared prior to implementing the
    spring 1996 "spike" flow.

    Operation of Glen Canyon Dam - Fish and Wildlife Coordination Act
    Report, U.S.  Fish and Wildlife Service, June 28, 1994.  In
    accordance with the Fish and Wildlife Coordination Act, FWS submitted
    this report to Reclamation with recommendations in connection with
    the Glen Canyon Dam's operations.  The act does not require
    Reclamation to accept the recommendations; however, reasonable and
    practicable recommendations will be implemented.  The act ensures
    that fish and wildlife receive equal consideration during the
    planning and construction of federal water projects.

    "Organisms and Biological Processes," River Resource Management in
    the Grand Canyon, pp.  84-117.  National Research Council, Committee
    to Review the Glen Canyon Environmental Studies, 1996.  This is a
    chapter of a National Research Council committee report on the Glen
    Canyon Environmental Studies.  The purpose of this report and the
    committee's task was to review research that was done in connection
    with the Glen Canyon Environmental Studies and to comment on the
    application of science in the management program of the Colorado
    River.

    "Response to the Final Biological Opinion on the Operations of Glen
    Canyon Dam," Bureau of Reclamation, Apr.  6, 1995.  This is
    Reclamation's official response to, and addressing of, the issues
    presented in the Final Biological Opinion.  In its response,
    Reclamation states that it does not agree with all the points made or
    positions taken by FWS but will take steps to comply with them.

          OFFICIALS INTERVIEWED
    ----------------------------------------------------- Appendix III:9.2

    We interviewed the following individuals about endangered species and
    other related Glen Canyon Dam EIS issues.

    Michael Armbruster, Bureau of Reclamation, principal author of
     the endangered species section of the EIS
    Frank Baucom, U.S.  Fish and Wildlife Service
    Debra Bills, U.S.  Fish and Wildlife Service
    Byran Brown, SWCA, Inc.
    Christine Karas, Bureau of Reclamation
    Dennis Kubly, Arizona Game and Fish Department
    William Leibfried, SWCA, Inc./Hualapai Tribe
    Gordon Lind, Bureau of Reclamation
    Margaret Matter, Western Area Power Administration
    Debra McGuinn-Robbins, Arizona Game and Fish Department
    Anthony Morton, Western Area Power Administration
    Ronald Moulton, Western Area Power Administration
    S.  Clayton Palmer, Western Area Power Administration
    Timothy Randle, Bureau of Reclamation
    Lawrence Riley, Arizona Game and Fish Department
    David Wegner, Bureau of Reclamation, Glen Canyon Environmental
     Studies

    FISH
    ========================================================== Appendix IV

    The construction of the Glen Canyon Dam altered the natural dynamics
    of the Colorado River, including the downstream aquatic system.  The
    predam aquatic system supported an array of native and nonnative
    fish.  The decline of the native fish in the Glen and Grand canyons
    is attributed to the presence of nonnative competitors and predators
    and to subsequent postdam river conditions that affected habitat and
    redefined the relationship between native and nonnative fishes.
    Scientific opinions differ about the potential impacts on fish
    resources of the flow alternatives addressed in the Glen Canyon Dam
    environmental impact statement.

    The U.S.  Fish and Wildlife Service's (FWS) final biological opinion
    expressed concern that the Modified Low Fluctuating Flow, the EIS's
    preferred alternative, would jeopardize the continued existence of
    two endangered fish species, the humpback chub and the razorback
    sucker.  The biological opinion's reasonable and prudent alternative
    identified actions that would modify the preferred alternative with
    seasonally adjusted steady flows about 25 percent of the time.  FWS
    and Reclamation agreed to categorize these flows as experimental, or
    research, flows so that studies could be conducted to verify an
    effective dam flow regime and to include those flows with another
    element of the reasonable and prudent alternative, "adaptive
    management." Reclamation intends to initiate a process of adaptive
    management that would provide for long-term monitoring and research
    to measure the actual effect of the selected dam-operating criteria.
    The results of this effort would form the basis for possible future
    modifications of the dam's operations and, with other conservation
    measures, may lead to the removal of the jeopardy opinion.

    EIS team members and resource scientists express a variety of
    opinions about the process and data used in making the impact
    determinations for fish.  Because of incomplete information, as
    stated in the final EIS, the impact of steady flows on fish is still
    uncertain.

       DESCRIPTION OF THE RESOURCE
    -------------------------------------------------------- Appendix IV:1

    Several elements comprise the aquatic ecosystem downstream of the
    Glen Canyon Dam.  These elements include the aquatic food base,
    native fishes, and nonnative fishes.  Nonnative fishes include
    warmwater, coolwater, and coldwater species.  Due to the very limited
    data collected before the construction of the dam, the predam
    distribution and relative abundance of native and nonnative fish are
    largely unknown and subject to speculation.

    In general, the ability of fish populations to persist and thrive
    depends on how well their life requirements are met.  Life
    requirements include food supply, habitat, and the ability to avoid
    or minimize competition and predation.

    Before the dam was closed, the aquatic food base for fish was founded
    on coarse organic material carried into the river from the drainage
    basin.  Today, this coarse material is trapped above the dam in Lake
    Powell.  Algae in the river (especially the filamentous green alga
    Cladophora glomerata) has now become an important part of the aquatic
    food base, along with associated diatoms (microscopic, single-celled,
    or colonial algae) and invertebrates (especially insects and the
    amphipod Gammarus lacustris).

    The predam aquatic ecosystem contained eight native fish species and
    several introduced species such as the channel catfish and the carp.
    The eight native species were the humpback chub, razorback sucker,
    Colorado squawfish, bonytail chub, roundtail chub, flannelmouth
    sucker, bluehead sucker, and speckled dace.  The Colorado squawfish,
    the roundtail chub, and the bonytail chub are considered extirpated
    (i.e., extinct in a given area) from the Grand Canyon, and the
    razorback sucker is very rare.  The population of humpback chub in
    the Grand Canyon is the largest of five remaining populations and the
    only population of the species in the Lower Colorado River Basin.

    Warmwater nonnative fish species began to be introduced into the
    river system possibly as early as the late 1800s.  About the time
    that the dam was completed, warmwater nonnative fish found near the
    dam site included channel catfish, carp, fathead minnow, green
    sunfish, killifish, largemouth bass, mosquito fish, and red shiner.
    Coolwater nonnative fishes introduced into the river include striped
    bass, smallmouth bass, and walleye.  In addition to these warmwater
    and coolwater nonnatives, coldwater nonnative trout species were
    introduced for sport purposes beginning in the 1920s.  Rainbow trout
    make up the major part of the sport fishery, but brook trout, brown
    trout, and cutthroat trout also have been stocked in the river.

    The variety of native and nonnative fish present in the system leads
    to the issue of "interactions" among them.  Interaction in the form
    of competition from, and predation by, nonnative fish has been cited
    along with habitat modification as causes of the decline of native
    fish in the Colorado River system.  Potential competitors for habitat
    with native fish include carp, fathead minnow, killifish, rainbow
    trout, and red shiner.  Species cited as predators on native fish
    include striped bass, channel catfish, brown trout, and possibly
    rainbow trout.  Because of limited data, opinions vary about
    interactions between native and nonnative fish and how operational
    changes would affect these interactions.

       EFFECTS OF PRE- AND POSTDAM
       CONDITIONS ON FISH
    -------------------------------------------------------- Appendix IV:2

    The aquatic ecosystem originally developed in a sediment-laden,
    seasonally fluctuating river environment.  The construction of the
    Glen Canyon Dam altered the natural dynamics of the Colorado River.
    Today, the ecological resources of the Glen and Grand canyons depend
    on the water releases from the dam and the sediment that comes from
    tributaries below the dam.  Lake Powell traps water, sediment, and
    the associated nutrients that previously traveled down the Colorado
    River.

    The interruption of riverflow and regulated release of lake water now
    support aquatic and terrestrial systems that did not exist before the
    Glen Canyon Dam.  The predam aquatic system supported an array of
    native and nonnative fish.  Native fish evolved in a river that
    carried large amounts of sediment and was subject to extreme seasonal
    variability in flow and temperature.  The construction of the dam
    created a relatively clear river with near constant year-round cold
    temperatures.  These water temperatures limit the possibility of
    successful reproduction by warmwater fish, including the five native
    fish still present in this portion of the Colorado River system.  The
    decline of the native fish in the Glen and Grand canyons is
    attributed to the presence of nonnative competitors and predators and
    to postdam river conditions.  The tributaries of the Colorado River
    in the Grand Canyon are used by native fish species for spawning and
    rearing young.

       ISSUE
    -------------------------------------------------------- Appendix IV:3

    As defined in the final EIS, the issue of concern for fish resources
    is how do dam operations affect fish--their food base, life cycles,
    habitat, and ability to spawn?

       INDICATORS
    -------------------------------------------------------- Appendix IV:4

    The indicators for fish resources listed in the final EIS are the

      -- abundance of Cladophora and associated diatoms for the aquatic
         food base;

      -- reproduction, recruitment(survival to adulthood), and growth of
         native fish;

      -- reproduction, recruitment, and growth of nonnative warmwater and
         coolwater fish; and

      -- level of interactions between native and nonnative fish.

    Both the biological productivity of the aquatic food base and the
    physical characteristics of the environment (temperature, reliable
    flow, turbidity, etc.) determine the limits of fish development.
    Therefore, the EIS team's assessments of impacts on fish included
    both of these areas.  The analysis of impacts on the food base
    focused on Cladophora production and used changes in the length of
    wetted perimeter (the productive band of shoreline) to demonstrate
    the differences between the alternatives.

    The analyses of the impacts of the alternatives on native and
    nonnative fish addressed (1) direct sources of mortality, (2)
    potential for reproduction and recruitment, and (3) potential for
    growth.  The analysis factors included the temperature of the water
    in the mainstem and access to tributaries for reproduction, food base
    and stable nearshore and backwater environments for recruitment and
    growth, flood frequency reduction measures, and
    beach/habitat-building flows.  The evaluation of native and nonnative
    interactions was qualitative and focused on the effects of each
    alternative on nearshore and backwater habitats used by native and
    nonnative fish.

       METHODOLOGY USED TO MAKE IMPACT
       DETERMINATIONS
    -------------------------------------------------------- Appendix IV:5

    EIS team members told us that the EIS was developed through a dynamic
    process involving three main groups--the EIS team, Glen Canyon
    Environmental Studies officials and researchers, and representatives
    of the cooperating agencies.  Researchers provided data to the EIS
    team that was responsible for the technical development of
    alternatives and impact determinations, while the cooperating agency
    group was a policy-level review body.

    The initial impact determinations for fish and endangered fish were
    primarily developed by two EIS team members assigned to that task on
    the basis of their areas of expertise.  These team members were from
    the Arizona Game and Fish Department and FWS.  No formal fish
    subgroup or workgroup existed at that time and no formal reports were
    produced.

    These two team members developed their sections of the EIS through an
    iterative process of drafting, discussions, and formal and informal
    presentations to, and review by, the whole EIS team, as well as
    through input from key researchers and colleagues with whom they
    shared their work and from whom they solicited feedback.
    Additionally, presentations of the impact assessments were made to
    the cooperating agency group.

    The EIS team's decision-making on fish issues was handled through
    voting; the goal was a consensus-based product.  Formal minutes of
    the EIS team meetings were kept as a record of key decisions.

    After public comments were received on the draft EIS, the Aquatic
    Biology Team (ABT) workgroup was formed by Reclamation to respond to
    the comments and to reorganize and rewrite the fish and endangered
    species sections of the final EIS.  This workgroup consisted of the
    two original individuals and five additional EIS team members
    representing Reclamation, the Hopi Tribe, the Hualapai Tribe, and the
    Arizona Game and Fish Department.  The workgroup was formed because
    of the controversy and diametrically opposed positions of many of the
    comments pertaining to aquatic biology.  All members of the workgroup
    participated in discussions and consensus decision-making on fish
    issues and revised impact determinations; however, two individuals
    were principally responsible for the rewrite of the sections under
    review, with assistance and input from other EIS team and ABT
    workgroup members.  Of the 33,000 comments received on the draft EIS,
    291 related to fish and 1,826 related to endangered species.
    However, the vast majority of endangered species comments focused on
    endangered fish.

    The ABT did its work through an iterative process similar to that
    used by the EIS team as a whole.  Individuals were given assignments,
    interactive discussions were held, and decisions were made through
    consensus.  According to ABT workgroup members, no official
    documentation of the discussions and decisions of this group were
    kept.  Rather, information was shared among members through personal
    communications, working meetings, and other collegial interactions.
    Some information relevant to fish resources is contained in the
    official minutes of the EIS team meetings.

    On the basis of the comments received on the draft EIS and the
    internal review, the EIS team/ABT workgroup made several major
    changes to the fish section of the final EIS.  Specifically:

      -- In order to make the document less confusing and to facilitate
         better integration of material, the fish section was
         substantially revised and reorganized to include new information
         and to integrate the extensive treatment of endangered fish
         previously covered in the endangered species section of the EIS.

      -- In response to the comments received and ongoing discussions,
         Reclamation and FWS jointly agreed to move the endangered fish
         research flows identified in FWS's reasonable and prudent
         alternative from the preferred alternative to the Adaptive
         Management Program.  The EIS team implemented this change.

      -- In response to the comments and concerns about interactions
         between native and nonnative fish, information on competition
         and predation and the predam fish population was expanded in the
         final EIS.  Information on nonnative fish and native/nonnative
         interactions was added to the summary table of impacts.

      -- In order to more explicitly recognize the uncertainty and
         disagreement that exist among resource scientists about the
         responses of fish to steady flow alternatives, the final EIS
         describes those areas of uncertainty and includes reference to
         this uncertainty in the matrix of potential impacts.

    Because final results were not available to the ABT from many of the
    phase II fish studies for the Glen Canyon Environmental Studies,
    professional judgment was an important factor in developing fish
    impact determinations for the final EIS.  However, as one ABT member
    stressed, these impact determinations were criterion based, using
    important resource indicators as the basis for judgment.  The ABT
    workgroup and EIS team thus used a combination of available data and
    professional judgment in developing the impact determinations for
    fish.

          DATA USED FOR MAKING IMPACT
          DETERMINATIONS
    ------------------------------------------------------ Appendix IV:5.1

    The research studies used to support the impact determinations on
    fish resources are listed in the bibliography of the final EIS.
    These studies include Glen Canyon Environmental Studies research, as
    well as research developed by various state and federal agencies
    involved with fish resources.  Those studies deemed most useful by
    several members of the EIS team who worked on fish issues are noted
    in the Key Studies Identified subsection of this appendix.

       EFFECTS OF FLOW ALTERNATIVES ON
       FISH
    -------------------------------------------------------- Appendix IV:6

    Details of the anticipated impacts of the nine flow alternatives on
    fish resources are found in the final EIS.  However, the following
    general statements can be made about the impacts of restricted
    fluctuating flows versus steady flows on fish:

      -- Fluctuating releases may affect fishes' access to tributaries
         and backwater habitat and destabilize these backwaters by
         alternately draining and refilling them with cold water from the
         Colorado River mainstem.

      -- Daily fluctuations in water level and cold water temperatures
         would continue to suppress reproduction and recruitment of
         nonnative warmwater fishes in the mainstem.

      -- Fluctuations may increase turbidity (cloudiness) of the water,
         which may provide cover for native fish and a degree of
         protection from predation.  Increased turbidity could also
         provide foraging opportunities for the adult chub.

      -- Steady flows would allow for increased warming of backwaters,
         which would benefit young native fish.  However, such improved
         habitat conditions for native species might also benefit
         nonnative species that are competitors or predators of these
         native endangered fish.  The potential for increased interaction
         between native fish and their competitors and predators is
         greatest under steady flows.

      -- Steady flows might adversely affect maintenance of backwaters,
         allowing them to become isolated and filled with sediment.

      -- Steady flows could reduce the availability of fish forage and
         slow its transport downstream.

    The final EIS points out that any change in the dam's daily
    operations or other management actions that result in improved
    habitat conditions for native fish also would improve conditions for
    nonnative warmwater and coolwater fish.  Resource scientists are not
    in agreement about what improving habitat conditions means in terms
    of interactions between native and nonnative fish.

       U.S.  FISH AND WILDLIFE
       SERVICE'S FINAL BIOLOGICAL
       OPINION
    -------------------------------------------------------- Appendix IV:7

    The U.S.  Fish and Wildlife Service conditioned its support of the
    preferred alternative in the Glen Canyon Dam's EIS on the basis that
    Reclamation would agree to additional research on the impact of
    steady flows on fish as part of the Adaptive Management Program.  In
    December 1994, FWS issued its final biological opinion on the
    operations of the Glen Canyon Dam, as required by section 7 of the
    Endangered Species Act.  In its final opinion, FWS supports a flow
    regime that includes steady flows, and especially the Seasonally
    Adjusted Steady Flow alternative, on the basis of the supposed
    benefits for native fish.  The final biological opinion concludes
    that the Modified Low Fluctuating Flow preferred alternative is
    likely to jeopardize the continued existence of the humpback chub and
    the razorback sucker.  Therefore, FWS issued a "jeopardy opinion"
    concerning the EIS preferred alternative for those fish species.

    In support of its 1994 opinion and findings, FWS states that "the
    preferred alternative (without a selective withdrawal structure) does
    not remove the issue of coldwater temperatures on reproductive
    success in the mainstem...." Furthermore, FWS asserts that

         "fluctuating flows limit solar warming of backwaters, flush
         organisms and nutrients important as food resources, and force
         earlier life stages of endangered and other native fishes out of
         quiet protected waters into unfavorable mainstem conditions.
         These conditions might include increased exposure to predation
         and debilitating effects of cold water and increased
         velocities."

    Regulations implementing section 7 of the Endangered Species Act
    state that a "reasonable and prudent alternative" to the recommended
    action can be identified during the formal consultation process.  For
    the Glen Canyon Dam's EIS, FWS' reasonable and prudent alternative
    recommends further studies of the effects of steady flows on
    endangered and native fish, otherwise known as endangered fish
    research flows.  When implemented, these research flows would require
    as many as 5 low release years (annual water releases at or near 8.23
    million acre-feet).  Because low water release years are expected to
    occur only about half the time, it is uncertain how many total years
    it would take to complete the research program.  However, it is
    likely that research flows could be completed within 10 years.

    Endangered fish research flows would likely be between 8,000 cfs and
    20,000 cfs with a spring through fall pattern and monthly releases
    similar to the Seasonally Adjusted Steady Flow alternative.  The
    results from the research program would be monitored, and corrective
    action would be taken if adverse effects on endangered species were
    identified.  Upon completion of the research flows and analysis of
    the data, Reclamation is to implement, through the Adaptive
    Management Program, any necessary changes in dam-operating criteria
    necessary to comply with the Endangered Species Act.  Reclamation and
    FWS are to meet at least annually to coordinate reasonable and
    prudent alternative activities and ensure that sufficient progress is
    being made to remove the jeopardy opinion for the endangered species
    that are affected by the operation of the Glen Canyon Dam.  FWS
    agreed to support the preferred alternative as modified by the
    reasonable and prudent alternative.

    Reclamation does not agree with FWS' jeopardy opinion on the
    preferred alternative.  In its comments on a draft version of the
    biological opinion, Reclamation presented its concerns about FWS'
    support of steady flows by noting that "scientific experts on native
    fishes in the Colorado River system who were convened to discuss the
    merits and detriments of flow alternatives on March 2, 1994, were not
    totally supportive that the draft biological opinion flow scenario
    will provide quantifiable benefit to native fish without additional
    temperature modification." Furthermore, Reclamation was also
    concerned that

         "the logic for identifying the effects of steady flows as
         related to the Colorado River system in the Grand Canyon is not
         well supported.  Data coming from the GCES program and in other
         research programs on Southwestern ecosystems consistently point
         to the importance of disturbance in maintaining the native
         species assemblages.  The statement that the ecology of the
         Grand Canyon will be supported by steady flows is not supported
         in the document or in the literature."

    Nevertheless, Reclamation has agreed to implement elements of FWS'
    reasonable and prudent alternative, including continued study of the
    effects of steady flows on fish.

          ASSESSMENT OF IMPACT
          DETERMINATIONS
    ------------------------------------------------------ Appendix IV:7.1

    EIS team and ABT workgroup members told us that they were pleased
    with the process used in developing the EIS, believed that this
    process was "reasonable," and were satisfied with their product.
    Several noted the professional and open-minded approach brought to
    the work by most of the team members.  FWS representatives to the
    team also said that they were pleased with the process up to the
    point where the draft EIS and the draft biological opinion were
    released.  However, with the formation of the ABT workgroup, they
    said, the focus shifted to a concern for supporting the preferred
    alternative and "discrediting" the Seasonally Adjusted Steady Flow
    alternative.  Other EIS team/ABT workgroup members took exception to
    this assertion, with one member stating that the preferred
    alternative was not forced upon FWS.  Another team member stated that
    when it comes to the operations of the Glen Canyon Dam, NEPA (the
    EIS) and the Endangered Species Act (the reasonable and prudent
    alternative) did not complement each other very well.

          REASONABLENESS OF THE
          METHODOLOGY
    ------------------------------------------------------ Appendix IV:7.2

    We received a variety of comments on the implementation of the fish
    impact determination methodology.  For example, many interviewees
    expressed regret about the lack of coordinated time frames between
    the completion of Glen Canyon Environmental Studies research and the
    EIS development schedule, because the timing problem led to the use
    of incomplete data for the fish resources.

    One of the ABT workgroup's tasks was to explicitly deal with the
    uncertain impacts of steady flows on fish resources.  The leader of
    the ABT workgroup told us that there were significant disagreements
    among team members about how to handle this uncertainty, and that the
    FWS representatives held a different opinion from other members of
    the ABT.  As with other decisions, this disagreement was handled
    through open discussion with the goal of establishing consensus.
    Many interviewees expressed the belief that the final EIS' increased,
    explicit acknowledgement of uncertainty about flow impacts on the
    fish resources was an important improvement in the document.  Some of
    these individuals told us that this change to the fish resource
    section accurately reflects the disagreements and uncertainties
    within the scientific community.

    EIS team members told us that an important component of the process
    of developing the impact determinations was the team's contacts with
    Glen Canyon Environmental Studies officials for updates on research
    results and the team's interactive relationship with key researchers.
    However, while some of the key researchers with whom we talked
    acknowledged that they had worked with EIS team members in this way,
    others told us that the EIS team's contact with them had been minimal
    or even nonexistent.

    Some interviewees expressed the belief that private consultants
    should not have been included on the EIS team because their loyalty
    may be to present or future clients rather than to objective science.
    On the other hand, one consultant was also mentioned by several
    interviewees as one of the most knowledgeable individuals on fish and
    other resource issues in the canyon.  Furthermore, several
    individuals expressed high regard for the work done by another
    consultant on some of the key Glen Canyon Environmental Studies
    research on the humpback chub.

    Some EIS team members were also researchers whose work was being
    reviewed for the EIS.  One EIS team member expressed the belief that
    this dual role was beneficial to the team because of their knowledge
    about the latest scientific findings as they developed.  Two
    researchers, however, told us that they were troubled by this dual
    role for EIS team members.  One suggested that it constituted a
    conflict of interest; the other was concerned that having individuals
    reviewing their own work might have affected the objectivity with
    which the research was examined.

          OPINIONS ON DATA USED FOR
          IMPACT DETERMINATIONS
    ------------------------------------------------------ Appendix IV:7.3

    Limited data permit opinions to vary among members of the scientific
    community on a number of issues related to fish.  Some of these
    differences occur because of disagreements over scientific
    interpretations and viewpoints; others reflect personal,
    institutional, and academic affiliations and rivalries.  Differences
    of opinion also exist on the issues related to the development of the
    impact determinations on fish for the final EIS.

    A number of the individuals we talked with both inside and outside of
    the EIS preparation process expressed frustration that the final
    results from many of the Glen Canyon Environmental Studies phase II
    fish studies were not available to the EIS team and the ABT workgroup
    for the development of the impact determinations in the final EIS.
    According to several interviewees, this lack of final results--or
    "hard data," as one EIS team member not on the ABT called
    it--inevitably lead to an increased reliance on professional judgment
    in developing impact determinations related to fish.

    Opinions varied as to whether the lack of final results from some
    phase II studies constituted a "limitation" on or simply a
    "hindrance" to the development of the impact determinations.  Some
    interviewees told us that while it was unfortunate that final results
    from phase II were not in, this was not a limitation on the
    usefulness of the available data or the conclusions drawn from them.
    They believed that if the final data had been available, the team's
    determinations might have been more refined or supported, but their
    conclusions (and the preferred alternative) would have remained the
    same.  Others believed that the lack of final results represented a
    significant limitation on the impact determinations.  Some of these
    even suggested that the determinations or decisions might have
    changed on the basis of these final research results or that if the
    EIS team had used all the science available to them, "they would have
    come up with a different alternative."

    Despite these differences, most of those who expressed an opinion to
    us said that the EIS team had used the "best available data" in
    determining the impacts on fish.  One said that the best available
    data were used, although these data were not complete.  Another told
    us that while the best available data were used, other, better data
    might have been available had the EIS time frames been changed to
    accommodate the completion of the Glen Canyon Environmental Studies.
    This individual further stated that the EIS team had developed
    "reasonable interpretations from unreasonable data." Even some of
    those individuals critical of the overall process agreed that the
    "best available data" had been utilized.

          PEER REVIEW OF STUDIES
    ------------------------------------------------------ Appendix IV:7.4

    Reclamation and Glen Canyon Environmental Studies officials and
    researchers told us that a three-tiered review process was developed
    for all Glen Canyon Environmental Studies, regardless of resource
    area.  This process included (1) internal agency/organizational
    review by the research entity, (2) Glen Canyon Environmental Studies
    office review, and (3) external peer review under the auspices of the
    Senior Scientist.  However, a number of the researchers that we
    interviewed were critical of the actual review process.  Furthermore,
    the individual responsible for overseeing this process told us that
    only about 30 to 35 out of approximately 140 anticipated Glen Canyon
    Environmental Studies had actually undergone the complete three-step
    review.

          RESULTS OF THE PROCESS
    ------------------------------------------------------ Appendix IV:7.5

    As to the results of the process, the views on the preferred
    alternative varied among interviewees.  Several supported the
    preferred alternative, especially when combined with the
    beach/habitat-building "spike" flow.  Others supported flow regimes
    that include the Seasonally Adjusted Steady Flow alternative favored
    by FWS.  Some interviewees told us that they were originally inclined
    to support steady flows but changed their views in favor of
    fluctuating flows on the basis of the developing data.  Two
    interviewees endorsed a flow regime that closely resembles the
    "natural hydrograph," including floods and low flows.  Some
    researchers told us that they had not read or reviewed the final EIS
    and were unfamiliar with the specifics of the flow alternatives.

          ABT WORKGROUP LEADER'S
          RESPONSES TO THE ISSUES
          RAISED
    ------------------------------------------------------ Appendix IV:7.6

    The leader of the ABT workgroup provided us with detailed comments on
    and responses to each of the issues noted above.  He agreed with some
    statements or positions and disagreed with others.  For example, he
    agreed that the lack of final results from the fish research studies
    was frustrating and that the limited data allow differences of
    opinion on and scientific interpretation of the impacts on fish
    resources.  However, he disagreed with the statement that had final
    results been available, the impact determinations might have been
    different.  Rather, he said the final data would have refined the EIS
    team's understanding of the issues and supported their conclusions
    but would not have changed the impact determinations or the preferred
    alternative.

    His overall position, taking into consideration the various
    perspectives and opinions expressed, was that

      -- the process used in making the impact determinations on fish
         resources was reasonable,

      -- the methodologies employed in this process were appropriate,

      -- the data used were the best available, and

      -- the results of the impact determinations are reasonable.

          SCOPE AND METHODOLOGY
    ------------------------------------------------------ Appendix IV:7.7

    To determine the data and process used in developing the impacts on
    fish resources, we identified and reviewed the following documents:
    the draft EIS and associated appendixes; the preliminary final EIS;
    the final EIS; the public comments on the draft EIS; Reclamation's
    analysis of and the EIS team's responses to these comments; copies of
    minutes of the EIS team meetings; summaries of the meetings of the
    cooperating agencies; and Reclamation's newsletters on the EIS
    process.  We also obtained and reviewed FWS' draft biological opinion
    and final biological opinion on the operation of the Glen Canyon Dam,
    Reclamation's comments on the draft biological opinion and official
    response to the final biological opinion, and FWS' Fish and Wildlife
    Coordination Act report (see list of related documents below for full
    citations).

    We obtained a copy of the final EIS bibliography from Reclamation,
    with titles sorted by each resource area.  The fish bibliography
    contained 57 titles, while the endangered species bibliography
    contained 29 titles.  We asked three EIS team members recommended to
    us as key initial contacts on fish and endangered species issues to
    review the titles related to these resources and to point out those
    studies they believed had been most useful in developing the impact
    determinations.

    To assess the procedures followed and obtain views on the quality of
    data used in preparing fish issues, we interviewed the EIS team
    members who had primary responsibility for writing the fish and
    endangered species section of the draft EIS, as well as all other
    members of the ABT workgroup, which was formed to revise and
    reorganize these two sections following the receipt of public
    comments on the draft EIS.  Additionally, we met with several other
    members of the EIS team, including two EIS team members not on the
    ABT workgroup who requested the opportunity to discuss fish and
    endangered species issues with us.  We spoke with several scientists
    identified by team members and others as having done key research
    used by the workgroup and the full EIS team in developing the fish
    impact determinations.  We interviewed other agency officials with
    information about the EIS and Glen Canyon Environmental Studies
    processes.

    Finally, we asked the leader of the ABT workgroup to review the
    factual accuracy of our description of the process for developing the
    impact determinations for fish resources.  He agreed that our
    description was generally accurate but made some suggestions for
    changes.  We have incorporated these changes into our description of
    the process.  We also presented him with our preliminary findings on
    fish resources in order to provide him with an opportunity to comment
    on and respond to the various issues raised through our audit work.

          KEY STUDIES IDENTIFIED
    ------------------------------------------------------ Appendix IV:7.8

    The following are titles from the fish bibliography selected by at
    least two of the three key initial contacts recommended to us.

    Angradi, T.R., R.W.  Clarkson, D.A.  Kinsolving, D.M.  Kubly, and
    S.A.  Morgensen.  "Glen Canyon Dam and the Colorado River:  Responses
    of the Aquatic Biota to Dam Operations," Glen Canyon Environmental
    Studies Technical Report.  Phoenix, Arizona:  Arizona Game and Fish
    Department, 1992.

    Glen Canyon Environmental Studies Phase II 1992 Annual Report.
    Prepared for the Bureau of Reclamation, Glen Canyon Environmental
    Studies.  Phoenix, Arizona:  Arizona Game and Fish Department, 1993.

    Gorman, O.T., S.T.  Leon, and O.E.  Maughan.  "Habitat Use by
    Humpback Chub, Gila Cypha, in the Little Colorado River and Other
    Tributaries of the Colorado River in the Grand Canyon," Glen Canyon
    Environmental Studies Phase II Annual Report.  Prepared for the
    Bureau of Reclamation by the U.S.  Fish and Wildlife Service,
    Pinetop, Arizona, and the Arizona Cooperative Fish and Wildlife
    Research Unit, Tucson, Arizona, 1993.

    Leibfried, W.C.  "Utilization of Cladophora Glomerata and Epiphytic
    Diatoms as a Food Resource by Rainbow Trout in the Colorado River
    Below Glen Canyon Dam in Arizona," Masters Thesis.  Flagstaff,
    Arizona:  Northern Arizona University, 1988.

    Leibfried, W.C., and D.W.  Blinn.  "The Effects of Steady Versus
    Fluctuating Flows on Aquatic Macroinvertebrates in the Colorado River
    below Glen Canyon Dam, Arizona," Glen Canyon Environmental Studies
    Technical Report.  Salt Lake City, Utah:  Bureau of Reclamation,
    1987.

    Maddux, H.R., D.M.  Kubly, J.C.  DeVos, Jr., W.R.  Persons, R.
    Staedicke, and R.L.  Wright.  "Effects of Varied Flow Regimes on
    Aquatic Resources of Glen and Grand Canyons," Glen Canyon
    Environmental Studies Technical Report.  Phoenix, Arizona:  Arizona
    Game and Fish Department, 1987.

    McGuinn-Robbins, D.K., Comparison of the Number and Area of
    Backwaters Associated With the Colorado River in Glen and Grand
    Canyons, Arizona.  Phoenix, Arizona:  Arizona Game and Fish
    Department, 1994.

    Suttkus, R.D., G.H.  Clemmer, C.  Jones, and C.R.  Shoop.  Survey of
    Fishes, Mammals and Herpetofauna of the Colorado River in Grand
    Canyon.  National Park Service, Colorado River Research Series
    Contribution no.  34, 1976.

    Usher, H.D., D.W.  Blinn, G.C.  Hardwick, and W.C.  Leibfried.
    Cladophora Glomerata and Its Diatom Epiphytes in the Colorado River
    Through Glen and Grand Canyons:  Distribution and Desiccation
    Tolerance.  National Technical Information Service No.
    PB88-183454/AS, 1986.

    Weiss, J.  "The Relationship Between Flow and Backwater Fish Habitat
    of the Colorado River in Grand Canyon" (draft report), Glen Canyon
    Environmental Studies Technical Report.  Flagstaff, Arizona:  Bureau
    of Reclamation, 1993.

    Weiss, S.J.  Spawning, Movement, and Population Structure of
    Flannelmouth Sucker in the Paria River.  Masters Thesis.  Tucson,
    Arizona:  University of Arizona, 1993.

    Titles related to fish selected from the endangered species
    bibliography by at least two of these contacts were as follows.

    Kubly, D.M., The Endangered Humpback Chub (Gila Cypha) in Arizona:  A
    Review of Past Studies and Suggestions for Future Research (draft
    report).  Salt Lake City, Utah:  Prepared by the Arizona Game and
    Fish Department for the Bureau of Reclamation, 1990.

    Tyus, H.M., and C.A.  Karp.  "Habitat Use and Streamflow Needs of
    Rare and Endangered Fishes, Yampa River, Colorado," Fish and Wildlife
    Service Biological Report, vol.  89, no.  14.  Vernal, Utah:  1989.

    Valdez, R.A.  Life History and Ecology of the Humpback Chub in Grand
    Canyon.  Logan, Utah:  BIO/WEST, 1994.

    Valdez, R.A., and M.  Hugentobler (editors).  Characterization of the
    Life History and Ecology of the Humpback Chub (Gila Cypha) in the
    Grand Canyon.  Annual Report 1992 to Bureau of Reclamation.  Logan,
    Utah:  BIO/WEST Report No.  TR-250-06, 1993.

    Valdez, R.A., W.J.  Masslich, and W.  Leibfried.  Characterization of
    the Life History and Ecology of the Humpback Chub (Gila Cypha) in the
    Grand Canyon.  Annual Report to the Bureau of Reclamation.  Logan,
    Utah:  BIO/WEST Report no.  TR 250-04, 1992.

    Valdez, R.A., A.  Wasowicz, and W.  Leibfried.  Characterization of
    the Life History and Ecology of the Humpback Chub (Gila Cypha) in the
    Grand Canyon.  Logan, Utah:  BIO/WEST Trip Report no.  7-1992, 1992.

    In addition to the studies identified above from the final EIS
    bibliography, other documents are relevant to fish issues.  These
    documents include the following.

    Carothers, S.W., and B.T.  Brown.  The Colorado River Through Grand
    Canyon:  Natural History and Human Change.  Tucson, Arizona:
    University of Arizona Press, 1991.  The coauthors of this book were
    both key researchers identified in our work.  Furthermore, Dr.
    Carothers was a member of the EIS team and the Aquatic Biology Team
    workgroup.  Portions of this book address fish and endangered species
    issues, drawing from GCES research.

    Clarkson, R.W., O.T.  Gorman, D.M.  Kubly, P.C.  Marsh, and R.A.
    Valdez.  "Management of Discharge, Temperature, and Sediment in Grand
    Canyon for Native Fishes." Mar.  1994.  A "white paper" provided to
    the EIS team, written by a number of key fish researchers from
    various agencies/organizations.  In it, the researchers present their
    thoughts on native fish management issues.  This document was
    mentioned by EIS team members as influential in their early
    discussions on fish issues.  However, it does not appear in the final
    EIS bibliography.

    Colorado River Endangered Fishes Critical Habitat Draft Biological
    Support Document.  U.S.  Fish and Wildlife Service, Sept.  3, 1993.
    Critical habitat must be designated for endangered species.  This
    document was mentioned by one researcher with whom we spoke as an
    example of how agencies should handle scientific data in
    environmental policy papers.

    Draft Recovery Implementation Program for Endangered Fish Species in
    the Upper Colorado River Basin.  U.S.  Fish and Wildlife Service,
    Sept.  3, 1993.  This document is not directly related to activities
    at the Glen Canyon Dam but contains information about the recovery of
    endangered fish in the Colorado River Basin.

    Final Biological Opinion:  Operation of Glen Canyon Dam as the
    Modified Low Fluctuating Flow Alternative of the Final Environmental
    Impact Statement (2-21-93-F-167).  U.S.  Fish and Wildlife Service,
    Dec.  21, 1994.  The final biological opinion and its related
    reasonable and prudent alternative were developed by FWS in response
    to Reclamation's request for formal consultation under section 7 of
    the Endangered Species Act.  The final biological opinion states that
    the preferred alternative is likely to jeopardize the continued
    existence of the humpback chub and razorback sucker and is likely to
    destroy or adversely modify designated critical habitat.  FWS'
    position is that the Seasonally Adjusted Steady Flow alternative may
    be more beneficial for these endangered native fish.

    Glen Canyon Dam:  Beach/Habitat-Building Test Flow, Final
    Environmental Assessment and Finding of No Significant Impact.
    Bureau of Reclamation, Feb.  1996.  This report presents the findings
    of the required environmental assessment prepared prior to
    implementing the spring 1996 "spike" flow.

    Glen Canyon Dam Discharge Temperature Control Draft Appraisal Report.
    Bureau of Reclamation, June 14, 1994.  This draft report discusses
    options for studying and implementing temperature controls at the
    Glen Canyon Dam, including building a selective withdrawal structure.

    Minckley, W.L.  "Native Fishes of the Grand Canyon Region:  An
    Obituary?" Colorado River Ecology and Dam Management.  Proceedings of
    a Symposium, May 24-25, 1990, Santa Fe, New Mexico, pp.  124-177.
    Washington, D.C.:  National Academy Press, 1991.  This paper is
    listed in the final EIS bibliography.  It is a part of the book
    developed from a symposium sponsored by the National Research
    Council's Committee to Review the Glen Canyon Environmental Studies.
    This paper is an overview of native fish issues by a recognized
    expert in the field.

    Operation of Glen Canyon Dam - Fish and Wildlife Coordination Act
    Report.  U.S.  Fish and Wildlife Service, June 28, 1994.  In
    accordance with the Fish and Wildlife Coordination Act, FWS submitted
    this report to Reclamation with recommendations in connection with
    the dam's operations.  The Fish and Wildlife Coordination Act does
    not require Reclamation to accept the recommendations; however,
    Reclamation has agreed that reasonable and practicable
    recommendations will be implemented.  The Fish and Wildlife
    Coordination Act ensures that fish and wildlife receive equal
    consideration during the planning and construction of federal water
    projects.

    "Organisms and Biological Processes," River Resource Management in
    the Grand Canyon, pp.  84-117.  National Research Council Committee
    to Review the Glen Canyon Environmental Studies, 1996.  This is a
    chapter of a National Research Council Committee report on GCES.  The
    purpose of this report and the committee's task was to review
    research that was done in connection with the GCES and to comment on
    the application of science in the management program of the Colorado
    River.

    Response to the Final Biological Opinion on the Operations of Glen
    Canyon Dam.  Bureau of Reclamation, Apr.  6, 1995.  This is
    Reclamation's official response to, and addressing of, the issues
    presented in the final biological opinion.  In it, Reclamation states
    that it does not agree with all the points made or positions taken by
    FWS but will take steps to comply with them.

    Threatened Native Wildlife in Arizona.  Phoenix, Arizona:  Arizona
    Game and Fish Department, 1988.  This publication presents
    information on a variety of species and subspecies including fish,
    amphibians, reptiles, birds, and mammals.

          OFFICIALS INTERVIEWED
    ------------------------------------------------------ Appendix IV:7.9

    We interviewed the following individuals about the fish impact
    determinations and the related Glen Canyon Dam EIS issues.

    Michael Armbruster, Bureau of Reclamation
    Frank Baucom, U.S.  Fish and Wildlife Service
    Debra Bills, U.S.  Fish and Wildlife Service
    Bryan Brown, SWCA, Inc.
    Steven Carothers, SWCA, Inc., Hopi Tribe
    Michael Douglas, Arizona State University
    Owen Gorman, U.S.  Fish and Wildlife Service
    David Harpman, Bureau of Reclamation
    Christine Karas, Bureau of Reclamation
    Dennis Kubly, Arizona Game and Fish Department
    William Leibfried, SWCA, Inc., Hualapai Tribe
    Gordon Lind, Bureau of Reclamation
    Paul Marsh, Arizona State University, Center for
     Environmental Studies
    Margaret Matter, Western Area Power Administration
    Debra McGuinn-Robbins, Arizona Game and Fish Department
    Wendell Minckley, Arizona State University
    Anthony Morton, Western Area Power Administration
    Ronald Moulton, Western Area Power Administration
    Clayton Palmer, Western Area Power Administration
    Timothy Randle, Bureau of Reclamation
    Lawrence Riley, Arizona Game and Fish Department
    John Thomas, SWCA, Inc., Navajo Nation
    Harold Tyus, University of Colorado, Boulder
    Richard Valdez, BIO/WEST, Inc.
    David Wegner, Bureau of Reclamation, Glen Canyon
     Environmental Studies
    Judy Weiss, Former Glen Canyon Environmental Studies
     Researcher (currently not active in the research community)

    HYDROPOWER
    =========================================================== Appendix V

    The purpose of this appendix is to review the methodology and key
    assumptions that the Bureau of Reclamation used to estimate the
    economic impact on hydropower of alternative water releases at the
    Glen Canyon Dam.  The Glen Canyon Dam, which began producing power in
    1964, is part of the Colorado River Storage Project, a federal
    project for water development in the Upper Colorado River Basin.
    Reclamation's purpose in analyzing hydropower issues in the EIS was
    to determine the impacts on the power system of potential changes in
    the Glen Canyon power plant operations.  We found that Reclamation's
    methodology for estimating the economic cost of changing the dam's
    operations is reasonable and that Reclamation used the best available
    information at the time of the study.

    Reclamation has estimated that the annual economic cost of changing
    the operations at the dam could range from -$1.5 million under the
    Maximum Powerplant alternative to $123.5 million under the Seasonally
    Adjusted Steady Flow alternative (in 1991 dollars, relative to the
    No-Action alternative).  We found shortcomings in several of the
    assumptions Reclamation used in the power analysis, inconsistencies
    in some results, and two phase III computational errors, which
    suggest that the estimated economic impacts may be either overstated
    or understated.  Because future events are inherently uncertain and
    because the actual cost of changing the dam's operations could also
    depend on factors yet to be determined, such as whether or not an
    Endangered Fish Research Program is implemented and the pace of
    deregulation in the electric utility industry, the actual economic
    impacts on power users may differ from those estimated.  However,
    because the shortcomings we identified generally affect the estimates
    for all of the alternatives, we do not believe that addressing the
    shortcomings would alter the relative ranking of the fluctuating and
    steady flow alternatives.  Furthermore, Reclamation and
    representatives of the power industry believe that the results of the
    hydropower analysis presented in the final EIS are reasonable and
    usable.  As a result, we believe that Reclamation's estimated
    economic impacts can be used to compare in a general way the economic
    trade-offs that are associated with the various flow alternatives.

       INTRODUCTION
    --------------------------------------------------------- Appendix V:1

    The Glen Canyon Dam is owned, operated, and maintained by the Bureau
    of Reclamation.  The Western Area Power Administration (WAPA)--a
    power-marketing administration established in the Department of
    Energy Organization Act of 1977--markets and transmits the power
    produced at the dam (that is, power in excess of that used by
    projects involving irrigation and flood control).  WAPA, in
    compliance with the Colorado River Storage Project (CRSP) Act of
    1956, is obligated to provide first priority to the power needs of
    CRSP Participating Projects (for example, Reclamation's irrigation
    projects).  Power that is surplus to this "project use" requirement
    is then marketed by WAPA to wholesale firm-power customers entitled
    to preference allocations (for example, municipal and county
    utilities, rural electric cooperatives, and other nonprofit
    organizations financed under the Rural Electrification Act of 1936).
    WAPA generally enters into long-term contracts with its preference
    customers to sell firm power (that is, long-term capacity and energy)
    at a rate that is limited to the recovery of its costs and all costs
    assigned to power for repayment, including that portion of irrigation
    costs beyond the ability of the user to repay per the CRSP Act (this
    rate is referred to as the Salt Lake City Area/Integrated
    Projects--SLCA/IP--rate).  If its customers require additional energy
    and additional energy is available, WAPA may sell short-term power to
    them at a price ranging from the SLCA/IP rate to the spot market
    rate, depending on market conditions.  If WAPA's generation exceeds
    the needs of Reclamation's project use requirements and of the
    SLCA/IP's firm-power customers, energy may be exchanged with other
    suppliers or may be sold on the spot market.  On the other hand, if
    WAPA's generation is less than the long-term firm-power commitments,
    WAPA must purchase replacement power on the spot market, make
    short-term contractual purchases, or exchange energy from other
    suppliers to make up the deficit.

    Historically, maximum power production at the dam has been limited to
    1,300 megawatts, which corresponds to a water release of 31,500 cubic
    feet per second.  Power production (that is, instantaneous output,
    measured in watts) is a function of reservoir head, flow, and the
    generating capacity of the dam's turbines.  The dam has eight
    electric generators that were originally installed when the dam was
    constructed and "uprated" to 1,356 megawatts during the 1980s.
    Energy production (that is, power produced over time, measured in
    watt-hours) is a function of capacity over time or the amount of
    water released over time.  During a typical year, water releases
    average about 10 million acre-feet, corresponding to an average
    annual energy production of about 5 million kilowatt hours.\1

    Currently, WAPA markets power from the Glen Canyon Dam to
    approximately 180 preference customers located mainly in Colorado,
    New Mexico, Arizona, Utah, Nevada, and Wyoming.  These customers sell
    electricity to about 1.7 million residential, commercial, industrial,
    and agricultural customers.  Since November 1, 1991, the Department
    of the Interior has operated the dam under an interim flow regime,
    whereby water releases are generally limited to a maximum of 20,000
    cubic feet per second (cfs).

    Reclamation's purpose in preparing the Glen Canyon Dam's
    environmental impact statement was to determine specific options that
    could be implemented to minimize the adverse impacts on the
    downstream resources and Native American interests in the Glen and
    Grand canyons.  In connection with hydropower production, the key EIS
    issue was to determine the impacts on the power system of potential
    changes in the Glen Canyon power plant's operations.  Reclamation was
    responsible for evaluating the economic, project repayment, and rate
    impacts of changing the magnitude and timing of water releases from
    the Glen Canyon Dam.  To make its assessment, Reclamation identified
    power operations flexibility (for example, the ability of WAPA to
    provide services to its customers) and power-marketing resources (for
    example, capacity and energy), costs, and rates as EIS indicators.
    Reclamation examined the effect that nine different alternative flow
    regimes could have on the EIS indicators.  However, only the impact
    on the power- marketing indicator was quantified; the impact on power
    operations flexibility was assessed qualitatively.

    Under each of the nine alternative flow regimes, the total volume of
    water released annually would be the same and would depend on a
    number of factors, including long-range operating criteria, such as
    an annual minimum flow of 8.23 million acre-feet and balanced storage
    between Lake Powell and Lake Mead (formed by the Hoover Dam).
    However, the nine alternatives would differ in terms of their daily,
    monthly, and seasonal flows.

    The nine alternative flow regimes can be grouped into three main
    categories:  (1) unrestricted fluctuating flows, (2) restricted
    fluctuating flows, and (3) steady flows.  The unrestricted
    fluctuating flow alternatives include the No-Action and Maximum
    Powerplant regimes.  The No-Action alternative, which reflects
    pre-1991 historic operations, would allow daily fluctuations up to
    30,500 cfs, depending on the season.  The Maximum Powerplant
    alternative would allow daily fluctuations up to 32,200 cfs, also
    depending on the season.

    The restricted flow alternatives include the high, moderate, modified
    low, and interim low fluctuating flow regimes.  In general, the
    restricted fluctuating flow alternatives would restrict ramping
    (increases or decreases in cfs per hour) and daily fluctuations (cfs
    per 24 hours) and increase the daily minimum release.  In general,
    maximum releases would be no greater than 31,500 cfs for the high and
    moderate flow alternatives, 25,000 cfs for the modified low flow
    alternative, and 20,000 cfs for the interim low flow alternative.

    The steady flow alternatives include the existing monthly volume,
    seasonally adjusted, and year-round steady flow regimes.  In general,
    the steady flow alternatives would restrict daily fluctuations to
    plus or minus 1,000 cfs, providing steady flows on either a monthly,
    seasonal, or year-round basis.  Under the seasonally adjusted flow
    alternative, the highest releases (that is, no greater than 18,000
    cfs) would occur in May and June, and the lowest releases would occur
    between August and December.

    Under habitat maintenance flows, however, releases could be greater
    than 31,500 cfs under the Moderate Fluctuating Flow alternative,
    greater than 25,000 under the Modified Fluctuating Flow alternative,
    and greater than 18,000 cfs under the Seasonally Adjusted Steady Flow
    alternative.

    One of the key attributes of hydropower is that it can be turned on
    and off relatively quickly, allowing operators to respond to daily,
    hourly, or instantaneous fluctuations in the demand for electricity.
    Demand is typically highest during on-peak periods (for example,
    Monday through Saturday, 7 a.m.  to 11 p.m.) and lowest during
    off-peak periods.  Operationally, hydropower generators can respond
    to changes in load more easily than most other types of generation,
    which makes hydropower operationally more valuable any time load
    following (power generation that instantaneously rises and falls in
    response to the demand for electricity) is required.  As a result of
    the operating constraints under the restricted and steady flow
    regimes, the maximum flows would generally be lower during on-peak
    periods, reducing on-peak energy production.  Consequently, in
    general, the flexibility of power operations would be reduced under
    the restricted and steady flow alternatives.  In addition, capacity
    (that is, instantaneous output) would be lower, generally speaking,
    under the restricted and steady flow alternatives, leading utilities
    to seek alternative and potentially higher-cost sources of peaking
    capacity.  However, the total energy produced at the Glen Canyon Dam
    would not change--energy production would simply be shifted from the
    on-peak demand periods when it is most valuable to off-peak periods
    when it is less valuable.  The additional energy produced during the
    off-peak periods would be available for sale in regional and other
    electricity markets.

    --------------------
    \1 A kilowatt hour is the amount of electrical energy involved in a
    demand or requirement for 1 kilowatt over a period of 1 hour.

       RECLAMATION'S POWER IMPACTS
       METHODOLOGY IS GENERALLY
       REASONABLE
    --------------------------------------------------------- Appendix V:2

    We found that Reclamation's methodology for estimating the economic
    impact of alternative water releases at the dam is generally
    reasonable.  For example, a strength of Reclamation's power analysis
    is that it was conducted by a committee of specialists from the
    federal government, the utility industry, and the environmental
    community, and as a result, the analysis reflects a broad range of
    views.  Other key features of the power analysis that we found
    appropriate include the use of a detailed analysis to determine the
    impact of alternative flows on hydropower production at the dam, a
    national perspective to estimate economic impacts, utility-specific
    data to determine the economic impact to the regional power system,
    and a sensitivity analysis to test the impact of key assumptions.
    Finally, Reclamation was responsive to the comments received on the
    draft EIS and partially revised the power analysis for the final EIS.

          POWER RESOURCES COMMITTEE
          CONDUCTED POWER STUDY
    ------------------------------------------------------- Appendix V:2.1

    To draw on expertise from the federal government, the utility
    industry, and the environmental community, Reclamation created a
    Power Resources Committee (the Committee) in 1989 to study the
    impacts of the various flow alternatives on the power system.  Under
    Reclamation's lead, the Committee's responsibility was to define the
    scope of analysis, select modeling techniques, make basic
    assumptions, review preliminary analyses, and report findings.  The
    Committee included representatives from the Colorado River Energy
    Distributors Association, the Environmental Defense Fund, and WAPA.
    In addition, Reclamation's primary contractor--HBRS, Inc.  (now
    Hagler Bailly Consulting)--subcontracted with Stone & Webster
    Management Consultants, Inc., to serve as technical advisor to the
    Committee, collect data, run simulation models, synthesize findings,
    and write and prepare the Committee's reports.  Another
    subcontractor, EDS Management Consulting Services, Inc., was involved
    in later phases of the power analysis.  We found that the Committee
    conducted a comprehensive analysis of the impacts on the power
    system.

    Using federal principles and guidelines for water resource projects
    and the professional judgments of its members, the Committee
    conducted an extensive analysis of the potential impacts on the power
    system from alternative water releases at the dam.  For example, the
    Committee analyzed the impact on the regional power market that
    receives power from the dam, involving utilities in Arizona, New
    Mexico, Nevada, Utah, Colorado, and Wyoming.  In addition, using
    historic operations as a base case or "No-Action" alternative, the
    Committee estimated the economic impacts of several different
    alternative flow regimes on the dam's power output and the regional
    power system over a 50-year period beginning in 1991.

          POWER RESOURCES COMMITTEE
          CONDUCTED DETAILED ANALYSIS
          OF IMPACTS ON POWER
          PRODUCTION
    ------------------------------------------------------- Appendix V:2.2

    The Committee conducted a detailed analysis to determine the
    potential impact of the alternative water releases on the dam's power
    production.  For example, the Committee used future projections of
    hydrologic conditions at the dam, two different marketing approaches,
    and standard microeconomic principles to estimate the amount of power
    that would be available for sale under each alternative flow regime
    over the 50-year analysis period.

    To develop long-term monthly projections of water releases and power
    and energy production at the dam, the Committee used Reclamation's
    Colorado River Simulation System.  This system projects future water
    conditions at the dam on the basis of historic water conditions.  In
    addition, the Committee used two marketing approaches to estimate the
    power and energy that could be marketed over the analysis period.
    One marketing approach--the Contract Rate of Delivery (CROD)--is
    based on the current marketing practices used by WAPA to market the
    dam's power and assumes that a fixed amount of power would be
    available for marketing.  The other approach--the Hydrology
    approach--assumes that a variable amount of power would be available
    for marketing, depending on the actual hydrologic conditions at the
    dam.  In general, the Committee found that more capacity is forgone
    under the CROD approach than under the Hydrology approach in moving
    from the No-Action alternative to the fluctuating and steady flow
    alternatives.

    Under the CROD approach, the power available under each alternative
    flow regime would be fixed at an amount that could be expected to be
    available roughly 9 years out of 10.\2 During periods when less power
    is available, WAPA is responsible for purchasing the replacement
    power needed to meet its contract commitments.

    By contrast, the Hydrology marketing approach assumes that the power
    and energy available for marketing would depend on the actual
    hydrologic conditions at the dam, which could vary monthly, daily, or
    hourly, depending on streamflow and reservoir storage conditions.
    WAPA's customers would be responsible for purchasing additional power
    during periods when the dam's production is insufficient to meet
    their needs.

    The Committee used two different methods to estimate the capacity and
    energy that would be available under the CROD and Hydrology marketing
    approaches for the fluctuating flow alternatives.  The geometric
    method was used to estimate the power and energy available under the
    CROD.  The peak-shaving algorithm was used to estimate the capacity
    and energy available under the Hydrology marketing approach.  The
    geometric method uses geometric principles to approximate hourly
    operational constraints and calculate the amount of capacity and
    energy available on a daily basis.  By contrast, the peak-shaving
    algorithm uses load projections, which vary hourly, daily, and
    seasonally, and operational constraints to optimally allocate water
    releases during periods of peak demand.  The resulting estimates of
    capacity and energy represent the amount that would be available for
    each marketing arrangement for each of the alternatives.\3

    In general, less capacity is available for the No-Action alternative
    under the Hydrology approach than under the CROD approach.  For
    example, the Committee found that the marketable capacity during the
    winter under the CROD would be about 1,058 megawatts compared to an
    average of 923 megawatts under Hydrology.

    --------------------
    \2 The CROD level is based on WAPA's desire to reduce the risk of not
    being able to provide a reliable level of power and energy.

    \3 Both the geometric method and the peak-shaving algorithm have
    limitations.  The geometric method assumes load does not vary on a
    daily basis, and thus may not accurately capture daily changes in
    load, and the peak-shaving algorithm assumes perfect knowledge of
    future hourly demand, and thus may overoptimize the hydro dispatch.

          POWER RESOURCES COMMITTEE
          USED NATIONAL PERSPECTIVE TO
          ESTIMATE ECONOMIC IMPACTS
    ------------------------------------------------------- Appendix V:2.3

    The Committee followed federal principles and guidelines for water
    resources planning where applicable in developing the analysis of the
    impacts to the power system.  For example, consistent with the
    federal principles and guidelines, the Committee used a "federal
    economic analysis" approach to estimate the economic costs to society
    from changing water releases at the federally owned Glen Canyon Dam.
    The Committee also analyzed the financial impacts on individual
    utilities using a "utility economic analysis" approach, and the
    impact on the retail rates of selected end-users.

    Federal principles and guidelines state that the federal objective of
    water and related land resources planning is to contribute to the
    national economic development consistent with protecting the
    environment, pursuant to national environmental statutes, applicable
    executive orders, and other federal planning requirements.\4 The
    principles and guidelines further state that contributions to
    national economic development are increases in the net value of the
    national output of goods and services, expressed in monetary units.
    Consistent with this guidance, the Committee included in its economic
    analysis only those costs associated with constructing and operating
    new generating resources and operating those existing generating
    resources that would be needed to replace forgone power at the dam.
    The Committee excluded other costs--referred to as "transfer
    payments"--from the economic analysis.  Transfer payments, including
    the fixed capital costs of currently operating powerplants, reflect a
    redistribution of income from one group in society to another and, as
    a result, do not reflect a net cost to society.  For example, when a
    utility purchases power from another utility to replace forgone power
    at the dam, the appropriate measure of costs for the national
    economic perspective is the marginal cost of production.  The fixed
    capital cost of the existing powerplant is considered a "sunk" cost.
    Because the decision to build the existing powerplant was made before
    the decision to change the dam's operations, the fixed costs of the
    existing plant are not an economic impact of changes in the dam's
    operations.

    Because the regional power system currently has excess generating
    capacity, the economic impacts of the alternative flow regimes are
    lower during the early years of the 50-year analysis period.
    Economic costs rise over time, however, as the region's excess
    capacity is used up and new resources are constructed to replace
    forgone capacity at the dam.

    In addition to the federal economic analysis, the Committee also
    measured the financial cost to individual utilities in a utility
    economic analysis.  In estimating the financial impact on utilities,
    the Committee included transfer payments that incorporate such costs
    as the fixed costs of existing powerplants.  In general, the
    financial impacts are substantially higher than the economic impacts
    because they include transfer payments between utilities.  The
    Committee also examined the impact of higher financial costs on the
    retail rates of some end-use customers.

    --------------------
    \4 Economic and Environmental Principles and Guidelines for Water and
    Related Land Resources Implementation Studies, U.S.  Water Resources
    Council, Mar.  10, 1983.

          POWER RESOURCES COMMITTEE
          CONDUCTED DETAILED ANALYSIS
          OF IMPACTS ON LARGE
          UTILITIES
    ------------------------------------------------------- Appendix V:2.4

    The Committee conducted a detailed analysis of the impact of
    alternative flows on seven utilities from the regional power
    market.\5 In addition, the Committee used state-of-the-art and
    industry-standard simulation models to project the power resource
    additions and the production costs that the large utilities would
    incur to replace forgone power at the dam.  In addition to the
    large-utility analysis, the Committee also estimated the impact of
    the alternative flow regimes on about 100 smaller utilities, using a
    spreadsheet model.

    The Committee divided the regional power market into two basic
    groups:  (1) seven large utilities, which own generating resources
    and sell power to other utilities and which represent about one-half
    of the regional power market, and (2) about 100 small utilities,
    which rely primarily on other utilities to generate their power
    needs.

    From the large utilities, the Committee collected detailed data such
    as load and peak demand forecasts, the capacity and the operating
    costs and operating life of each generating unit, firm load purchases
    and sales, and the current and projected demand-side management
    programs.\6 In addition, the Committee developed assumptions about
    future prices for natural gas, oil, coal, and nuclear power and the
    future costs of adding new generating resources.

    On the basis of the utility-specific data and using the Electric
    Generation Expansion Analysis System (EGEAS), the Committee
    calculated for the base case and each alternative flow regime each
    large utility's future expansion plan.  The expansion plans represent
    the least-cost combination of new generating resources (or
    demand-side management programs) and purchased power that each
    utility would need to meet future demand for electricity.\7 In
    addition to the EGEAS model, the Committee used the Electric Utility
    Financial and Production Cost Model (Elfin) to cross-check the
    production cost estimates.  The Committee used a 20-year planning
    period, beginning in 1991, to develop the expansion plans; a 30-year
    extension period was added on to complete the 50-year analysis
    period.  Under the extension period, load was held constant but costs
    were allowed to escalate.

    To model the large utilities in an integrated way, the Committee used
    several interconnected utility systems--consisting of a large utility
    and other utilities that sell or purchase power from the large
    utilities--to determine the effect of resource coordination on the
    selection of future generating resources by the large utilities.  The
    large utilities were modeled to use their own generation resources to
    meet load demand.  However, a utility was allowed to meet deficits or
    surpluses by purchasing energy from or selling it to its
    interconnected system.

    Because most of the modeled small utilities rely on other utilities
    to generate their power needs, the Committee used historic load data
    from the small utilities, replacement costs from the large-utility
    analysis, and a spreadsheet model to estimate the economic impact on
    small utilities over the analysis period.  For example, the cost to a
    small utility of replacing forgone capacity was calculated as the
    increase in capacity and/or production costs incurred by the small
    utility's alternate supplier (that is, large utility).  Unlike the
    large-utility analysis, however, the estimated costs for small
    utilities may not necessarily reflect the least-cost approach for
    replacing forgone power.  For example, demand-side management
    programs were not considered as an option that small utilities could
    use to replace forgone power.

    For both large and small utilities, the Committee calculated the
    economic costs for the base case and each alternative flow regime,
    under both the CROD and Hydrology marketing approaches.  A discount
    rate of 8.5 percent was used to convert the annual stream of future
    economic costs to 1991 present valued dollars.\8 The Committee also
    "levelized" the total present-value cost estimate over the 50-year
    period to determine the annual levelized costs.

    The difference between the base case and each alternative flow regime
    reflects, essentially, the cost of adding new generating capacity to
    replace forgone peaking power, and the cost of operating new and
    existing generating units to replace the energy shifted from on-peak
    periods to off-peak periods.  A simplified representation of the
    Committee's methodology is shown in figure V.1.

       Figure V.1:  Simplified
       Representation of the Power
       Resource Committee's Power
       Systems Economic Impact
       Methodology

       (See figure in printed
       edition.)

       (See figure in printed
       edition.)

    GAO presentation of the Bureau of Reclamation's data.

    --------------------
    \5 One of the seven large utilities is no longer in existence.

    \6 Demand-side management programs are used by utilities to promote
    more efficient energy use and include, for example, rebating or
    subsidizing the purchase of more efficient home appliances.

    \7 The expansion plans were determined on the basis of the impacts of
    each alternative for the CROD marketing approach.  The Committee used
    the expansion plans developed for the CROD approach to analyze the
    impacts of each alternative under the Hydrology marketing approach.

    \8 The Committee measured costs in nominal terms (that is, including
    inflation) partly because the federal discount rate policy for water
    resources planning requires the use of a nominal discount rate.  The
    Committee also conducted a separate analysis using inflation-adjusted
    dollars and the nominal rate; however, this analysis is inconsistent
    because it uses a nominal rate to discount inflation-adjusted
    dollars.

          POWER RESOURCES COMMITTEE
          USED SENSITIVITY ANALYSIS TO
          TEST IMPACT OF KEY
          ASSUMPTIONS
    ------------------------------------------------------- Appendix V:2.5

    The Committee assessed the impact of changes in several key
    assumptions on the estimated economic costs.  For example, for the
    large-utility analysis, the Committee assessed the impact of changes
    in assumptions about load growth, capital costs, fuel costs and
    escalation rates, environmental costs, hydrologic conditions,
    demand-side management program costs, and the potential for a
    curtailment in electricity transmission between WAPA and the Salt
    River Project (Salt River) in Phoenix, Arizona.  WAPA and Salt River
    currently have an agreement for the exchange of surplus Glen Canyon
    Dam generation.

    In addition to the large-utility analysis, the Committee also
    assessed the impact on the small systems of changes in the
    assumptions about escalation rates for electricity prices paid by the
    small utility to their alternate supplier.\9 The sensitivity analysis
    for the large utilities indicated that in particular the results for
    the Hydrology marketing approach are very sensitive to changes in
    load growth and in the level of curtailment in the WAPA-Salt River
    exchange agreement.

    To conduct the sensitivity analysis, the Committee selected several
    variables that were the most influential in determining economic
    impacts.  In addition, the Committee evaluated the effect of changes
    in these variables on the No-Action, Low Fluctuating Flow, and
    Seasonally Adjusted Steady Flow alternatives.  For each variable, the
    Committee assumed low and high values.  For example, zero annual
    growth was used for the low load-growth scenario, and double the
    medium load growth (medium annual growth was assumed to average 1.5
    percent) was used for the high load-growth scenario.

    To examine the effect of alternative curtailment levels on the Salt
    River exchange agreement with WAPA, the Committee assumed that a
    curtailment in the transmission of electricity between Salt River and
    WAPA would occur more or less frequently than the base case,
    depending on the scenario.  Salt River entered into an agreement with
    the United States in 1962 to exchange surplus Glen Canyon Dam
    generation.  Under the agreement, and when generation at federally
    owned facilities is sufficient, WAPA exchanges surplus Glen Canyon
    generation with Salt River for thermal generation at three units in
    which Salt River owns shares.\10 In addition, under certain
    conditions, WAPA wheels power generated at Salt River's units to its
    main customer base in Arizona.  However, because power generation
    would be reduced at Glen Canyon Dam under many of the flow
    alternatives, WAPA may be unable to continue to meet its load
    commitments and also continue to exchange generation with Salt River.
    To approximate the potential for a curtailment in the exchange of
    electricity between WAPA and Salt River, the Committee assumed that
    Salt River's generation shares in the three generating units would
    undergo periodic nonscheduled shutdowns.  In the sensitivity
    analysis, the Committee increased the probability of a shutdown for a
    high forced-outage-rate scenario and decreased the probability of a
    shutdown for a low forced-outage-rate scenario, relative to the base
    case.

    The sensitivity analyses indicated that alternative assumptions in
    load growth and in transmission curtailment can have a large impact
    on the estimated economic impacts, depending on the alternative and
    the marketing approach.  For example, the Committee found that under
    a high-load growth forecast, on average, the 50-year economic cost of
    the Low Fluctuating Flow alternative using the Hydrology marketing
    approach would be higher by about $1.5 billion, compared to the
    No-Action alternative.  Similarly, under a high probability of
    curtailment in the WAPA-Salt River exchange agreement in the
    Seasonally Adjusted Steady Flow alternative under the CROD marketing
    approach, on average, the 50-year economic cost would be higher by
    about $620 million, relative to the No-Action alternative.\11

    --------------------
    \9 Because the sensitivity analysis was conducted separately for the
    large and small systems using different sensitivity variables, the
    analysis does not fully capture the potential impact of changes in
    the key variables.

    \10 Salt River has generation rights at Craig (29 percent of Units 1
    and 2) and Hayden (50 percent of Unit 2) in Northern Colorado, and
    Four Corners (10 percent of Units 4 and 5) in New Mexico.

    \11 The Committee's transmission exchange analysis is based on an
    assumption that WAPA would continue to market load at 1991 levels
    even though less Glen Canyon Dam capacity would be available for
    marketing under most of the alternatives.  Because WAPA's load
    requirements would be lower than assumed, the likelihood and
    subsequent cost of a curtailment would be less, all else being the
    same.

          POWER RESOURCES COMMITTEE
          PARTIALLY REVISED POWER
          ANALYSIS FOR FINAL EIS
    ------------------------------------------------------- Appendix V:2.6

    The Committee's initial analysis of the impacts on the power system,
    published in October 1993 and referred to as the phase II study, was
    included in the draft EIS.  Reclamation received numerous comments on
    the draft EIS' power analysis.  In addition, the Committee solicited
    additional review from three external energy experts, and Reclamation
    partially modified the draft EIS' preferred alternative.  As a
    result, the Committee partially revised the power analysis in a phase
    III study, which was published in July 1995.  For example, the
    Committee updated the projected costs of building gas-combustion
    powerplants, conducted additional sensitivity analyses, and revised
    the retail rate analysis.\12 However, because of Reclamation-imposed
    funding constraints, the Committee was able to revise the economic
    impacts only for the No-Action and the Modified Low Fluctuating Flow
    (preferred alternative) alternatives.

    Furthermore, before the release of the draft EIS, but too late for
    inclusion in the phase II power analysis, Reclamation modified the
    characteristics of the Moderate Fluctuating Flow and Seasonally
    Adjusted Steady Flow alternatives to include beach-building flows and
    habitat maintenance flows.  To include the impact of these
    modifications in the final EIS, the Committee used phase II cost and
    capacity data and a regression model to project the annual economic
    impacts of the two alternatives.

    In addition, to develop comparable results between the phase II
    alternatives and the revised preferred alternative, the Committee
    also used the regression approach and phase II data to estimate the
    annual economic impact of implementing the preferred alternative.
    Before the release of the final EIS, Reclamation modified the
    preferred alternative to include a higher maximum release, a greater
    allowable daily increase in releases from the dam, and beach-building
    and habitat maintenance flows.  Because this revised preferred
    alternative was not analyzed in the phase II study, comparable
    results with the other phase II alternatives were not available.  As
    a result, the Committee used the regression approach to derive the
    economic impacts for the preferred alternative.

    Consequently, the economic impacts for all nine alternatives shown in
    table IV-26 in Reclamation's final EIS (see page 300) are based on
    the phase II analysis and are generally comparable.  The revised
    phase III power analysis for the preferred alternative is discussed
    separately on page 312 in the EIS under the description of the
    preferred alternative.  Because the phase III results reflect a
    revised methodology and updated data, they are not comparable with
    the phase II results.

    Although the phase III analysis reflects an improvement in
    methodology and in some data, it is of limited use in assessing the
    economic trade-offs between alternatives because only the No-Action
    and Modified Low Fluctuating Flow alternatives were modeled.
    Consequently, to show the impacts across alternatives, we display in
    table V.1 the estimated marketable resource and the comparable phase
    II economic results (that is, the point estimates) for the No-Action,
    High Fluctuating Flow, Modified Low Fluctuating Flow, and Seasonally
    Adjusted Steady Flow alternatives under the CROD marketing approach.

                                   Table V.1

                    Projected Impacts of Operational Changes
                     at Glen Canyon Dam on Hydropower Over
                              the Period 1991-2041

                                                      Modified  Seasonally
                                              High         Low    Adjusted
    Glen Canyon Dam                     Fluctuatin  Fluctuatin      Steady
    hydropower\a             No Action      g Flow      g Flow        Flow
    ----------------------  ----------  ----------  ----------  ----------
    Annual energy                6,010       6,010       6,018       6,123
     (gigawatt-hours)
    Winter capacity              1,407       1,383         965         640
     (megawatts)
    Summer capacity              1,315       1,272         845         498
     (megawatts)
    Change in annual                $0  $2,500,000  $44,200,00  $123,500,0
     economic costs (1991                                    0          00
     nominal $), compared
     to No-Action
     alternative
    ----------------------------------------------------------------------
    Source:  Bureau of Reclamation.

    \a Energy and capacity estimates are for WAPA's Salt Lake City
    Area/Integrated Projects facilities in total, including Glen Canyon
    Dam, which represents about 72 percent of WAPA's Salt Lake City
    Area/Integrated Projects generating resources.  The change in annual
    economic costs are only for the operation of the Glen Canyon Dam.

    --------------------
    \12 In the phase III sensitivity analysis, the Committee tested the
    impact of changing the base year to 1995.  The 1995 base year results
    indicated that the economic impact would be higher than the 1991 base
    year results, due partly to lower amounts of excess generating
    capacity.

       ESTIMATED IMPACTS ON THE POWER
       SYSTEM COULD BE OVER- OR
       UNDERSTATED
    --------------------------------------------------------- Appendix V:3

    We found shortcomings in certain phase II and phase III assumptions,
    inconsistencies in some phase II results, and computational errors
    made by Reclamation during the phase III analysis.  For example, the
    Committee did not explicitly consider in either the phase II or phase
    III analysis the effect that higher electricity prices would have in
    reducing the demand for electricity and the need to replace forgone
    power at the dam.  In addition, the Committee's escalation rates for
    future natural gas prices are relatively high, potentially increasing
    the cost of replacing forgone power.  These shortcomings would
    suggest that the estimated economic impacts may be overstated.
    However, we also found that in the phase III analysis the Committee
    did not incorporate the possibility of a curtailment in the Salt
    River exchange agreement with WAPA.  This factor (all else being the
    same) would tend to understate the estimated economic costs to
    hydropower because a curtailment in the exchange agreement might
    require Salt River to purchase additional higher-cost capacity.
    Because of the time and expense that would be required to recompute
    the results with revised methodology and data, we did not determine
    the net effect of these factors on the estimated economic impacts.

          SHORTCOMINGS IN THE
          COMMITTEE'S ASSUMPTIONS
    ------------------------------------------------------- Appendix V:3.1

    Price elasticity effects were not explicitly incorporated into either
    the phase II or phase III analysis.\13 The Committee assumed that
    both load demand and electricity price would continue to rise over
    the planning period.  However, the rise in electricity price would
    likely induce some electricity consumers (wholesale and end-use) to
    consume less electricity or switch to cheaper alternative suppliers.
    Consequently, fewer resources would be needed to replace forgone
    power at the dam, and the subsequent economic impacts would be lower
    than estimated (all else being the same).  The Committee attempted to
    approximate the effects of price elasticity by using a low
    load-growth scenario in the sensitivity analysis.  However, the
    inclusion of price elasticity effects in the base-case assumptions
    would give a more accurate picture of the potential economic impact
    of the alternative flow regimes.

    Relatedly, demand-side management programs were not included as an
    option available to small utilities for replacing forgone power.  The
    Committee assumed that the small systems would replace forgone power
    by purchasing power from their alternative supplier (that is, a large
    utility).  Because this approach limits the choices that small
    utilities have in replacing forgone power, it may not reflect the
    least-cost option of replacing forgone power at the dam.  Small
    utilities, for example, could also implement demand-side management
    programs as a way to mitigate the impact of forgone power, possibly
    at a lower cost.

    We also found that the estimated economic impact of the preferred
    alternative in the phase III analysis does not incorporate the
    possibility of a curtailment in the Salt River exchange agreement
    with WAPA.  During the phase III study, the Committee initially
    assumed that the preferred alternative (that is, the Modified Low
    Fluctuating Flow) would not affect the transmission exchange
    agreement between WAPA and Salt River, on the basis of the phase II
    analysis conducted for the draft EIS.  However, some Committee
    members later revised their original assessment after Reclamation
    modified the preferred alternative to incorporate an increase in the
    maximum release and upramp rates and the beach-building and habitat
    maintenance flows.  Implementation of beach-building and habitat
    maintenance flows could negatively affect the exchange agreement by
    effectively reducing water releases and subsequent power production
    during the summer months, when the demand for electricity is fairly
    high and when Salt River's system is at its peak.  As a result, the
    economic impact could be greater because a curtailment in the
    exchange could require Salt River to add additional higher-cost
    capacity.  The key consultant who directed the power analysis told us
    that if curtailments increase in the summer months the impact on
    economic costs would be significant.  According to some Committee
    members, a lack of time prevented the contractor from including these
    potential impacts in the phase III analysis.

    In addition, the Committee's escalation rates, used to project future
    natural gas prices in the phase II and phase III analyses, are
    relatively high.  The Committee used the escalation rates from
    DRI/McGraw-Hill's fourth-quarter 1991 forecast to project gas prices
    for the western states over the 50-year analysis period (the same
    escalation rates were used for the base case and the alternative
    cases).  DRI has since revised downward its price forecast for
    natural gas.  Despite comments from several reviewers that these
    escalation rates were too high, the Committee did not revise its
    analysis.  For example, using DRI's 1991 forecast for Arizona and New
    Mexico, the Committee assumed that the average gas price would
    increase annually by 8 percent from 1991 through 2010.  By contrast,
    DRI's 1994 forecast projected that gas prices would increase by about
    6 percent annually from 1991 through 2010.  Its 1995 forecast assumes
    that prices will rise by only 5 percent annually over the forecast
    period.  Similar to hydropower, some gas-powered resources can be
    ideal as peaking resources because they can be turned on and off
    relatively quickly to meet fluctuations in demand.  The higher
    escalation rates could affect the power analysis in two ways:  (1)
    gas resources are selected later than they would be if fuel were
    cheaper and (2) gas resources are more expensive to operate than they
    would be under a lower gas-price trend.  The Committee tested the
    impact of lower escalation rates in the phase II sensitivity
    analysis.  However, the inclusion of the lower gas-price trend in the
    base-case assumptions would give a more accurate picture of the
    potential economic impact of the alternative flow regimes.

    Finally, the Committee did not give full credit to the value of
    off-peak energy in mitigating the on-peak demand and energy costs in
    the small-utilities analysis in the phase II analysis.  In general,
    the alternatives shift energy production from the on-peak period to
    the off-peak period.  Even though less energy is produced during
    on-peak periods when it is more valuable, additional energy
    production during the off-peak period may help offset the cost of the
    forgone energy during the on-peak period.  In the phase II analysis,
    however, the Committee essentially assigned a value of zero to some
    of the off-peak energy in the small-utilities analysis.  In a
    separate exercise, the Committee estimated that the value of the
    off-peak energy could reduce annual economic costs by as much as $19
    million, depending on the alternative and the unit price of the
    energy.\14

    --------------------
    \13 The price elasticity of demand is a measure of the percentage
    change in the quantity demanded resulting from a percentage change in
    price.  For example, assuming an estimated price elasticity of demand
    for electricity of -0.4, if the price of electricity rose by 1
    percent, the quantity demanded for electricity would be expected to
    fall by 0.4 percent.

    \14 Power System Impacts of Potential Changes in Glen Canyon Power
    Plant Operations, Final Report (phase II) (Oct.  1993), page ES-17.

          INCONSISTENCIES IN THE
          COMMITTEE'S RESULTS
    ------------------------------------------------------- Appendix V:3.2

    We found two inconsistencies in the Committee's results.  First, the
    economic results for the large utilities and the fluctuating flow
    alternatives under the Hydrology marketing approach are inconsistent
    in the phase II analysis.  For example, in the phase II analysis the
    Committee found that on average less capacity is lost under the
    Hydrology marketing approach than under the CROD approach.  However,
    the economic impacts are higher for the fluctuating flow alternatives
    under the Hydrology approach than for the fluctuating flow
    alternatives under the CROD approach.  The key consultant who
    directed the power analysis told us that the inconsistency is due to
    the Committee's use of the CROD-based utility expansion plans to
    represent expansion plans in the Hydrology marketing approach.
    However, even though the expansion plans are least-cost under a CROD
    marketing approach, they may not reflect least-cost conditions under
    a Hydrology approach.

    In addition, some of the phase II sensitivity analysis results are
    inconsistent.  For example, the Committee found that under a wide
    range of possible expansion plans, the economic impact of the Low
    Fluctuating Flow alternative versus the No-Action alternative would
    be approximately $173,923,000 under the "all medium" scenario (all
    variables held at expected values) and about $143,170,000 under the
    "high-load forecast" scenario.  This result is inconsistent because
    we would expect that the impact of the Low Fluctuating Flow
    alternative versus the No-Action alternative would be greater under a
    future scenario of high-load growth than a future scenario in which
    all variables were held at their expected values.  The key consultant
    who directed the power analysis agreed that this result is
    inconsistent and stated that the most likely explanation is that more
    inefficient generation is replaced in the high-load forecast
    scenario.

          COMPUTATIONAL ERRORS IN THE
          COMMITTEE'S ANALYSIS
    ------------------------------------------------------- Appendix V:3.3

    Computational errors were made by the Reclamation staff during the
    phase III analysis.  The Committee acknowledged these errors in its
    phase III report and stated that the errors affected the results in
    opposite ways.  For example, in revising the monthly hydrologic
    release volumes, Reclamation incorrectly assumed that the
    beach-building flows would occur every year rather than every so many
    years, as is planned.  As a result, more water was projected to flow
    through the spillways and less capacity and energy would be available
    for marketing purposes.  The Committee stated that this error may
    have overstated the economic and financial impact of the preferred
    alternative.  In another case, instead of using the average
    hydrological sequence (that is, the average of dry and wet years) to
    calculate future hydrological conditions and the impact on power
    production at the dam, the Committee used a different hydrological
    sequence.  The Committee stated that this error may have understated
    the economic impact of the preferred alternative under the Hydrology
    marketing approach.  The Committee was unable to correct these errors
    because of time and resource constraints and, consequently, was
    unable to determine the effect of the errors on the estimated
    economic and financial impacts.

       POWER RESULTS CAN BE USEFUL
       DESPITE LIMITATIONS
    --------------------------------------------------------- Appendix V:4

    Because future events are inherently uncertain and the actual cost of
    changing the dam's operations could also depend on factors yet to be
    determined, such as whether or not an Endangered Fish Research
    Program is implemented and the pace of deregulation in the electric
    utility industry, the actual economic impacts on power users may
    differ from those estimated.  Often a point-estimate forecast is used
    to represent the most likely or expected outcome.  In the case of the
    Committee's hydropower analysis, however, the limitations we have
    identified indicate that the point estimates lack precision.  As a
    result, it should not be anticipated that the actual impacts will
    equal the estimated impacts.  However, because the shortcomings we
    identified generally affect the point estimates for all of the
    alternatives, we do not believe that addressing the shortcomings
    would alter the relative ranking of the fluctuating and steady flow
    alternatives.  In addition, we do not believe that addressing the
    inconsistency in the Hydrology marketing analysis (for example, using
    Hydrology-based expansion plans in the expansion analysis) would
    alter the relative ranking of the fluctuating and steady flow
    alternatives.  Moreover, the inconsistency noted in the sensitivity
    analysis does not affect the phase II point estimates.  Because the
    phase III analysis was limited to an assessment of the impacts of the
    No-Action and preferred alternative, the computational errors have no
    impact on the relative ranking of the phase II alternatives.
    Furthermore, Reclamation and representatives of the power industry
    believe that the results of the hydropower analysis presented in the
    final EIS are reasonable and usable.  As a result, we believe that
    the estimated economic impacts can be used to compare in a general
    way the economic trade-offs that are associated with the various flow
    alternatives.

    Consequently, we believe that Reclamation's estimated economic
    impacts are useful for comparing the economic trade-offs that may be
    associated with the fluctuating and steady flow alternatives.  The
    Committee's analysis indicates that the estimated impacts are robust
    across alternatives; that is, the relative ranking of the fluctuating
    and steady flow alternatives is consistent even when taking into
    account changes in key assumptions such as load growth.  Thus, in
    making a determination about the future operational plan for the dam,
    a decision maker can anticipate that, for example, a Seasonally
    Adjusted Steady Flow alternative would cost substantially more than a
    Modified Low Fluctuating Flow alternative.  Furthermore, officials
    from Reclamation and the electric utility industry believe that the
    results are reasonable and usable.  The Reclamation economist who
    served on the Power Resources Committee stated that he generally
    agreed with our observations but believed the methodology and the
    results are reasonable and should be useful in comparing economic
    trade-offs between alternatives.  Similarly, an official from a
    regional utility who also served on the Committee said that the
    methodology and results are reasonable.  Although the association
    that represents the affected power utilities maintained throughout
    the power studies process that the costs to the power system are
    understated, the association does not believe that Reclamation's cost
    estimate is understated by a large magnitude.  The Salt River Project
    has also maintained that the estimated costs do not fully account for
    the higher costs that Salt River could incur as a result of a
    curtailment in the exchange agreement.  However, the Salt River
    Project did not provide us with documentation supporting its
    position.

    As indicated by the Committee's sensitivity analysis, changes in
    variables such as load growth can have a substantial impact on the
    estimated impacts.  Economic impacts could also be affected by other
    factors yet to be determined, including whether or not an Endangered
    Fish Research Program (fish research) is implemented, and the pace of
    deregulation in the electric utility industry.  For example, fish
    research could require higher-than-average water releases in the
    spring and summer months periodically to enable scientists to conduct
    fish research.  As a result, water releases and power production
    during the other half of the year--between September and
    February--will be lower than average.  Consequently, WAPA and its
    customers may have to seek alternative power supplies during certain
    periods, possibly at higher cost.  In addition, the impact of fish
    research on Salt River could be substantial, because the decrease in
    the capacity available in the summer could limit the Salt River-WAPA
    electricity exchange agreement when the Salt River system peaks.  As
    indicated by the Committee's sensitivity analysis, the economic costs
    of changes in the dam's operations increase substantially under
    assumptions of a greater probability of a curtailment in the Salt
    River-WAPA exchange agreement.  According to the draft EIS, the
    economic impact of implementing fish research would fall within the
    range of impacts identified for the Modified Low Fluctuating Flow
    alternative and the Seasonally Adjusted Steady Flow alternative.  The
    former alternative does not include the potential impact of fish
    research, and thus it represents the minimum potential impact.  On
    the other hand, the latter alternative would involve flows similar to
    fish research flows but on a seasonal and annual basis; thus, it
    represents the maximum potential impact.

    Finally, partly as a result of the Energy Policy Act of 1992, more
    opportunities for producing and delivering low-cost power to
    customers could emerge in the regional power market, which could help
    mitigate some of the economic burden that some small utilities in
    particular may bear as a result of changes in the dam's operations.
    For example, under the act, electricity generators (utilities,
    alternative energy producers) can use a competitor's transmission
    grid to wheel power directly to other utilities.  As a result, small
    utilities may have access to alternative power sources that may be
    cheaper than their traditional suppliers.

       SCOPE AND METHODOLOGY
    --------------------------------------------------------- Appendix V:5

    To gain an understanding of the Bureau of Reclamation's power
    methodology, key economic assumptions, and results, we reviewed
    documentation that describes the methodology, economic assumptions,
    and results, including reports by the Power Resources Committee,
    entitled Power System Impacts of Potential Changes in Glen Canyon
    Power Plant Operations, Final Report (phase II) (Oct.  1993), and
    Power System Impacts of Potential Changes in Glen Canyon Power Plant
    Operations, Phase III Final Report (July 1995).  Also, we interviewed
    members of the Power Resources Committee, including the Reclamation
    officials who served as Chairman and economist; representatives from
    the Western Area Power Administration, the Colorado River Energy
    Distributors Association, and the Environmental Defense Fund; and
    representatives from the primary contractor, HBRS, Inc., and
    subcontractor Stone & Webster Management Consultants, Inc.  We also
    interviewed Ms.  Leslie Buttorff who directed the power analysis for
    Stone and Webster.

    To assess the reasonableness of the power methodology, economic
    assumptions, and results, we reviewed federal guidance on water
    resource projects entitled Economic and Environmental Principles and
    Guidelines for Water and Related Land Resources Implementation
    Studies (U.S.  Water Resources Council, Mar.  10, 1983); public
    comments on the draft and final EIS; and comments by three energy
    consultants retained by HBRS, Inc., to review the power analysis.
    Also, we reviewed comments by the National Research Council on the
    power analyses in the draft and final environmental impact
    statements.  In addition, we interviewed members of the Power
    Resources Committee, including representatives from Reclamation, the
    Western Area Power Administration, the Environmental Defense Fund,
    the Salt River Project, and the Platte River Power Authority, as well
    as officials from the Colorado River Energy Distributors Association,
    HBRS, Inc., Stone & Webster Management Consultants, Inc., the
    National Research Council's EIS review team, and several regional
    utilities.  Finally, we used standard microeconomic principles to
    assess the reasonableness of the Power Resource Committee's
    methodology, analytical framework, economic assumptions, and results.

    Our assessment of the reasonableness of Reclamation's methodology was
    limited to a review of the general analytical framework and an
    assessment of the reasonableness of key assumptions and data.  We did
    not evaluate the Committee's calibration of the EGEAS and Elfin power
    simulation models or the small systems spreadsheet model, nor did we
    verify the accuracy of data inputs.

    The organizations and individuals we contacted include those in the
    following list.

    Arizona Public Service Company, Phoenix, Arizona
    Bureau of Reclamation, Denver, Colorado
    Buttorff, Leslie, A.T.  Kearney, Inc., Englewood, Colorado
    Colorado River Energy Distributors Association, Salt Lake City,
      Utah
    Environmental Defense Fund, Oakland, California
    Goodman, Ian, The Goodman Group, Boston, Massachusetts
    HBRS, Inc., Madison, Wisconsin
    Marcus, David, Berkeley, California
    National Research Council, Washington, D.C.
    Plains Electric Generation and Transmission Cooperative, Inc.,
     Albuquerque, New Mexico
    Platte River Power Authority, Fort Collins, Colorado
    Salt River Project, Phoenix, Arizona
    Stone & Webster Management Consultants, Inc., Englewood, Colorado
    Tucson Electric Power Company, Tucson, Arizona
    Western Area Power Administration, Salt Lake City, Utah

    NON-USE VALUE
    ========================================================== Appendix VI

    The construction and operation of the Glen Canyon Dam changed river
    flows and the environment along the Colorado River, affecting, among
    other things, fish populations, beach and wildlife conditions, and
    sites of archeological significance in and near the Glen and the
    Grand canyons.  The values that people may receive from the knowledge
    that such things as, for example, rare plants, animals, and unspoiled
    natural environments exist, even if people do not consume or use
    these goods directly, have been defined as "non-use values." The
    non-use value concept, which is generally attributed to economist
    John Krutilla,\1 can be relevant in natural resource and
    environmental policy settings that focus on proposals to develop the
    natural environment or to mitigate prior resource damage.  In the
    context of the Glen Canyon Dam's EIS, individuals suffered losses in
    non-use values to the extent they valued the natural resources that
    were affected negatively by the changes in river flows after the
    construction of the dam.  Conversely, the changes in the operation of
    the Glen Canyon Dam that are currently under consideration could
    result in environmental improvements in downstream riparian resources
    and hence gains in non-use values.  At the urging of the National
    Research Council, an entity of the National Academy of Sciences,
    Reclamation undertook the non-use value study as part of the Glen
    Canyon Dam's EIS to provide estimates of the non-use values placed on
    changes in environmental quality that may be expected to result from
    particular operating changes at the Glen Canyon Dam.

    The purpose of this appendix is to review the methodology and
    economic assumptions that Reclamation used to estimate non-use values
    and the reasonableness of the results.  A key aspect of Reclamation's
    non-use value study\2 is its use of the "contingent valuation" method
    (CVM) to estimate economic impacts.  While CVM is currently the only
    known method of estimating non-use values empirically, some prominent
    economists question the usefulness of the estimates of non-use values
    produced by contingent valuation studies.  We are not taking a
    position on the appropriateness of contingent valuation generally.

    The Glen Canyon Dam's EIS non-use value study was carried out in a
    manner consistent with contingent valuation and survey research
    guidance developed to produce high-quality contingent valuation
    studies.  Non-use values were estimated for the level of change
    associated with each examined alternative compared to the no-action
    base case.  As such, no estimate for the level of non-use values
    associated with the No-Action Flow alternative is provided.  The
    study produced results that suggest that there are substantial
    non-use values associated with each of the examined alternatives to
    current operations at the Glen Canyon Dam.  However, the results of
    the non-use value study were not available at the time the Glen
    Canyon Dam's final EIS was issued; therefore, the study did not
    receive public comment.  Reclamation noted that although the non-use
    study did not go through the public comment process, the study team
    was comprised of interests that will be affected by changes to the
    Glen Canyon Dam, such as power groups and environmental groups.
    Furthermore, Reclamation stated that the study team received peer
    review at various key decision points in the process and that the
    final results received a positive review by the National Research
    Council.\3

    --------------------
    \1 "Conservation Reconsidered," American Economic Review, vol.  57,
    Sept.  1967, pp.  777-786.

    \2 The term non-use value applies to the value an individual places
    on a resource without directly or indirectly using that resource.
    The term total value applies to the value an individual places on a
    resource, including non-use and use components.  According to
    Reclamation's non-use value study, the study actually measures total
    values.  That is, a respondent to the non-use value survey could have
    been motivated by an experience of direct use (such as rafting or
    fishing) or indirect use of the natural resources in the study area,
    and thus the estimates may include values associated with recreation.
    Reclamation states, however, that the estimated total values are
    likely to consist primarily of non-use values.

    \3 River Resource Management in the Grand Canyon, Committee to Review
    the Glen Canyon Environmental Studies, National Research Council,
    Washington, D.C.:  National Academy Press, 1996, p.  135.

       RECLAMATION USED THE CONTINGENT
       VALUATION METHOD AS BASIS FOR
       ESTIMATING ECONOMIC IMPACTS
    -------------------------------------------------------- Appendix VI:1

    While economists have traditionally preferred to rely on information
    on what people do rather than on what they say they would do,
    economists and survey researchers working in the natural resource and
    environmental areas have developed the theory and practice of
    contingent valuation to estimate non-use values.\4

    Non-use values are typically expressed in terms of willingness to pay
    by individuals or households for a specified environmental
    improvement.  Typically, economists are more accustomed to
    calculating willingness-to-pay measurements for marketed goods
    because, in markets, information on how consumers value goods can be
    determined by their purchases of goods and services.  Because by its
    definition a non-use good is not used, information from market
    transactions in which consumers reveal information about how much
    they are willing to pay for the good is not available.  Contingent
    valuation methods currently offer the only known method of estimating
    non-use values empirically.

    Contingent valuation studies rely on surveys to elicit information
    from consumers to estimate how much they would be willing to pay for
    a non-use good.  In an overview of contingent valuation practice, a
    leading resource economist described three general features typically
    contained in contingent valuation studies.\5 First, a contingent
    valuation study contains descriptions of the policy or program at
    issue and the likely environmental effects so that respondents can
    understand the good they are valuing.  Second, a contingent valuation
    study contains a framework or mechanism for eliciting willingness to
    pay.  Several mechanisms have been used in contingent valuation
    studies, such as open-ended questions (How much would you be willing
    to pay?) and referendum formats (Would you vote for the described
    proposal if your taxes increase by $10?).  Third, a contingent
    valuation study gathers information on socioeconomic variables and
    attitudes about the environment.  This information is used in
    estimating willingness-to-pay functions using econometric techniques.

    Some prominent economists have voiced strong criticisms of contingent
    valuation methods.\6 One of the main concerns about contingent
    valuation methods is the ability of survey research and statistical
    techniques to adequately capture true estimates of willingness to
    pay.  Particularly with respect to non-use values, critics argue that
    it can be very difficult for individuals to comprehend a particular
    environmental or resource valuation issue, or to distinguish what
    researchers envision as a well-defined specific issue from a more
    general "warm glow" effect.  Furthermore, some critics argue that the
    statistical estimation process by which willingness-to-pay estimates
    are produced from survey responses can be very imprecise.\7
    Nonetheless, the contingent valuation method has become a standard
    tool for analyzing many natural resource issues.

    --------------------
    \4 See, for example, Using Surveys to Value Public Goods:  The
    Contingent Valuation Method, by Robert Cameron Mitchell and Richard
    T.  Carson, Resources for the Future, 1989.

    \5 Paul R.  Portney, "The Contingent Valuation Debate:  Why
    Economists Should Care," Journal of Economic Perspectives, 8(4), Fall
    1994, pp.  3-17.

    \6 A collection of studies critical of contingent valuation can be
    found in Jerry A.  Hausman, Contingent Valuation:  A Critical
    Assessment.  Amsterdam:  North Holland Press, 1993; and also Peter A.
    Diamond and Jerry A.  Hausman, "Contingent Valuation:  Is Some Number
    Better Than No Number?," Journal of Economic Perspectives, 8(4), Fall
    1994, pp.45-64.

    \7 Daniel McFadden, "Contingent Valuation and Social Choice,"
    American Journal of Agricultural Economics, 76(4), Nov.  1994, pp.
    689-708.

       DEVELOPING CRITERIA TO EXAMINE
       RECLAMATION'S NON-USE VALUE
       STUDY
    -------------------------------------------------------- Appendix VI:2

    To evaluate Reclamation's Glen Canyon non-use value study, we made
    use of some general guidelines that focus on the quality of a
    contingent valuation study and on the underlying survey research.
    Specifically, we relied on (1) the statement of a panel of prominent
    researchers convened by the National Oceanic and Atmospheric
    Administration (NOAA) to develop some general guidelines applicable
    to conducting contingent valuation studies\8

    and (2) the total design method for conducting mail surveys developed
    by Dillman.\9

    --------------------
    \8 The panel's report was published in the Federal Register.  See 58
    Fed.  R.  4601, Jan.  15, 1993.

    \9 The most widely accepted written standards for mail questionnaires
    are presented by Don A.  Dillman in Mail and Telephone Surveys, the
    Total Design Method (1978).

          NOAA PANEL DEVELOPED GENERAL
          GUIDELINES
    ------------------------------------------------------ Appendix VI:2.1

    As part of a process by which it developed regulations related to oil
    spill damages,\10 NOAA convened an advisory panel to address such
    issues as whether the contingent valuation method was capable of
    providing reliable estimates of non-use values for use in resource
    damage assessments.\11 The panel stated that contingent valuation
    "can produce estimates reliable enough to be the starting point of a
    judicial process of damage assessment, including lost passive-use
    (non-use) values," listed some guidelines for producing credible
    studies, and noted concerns about some past studies.

    The panel suggested (1) using probability sampling and appropriate
    statistical sampling procedures, (2) subjecting the survey
    instruments to pretesting, and (3) taking steps to reduce nonresponse
    rates.  Additionally, the panel suggested that contingent valuation
    studies disclose information on the sample selection process and
    provide information on survey instruments and responses.  The panel
    also suggested that the use of the referendum format, as opposed to
    open-ended elicitation, was desirable.

    The panel suggested that respondents be provided with a reminder that
    paying for the non-use good at issue would result in a smaller budget
    to spend on other goods and services and that they be told of any
    available substitutes.  In this way, the decisions made by the
    respondents may more closely resemble market transactions in which
    consumers make choices in the face of budget constraints.

    The panel stated a preference for the use of in-person surveys as
    superior to telephone or mail surveys.  The panel's report stated
    that it is "unlikely that reliable estimates of values could be
    elicited with mail surveys." This guideline in particular has been
    criticized by some contingent valuation practitioners, who argue that
    the use of large-scale, in-person surveys can dramatically increase
    the cost of conducting contingent valuation studies.

    The NOAA panel echoed the concern that estimated willingness-to-pay
    figures be consistent with common notions of rationality.  One aspect
    of rationality is that, generally speaking, people are willing to pay
    more for greater amounts of a good.  The panel was troubled by
    evidence presented in one contingent valuation study finding that
    estimated willingness to pay "for the cleanup of all lakes in Ontario
    was only slightly more than willingness to pay for cleaning up lakes
    in just one region" and in another study that "willingness to pay to
    take measures to prevent 2,000 migratory birds (not endangered
    species) from dying in oil-filled ponds was as great as that for
    preventing 20,000 or 200,000 birds from dying." The sensitivity of a
    study to these so-called scope effects can be important in evaluating
    its credibility.

    --------------------
    \10 The Oil Pollution Act of 1990, Pub.  L.  No.  101-380, 104 Stat.
    484, required NOAA, within the Department of Commerce, to develop
    regulations for use by natural resource trustees in assessing damages
    due to oil spills.

    \11 The panel was composed of Kenneth Arrow, Robert Solow
    (co-chairs), Edward Leamer, Roy Radner, Howard Schuman, and Paul
    Portney.  Schuman is a prominent survey researcher, and the others
    are economists.  Arrow and Solow are Nobel laureates.

          DILLMAN'S STANDARDS REFLECT
          A TOTAL SURVEY DESIGN METHOD
    ------------------------------------------------------ Appendix VI:2.2

    While the usefulness of contingent valuation methodology has been
    debated, survey research, a key component of contingent valuation
    studies, is itself a mature discipline with an accepted set of
    standards.  For example, Dillman's "total design method" has become
    an accepted standard in survey research for maximizing the quality
    and quantity of responses to mail questionnaires.

    By maximizing the quality of responses, researchers can have greater
    confidence in the validity of their work; that is, they can be surer
    that they are measuring what they intend to measure.  By maximizing
    the quantity of responses they can have greater confidence in the
    reliability of their work; that is, repeated investigations will come
    up with similar results.  Dillman's method provides a comprehensive
    approach that spans the design and implementation of mail
    questionnaires.  From the wording of the questions to the pretest
    regimen to the design of the survey package and, finally, to the
    timetables for mailing and following up on the mailing, Dillman has a
    proven set of techniques that have been embraced by the survey
    research community.

       RECLAMATION'S NON-USE VALUE
       STUDY FINDS SUBSTANTIAL NON-USE
       VALUES ASSOCIATED WITH CHANGES
       IN OPERATIONS AT GLEN CANYON
       DAM
    -------------------------------------------------------- Appendix VI:3

    Using a contingent valuation study, Reclamation estimated non-use
    values for the environmental improvements associated with changing
    the operations at Glen Canyon Dam.  These estimates, which ranged
    from less than $15 per household annually to almost $30 per household
    annually, depending on, among other things, the specific
    dam-operating alternative under consideration, indicate the large
    non-use values associated with environmental improvements and are
    consistent with the idea that some change in the dam's operations
    will lead to these improvements.  Furthermore, although the EIS
    included a discussion of non-use values, the results of the non-use
    value study were not formally included as part of the EIS and thus
    were not subject to the same set of formal comments from interested
    parties.

          AN OVERVIEW OF THE GLEN
          CANYON NON-USE VALUE STUDY
    ------------------------------------------------------ Appendix VI:3.1

    The Glen Canyon non-use value study was one of the economic studies
    Reclamation carried out as part of the Glen Canyon Environmental
    Studies.\12 As part of the study process, a non-use value committee,
    including representatives from the power industry, environmental
    groups, Native American tribes, and federal agencies, met to consider
    interim results and to provide input to the research team.
    Additionally, the study team received peer review at various key
    decision points.

    The researchers addressed some important preliminary issues in a
    qualitative research phase designed to establish whether a contingent
    valuation study would be likely to produce meaningful results.
    First, the researchers determined that representative individuals
    were able to distinguish the Colorado River environment in the Grand
    Canyon from the Grand Canyon itself.  This was important because
    changes in the Glen Canyon Dam's operations would not affect the
    existence of the Grand Canyon itself.  Rather, they would change
    aspects of the riparian environment along the Colorado River in and
    around the Grand Canyon.  Importantly, if people were unable to
    distinguish changes to aspects of the riparian environment from broad
    changes to the Grand Canyon itself, then it would be impossible to
    provide meaningful estimates of non-use values related to operational
    changes at the Glen Canyon Dam.  The researchers were convinced that
    people were able to make these distinctions and, moreover, were
    likely to care about, or to place meaningful values on, these
    resources.

    The researchers also determined that people living far away from the
    Glen Canyon Dam were likely to care about the affected resources.
    This is important in estimating aggregate non-use value because an
    average willingness-to-pay estimate is multiplied by the number of
    individuals or households believed to have non-use values.  Because
    there are close to 100 million households in the United States, an
    average household's willingness to pay estimated to be $5 per year
    yields an aggregate non-use value of $500 million annually.

    A pilot test phase was initiated in early 1994.  A key research
    objective of this phase was to investigate whether willingness-to-pay
    estimates were sensitive to the various flow regimes under
    consideration, that is, whether non-use values were likely to
    increase in measurable ways related to the different river flows
    resulting from the different dam-operating alternatives.  The pilot
    test included a series of nine versions of survey questionnaires
    given to separate samples of 250 respondents.  Three of these
    versions were sent to national samples of households, with each
    version describing one river flow alternative and its likely effects
    on the affected resources.  The three versions were the moderate
    fluctuating flow; the low fluctuating flow; and the seasonally
    adjusted steady flow.  In general, the moderate fluctuating flow
    version describes the smallest improvement in environmental
    conditions, and the seasonally adjusted steady flow describes the
    biggest improvement.  The surveys also describe adverse impacts on
    power customers, with more severe effects described in the seasonally
    adjusted steady flow version.  Two versions, one describing the
    moderate fluctuating flow and one describing the seasonally adjusted
    steady flow, were sent to marketing area households.\13 The other
    four survey versions were sent to national samples and were used to
    address other methodological issues.

    The qualitative research and pilot study phases included a thorough
    development and pretesting strategy, as well as peer and other
    reviews.  During the qualitative research phase, researchers held 15
    focus groups in which various methodological issues were
    investigated.  In particular, focus groups were held in New York,
    Tennessee, and Nebraska to examine the geographic extent to which
    people living at some distance from the study area were likely to
    care about these resources.

    The final phase of the non-use value study, built upon the knowledge
    developed during earlier phases, was designed to estimate non-use
    values.  The researchers selected two samples--a national sample and
    a marketing area sample--and developed seven versions of a mail
    questionnaire.  Multiple versions of the instrument permitted the
    researchers to investigate the differences in non-use values
    associated with the differences in river flow conditions.  While the
    overall Glen Canyon Environmental Studies examined nine alternatives,
    three flow alternatives were considered in the non-use study:
    moderate fluctuating flow; low fluctuating flow; and seasonally
    adjusted steady flow.  According to the non-use study, these
    alternatives "covered most of the range of alternative dam operations
    being studied and were considered to include the set of alternatives
    most likely to contain the eventual preferred alternative."

    --------------------
    \12 The study was performed by Hagler Bailly Consulting under
    contract to Reclamation.

    \13 The marketing area refers to the geographic area in which
    individuals are served by utilities receiving power produced at Glen
    Canyon Dam.

          ESTIMATES OF WILLINGNESS TO
          PAY FOR ENVIRONMENTAL
          IMPROVEMENTS ASSOCIATED WITH
          CHANGES IN THE OPERATION OF
          GLEN CANYON DAM
    ------------------------------------------------------ Appendix VI:3.2

    Non-use values were based on estimates of willingness to pay for the
    described flow alternatives.  Respondents were provided with
    background information on a proposal to change the dam's operations
    and the likely downstream environmental effects and were asked how
    they would vote on the proposal if it were to cost them nothing.  If
    they indicated they would vote yes, they were then asked another
    voting question, but this time the proposal was tied to a specified
    annual dollar amount and to a specified "payment vehicle." This form
    of contingent valuation study is known as the referendum format.  The
    payment vehicle for respondents in the national sample was a tax
    increase, and the payment vehicle for respondents in the marketing
    area sample was a utility bill increase.  Each respondent was
    assigned one of the following eight dollar amounts:  $5, $15, $30,
    $60, $90, $120, $150, and $200.

    Willingness to pay was then estimated using a logistic regression
    based on the resulting "yes or no" answers to the voting question.  A
    variable, referred to here as BID, is defined as the specific dollar
    amount associated with the cost of the referendum proposal presented
    to the respondent.  A variety of other explanatory variables were
    derived from the survey responses.  For example, four variables
    describing the respondent's environmental attitudes were constructed
    using factor analysis of a variety of environmental attitude
    questions provided in the questionnaire.  Also, a score variable was
    calculated from a portion of the survey used to test how well the
    respondent understood the proposal.

    The form of the logistic cumulative density function is:

    probability(yes vote)=1/(1 + exp((-� i*Xi ) -
    BID*BID)),    (1)

    where the i are the coefficients for the explanatory
    variables and BID is the coefficient on the BID variable
    specifically.  An expression for mean willingness to pay (WTP) is
    derived from the following formula suggested by Hanemann\14 :

    WTP = ln (1 + exp � i*Xi) / -BID.   (2)

    The samples were split to focus on the different operating
    alternatives under consideration.  The national sample was split four
    ways, examining two versions of the seasonally adjusted steady flow
    alternative along with the moderate and low fluctuating flow
    alternatives--and the marketing area sample was split three ways.
    For analytical purposes, a set of 0-1 dummy variables were included
    to indicate the different versions.\15

    The non-use questionnaires did not ask a binary "yes or no" vote
    question but used a scale which included "definitely yes" and
    "probably yes." The researchers investigated two definitions of yes
    votes for use in the logistic regressions:  using "definitely yes" as
    the definition of yes, and alternatively with "definitely/ probably
    yes" as the definition of yes.  "Definitely yes" models generated
    mean willingness-to-pay values in the $20 to $38 range across all
    flow alternatives and for both the national and marketing area
    samples.  "Definitely/Probably yes" models generated mean
    willingness-to-pay values of $100 to about $130.  The researchers
    believe that the "definitely yes" definition provides better
    estimates than the use of binary "yes or no" definition.  They also
    believe the "definitely yes" definition yielded lower
    willingness-to-pay estimates.

    To generate population willingness to pay, the researchers had to
    address additional issues.  The regression-derived mean
    willingness-to-pay values apply to those respondents who voted for
    the specified proposal when it was presented to them with the
    condition that they would not have to pay for it.  However, some
    people did not respond to the survey, some respondents did not vote
    on the referendum question, and some respondents did not vote for the
    proposal at zero cost.  In this study, the respondents who did not
    vote and those who voted no were both assigned a willingness to pay
    of $0.  The researchers gathered information on nonrespondents using
    follow-up telephone interviews.\16 \17 The assumed or estimated
    values for each of the groups were averaged together on the basis of
    their proportion of the sample.  Table VI.1 presents the resulting
    willingness-to-pay values for the "definitely yes" version (dollars
    per household per year).

                                   Table VI.1

                     Population Average Willingness to Pay,
                    Definitely Yes Model With Imputed Values
                    for Nonrespondents (1991 Nominal Dollars
                            per Household per Year)

                                                  National  Marketing area
    Riverflow                                       sample          sample
    --------------------------------------  --------------  --------------
    Moderate fluctuating                            $13.65          $22.06
    Low fluctuating                                 $20.15          $21.45
    Seasonally adjusted steady                      $20.55          $28.87
    Seasonally adjusted steady                      $23.79            ----
     (but describing lower power cost
     effects)
    ----------------------------------------------------------------------
    In general, the results indicate that individuals have a significant
    willingness to pay for the environmental improvements associated with
    a change from the no-action alternative to each of the other flow
    alternatives (i.e., the moderate fluctuating, low fluctuating, and
    seasonally adjusted steady flow alternatives).  In addition, the
    national sample results indicate that individuals are willing to pay
    more for the environmental improvements associated with the
    seasonally adjusted steady flow alternative, compared to the moderate
    fluctuating flow alternative, and that the difference is
    statistically significant.  The results also indicate that
    individuals are willing to pay more for the environmental
    improvements associated with the low fluctuating flow alternative,
    compared to the moderate flow alternative; however, this difference
    is not statistically significant.  Consequently, we have less
    confidence in the precision of the estimate for the low fluctuating
    flow alternative.

    Researchers provided ranges around the average willingness-to-pay
    values to reflect the statistical uncertainty surrounding the
    estimates.  These ranges were calculated using repeated sampling from
    the estimated distributions of the parameters generated by the
    logistic regressions.  In essence, the researchers calculated 3,000
    estimates of mean willingness-to-pay for each alternative, arrayed
    them from lowest to highest, and reported the values as the lower and
    upper limits associated with a 95-percent confidence interval.  Table
    VI.2 presents these results for the national sample and table VI.3
    presents these results for the marketing area sample.

                                   Table VI.2

                    Population Weighted Average Willingness
                       to Pay, Definitely Yes Model With
                     Imputed Values for Nonrespondents and
                      the Associated 95-Percent Confidence
                    Interval, National Sample (1991 Nominal
                        Dollars per Household per Year)

                                              Populati
                                                    on
                                              weighted     Lower     Upper
    Riverflow                                  average     limit     limit
    ----------------------------------------  --------  --------  --------
    Moderate fluctuating                        $13.65     $9.27    $20.39
    Low fluctuating                             $20.15    $14.22    $29.29
    Seasonally adjusted steady                  $20.55    $14.57    $29.84
    Seasonally adjusted steady                  $23.79    $17.17    $33.39
     (but describing lower power cost
     effects)
    ----------------------------------------------------------------------

                                   Table VI.3

                    Population Weighted Average Willingness
                       to Pay, Definitely Yes Model With
                     Imputed Values for Nonrespondents and
                      the Associated 95-Percent Confidence
                     Interval, Marketing Area Sample (1991
                    Nominal Dollars per Household per Year)

                                              Populati
                                                    on
                                              weighted     Lower     Upper
    Riverflow                                  average     limit     limit
    ----------------------------------------  --------  --------  --------
    Moderate fluctuating                        $22.06    $16.68    $29.39
    Low fluctuating                             $21.45    $15.84    $29.28
    Seasonally adjusted steady                  $28.87    $22.50    $37.24
    ----------------------------------------------------------------------
    Researchers calculated aggregate willingness-to-pay values on the
    basis of the population averages.  This involved gathering estimates
    of the number of households in the United States and in the marketing
    area as well as population growth rates nationally and for a set of
    states to approximate future growth in the marketing area.\18 A
    50-year period (1991-2040) was used.  Levelized annual aggregate
    willingness-to-pay values were calculated using a discount rate of
    8.5 percent.  The results are presented in table VI.4.

                                   Table VI.4

                      Annual Aggregate Willingness to Pay,
                    Definitely Yes Model With Imputed Values
                      for Nonrespondents (Millions of 1991
                                Nominal Dollars)

                                                  National  Marketing area
    Riverflow                                       sample          sample
    --------------------------------------  --------------  --------------
    Moderate fluctuating                          $2,286.4           $62.2
    Low fluctuating                               $3,375.2           $60.5
    Seasonally adjusted steady                    $3,442.2           $81.4
    Seasonally adjusted steady (but               $3,984.8            ----
     describing lower power cost effects)
    ----------------------------------------------------------------------
    A range of annual aggregate values calculated using the lower and
    upper limits of the 95-percent confidence intervals for the
    population weighted averages are provided in table VI.5 for the
    national sample and in table VI.6 for the marketing area sample.

                                   Table VI.5

                      Range of Values for Annual Aggregate
                    Willingness to Pay, Definitely Yes Model
                    With Imputed Values for Nonrespondents,
                       National Sample (Millions of 1991
                                Nominal Dollars)

                                              Populati
                                                    on
                                              weighted     Lower     Upper
    Riverflow                                  average     limit     limit
    ----------------------------------------  --------  --------  --------
    Moderate fluctuating                      $2,286.4  $1,552.7  $3,415.4
    Low fluctuating                           $3,375.2  $2,381.9  $4,906.2
    Seasonally adjusted steady                $3,442.2  $2,750.3  $4,998.4
    Seasonally adjusted steady                $3,984.8  $2,875.8  $5,592.7
     (but describing lower power cost
     effects)
    ----------------------------------------------------------------------
    Note:  Lower and upper limits refer to the lower and upper limits of
    the 95-percent confidence interval for the population weighted
    average.

                                   Table VI.6

                      Range of Values for Annual Aggregate
                    Willingness to Pay, Definitely Yes Model
                    With Imputed Values for Nonrespondents,
                    Marketing Area Sample (Millions of 1991
                                Nominal Dollars)

                                              Populati
                                                    on
                                              weighted     Lower     Upper
    Riverflow                                  average     limit     limit
    ----------------------------------------  --------  --------  --------
    Moderate fluctuating                         $62.2     $47.0     $82.9
    Low fluctuating                              $60.5     $44.7     $82.6
    Seasonally adjusted steady                   $81.4     $63.4    $105.0
    ----------------------------------------------------------------------
    Note:  Lower and upper limits refer to the lower and upper limits of
    the 95-percent confidence interval for the population weighted
    average.

    --------------------
    \14 W.  Michael Hanemann, "Welfare Evaluations in Contingent
    Valuation Experiments With Discrete Responses," American Journal of
    Agricultural Economics, vol.  66, Aug.  1984, pp.  332-341.

    \15 In other words, the explanatory variables (the Xi) include a set
    of intercept dummies which permits different willingness-to-pay
    amounts to be determined for the different dam operation
    alternatives.  BID is estimated for the whole sample, but
    the � i*Xi component in expression (2) above will be
    different depending on which flow alternative (survey version) is
    being considered.

    \16 The follow-up information was used to estimate willingness to pay
    on the basis of the characteristics derived through this process in
    conjunction with the results of a model using the mail survey
    respondents to predict the likelihood of voting for the proposal at
    zero cost.

    \17 Estimates were provided for population average willingness to pay
    calculated with the assumption that nonrespondents had zero
    willingness to pay.  These estimates were in the range of 15 to 20
    percent less than the corresponding estimates with imputed values for
    nonrespondents.

    \18 These states were Wyoming, Utah, Colorado, New Mexico, Arizona,
    and Nevada.

          EVALUATING THE NON-USE VALUE
          STUDY USING THE NOAA PANEL
          AND DILLMAN'S FINDINGS
    ------------------------------------------------------ Appendix VI:3.3

    We evaluated Reclamation's non-use study on the basis of issues
    considered by the NOAA panel and Dillman's total design methods as
    described above.\19 Most of the NOAA panel's suggested practices were
    part of the design and implementation of the Glen Canyon non-use
    value study, including those related to the sampling, pretesting, and
    reporting of results.  Samples were based on commercially available
    sampling frames and were augmented with motor vehicle and postal
    service address update information.  The researchers took random
    samples proportionate to the number of households in each state for
    the national sample and proportionate to the number of households in
    zip codes for the marketing area sample.\20 Respondents to the
    national survey had higher average levels of educational attainment
    and household income than the underlying population.  It is likely
    that these characteristics are positively associated with willingness
    to pay for environmental improvements and thus increase non-use
    values.  However, the magnitude of the effect is uncertain.  During
    the qualitative research phase, draft questionnaires were pretested
    with six focus groups and six in-depth personal interviews.  The
    questionnaires were reproduced in the report, along with responses to
    the various questions.

    The study used the referendum format in preference to open-ended
    elicitation, and questionnaires emphasized the consumer's budget
    constraint, consistent with suggestions by the NOAA panel.\21

    The study also provided a test on a respondent's level of
    understanding of the issue at hand.

    A notable exception to the NOAA panel's suggested practices is that
    the Glen Canyon non-use value study used mail surveys.  The panel
    strongly favored the use of in-person surveys.  The Glen Canyon
    researchers maintain that well-designed mail surveys are capable of
    producing reliable results.

    With respect to the design and implementation of the mail survey, we
    found that, except for one component, the researchers followed the
    total design method to the letter.  Everything from the size and
    shape of the documents to the timing and amount of follow-up material
    was as Dillman suggested, and in general, the questionnaires were
    designed and implemented with extremely high standards.  The
    researchers made a great effort to ensure that the questions both met
    the needs of the research design and were easily understood by the
    respondents.

    Only the length of the instrument exceeded the maximum suggested by
    Dillman.  The questionnaires were 18 pages, and according to Dillman,
    10 to 12 pages is the maximum length for a questionnaire if a
    researcher does not want reduced response rates.  Nonetheless, the
    average of 74 percent of the usable sample responding to the mail
    surveys and an average of 83 percent responding to the mail and
    follow-up telephone surveys is commendable given the nature of
    general public surveys.  Although a shorter instrument may have led
    to higher response rates, the researchers faced a trade-off between
    the amount of background information and environmental attitude
    questions on the one hand and response rates on the other.

    --------------------
    \19 The NOAA panel's findings have no bearing on the Glen Canyon
    non-use study, and indeed were not published until after the Glen
    Canyon study was well under way.  We refer to them because we believe
    that the NOAA panel's deliberations represent valuable critical and
    impartial thinking related to contingent valuation.

    \20 The national sample size was 3,400 individuals, and the marketing
    area sample size was 2,550.  Each of the seven survey versions was
    administered to 850 individuals.  In the national sample, two
    versions pertained to the Seasonally Adjusted Steady Flow alternative
    and differed not in their descriptions of environmental impacts but
    in their descriptions of possible electricity price impacts on users
    of Glen Canyon power.

    \21 Respondents in the national sample were asked to answer the
    following question:  "If this proposal passes and you had to pay $xxx
    every year for the foreseeable future, on what sorts of things would
    you spend less money in order to pay for the cost of this proposal?"
    In the marketing area survey, respondents were asked a similar
    question about monthly increases in utility bills.  The next question
    then provided an opportunity for the respondent to change his or her
    vote.  (Emphasis is contained in the questionnaires.)

          EVALUATING SCOPE EFFECTS IN
          THE GLEN CANYON NON-USE
          VALUE STUDY
    ------------------------------------------------------ Appendix VI:3.4

    Scope effects were of concern to the NOAA panel.  Scope effects,
    broadly interpreted to mean that changes in estimated willingness to
    pay vary in ways that seem consistent with the changes in the degree
    of environmental improvement, are at the center of the Glen Canyon
    non-use value study because willingness to pay for the environmental
    effects of different river flows should differ to the extent that the
    effects differ.  The researchers investigated scope effects in their
    discussion of the "construct validity" of the non-use value study.\22

    Scope tests can be considered a form of theoretical construct
    validity, in which hypotheses based on economic theory are addressed.
    For instance, one potentially important construct validity test is
    whether income is positively related to measured willingness to pay.
    In their summary of various construct validity issues, the
    researchers stated that they believed the national sample results
    provided the highest level of credibility, but that the marketing
    area sample results were a little less credible.

    Scope issues were examined using both the pilot and final versions of
    the survey.  Compared to the pilot version, the final survey's
    descriptions of the environmental effects differed less sharply
    across the various flow alternatives because, over time, scientific
    assessments carried out in the Glen Canyon Environmental Studies did
    not support such sharp distinctions.\23 Thus, the pilot test language
    permitted a somewhat cleaner test of the general issue of whether
    respondents were able to distinguish among the various degrees of
    environmental improvement associated with the different flow
    alternatives.  Additionally, some versions of the pilot survey used a
    multiple-bounded rather than a single-bounded referendum format.
    This permitted greater statistical precision in testing for scope
    effects.\24

    Some scope tests are provided by the voting behavior of those
    respondents who voted for the proposal facing them at zero cost.
    According to the study, "the portion of respondents who would support
    proposals if the cost to them were zero varied significantly across
    proposals in ways that were consistent with prior expectations."
    Generally, respondents appeared willing to pay more for the
    environmental improvement associated with the Seasonally Adjusted
    Steady Flow alternative than for that associated with the Moderate
    Fluctuating Flow alternative.\25

    Direct tests for scope effects are accomplished by examining the
    dummy variables indicating the various survey versions.  In the
    regressions, each dummy variable can be interpreted as an additional
    willingness-to-pay contribution for the additional environmental
    improvement associated with that flow version over the environmental
    effects associated with the examined reference case, moderate
    fluctuating flow.\26 One complicating factor, however, is that the
    different versions can involve trade-offs.  Specifically, the
    seasonally adjusted steady flow version describes a greater
    environmental improvement but a more serious adverse effect on power
    customers.\27 To focus more clearly on willingness to pay for
    environmental improvement, researchers developed two versions of the
    seasonally adjusted steady flow survey, which differed only in the
    description of the adverse effects on power customers.\28 This
    permits some disentangling of an environmental improvement scope
    effect from the combined effect of environmental improvement and
    adverse power impacts.\29

    Because each survey version designated with a dummy variable offers
    greater environmental improvement compared to the moderate
    fluctuating flow version, expectations are that the parameter
    estimates for variables representing alternative flows should be
    positive.  For the preferred "definitely yes" model, four of the five
    key parameter estimates are of the correct sign.  However, only the
    coefficients for the two seasonally adjusted steady flow alternatives
    in the national sample are statistically significant (i.e., different
    from zero, using a one-tailed test at the 90-percent confidence
    level).  The study acknowledges that the results of these scope tests
    are mixed but suggests that the totality of evidence (including pilot
    test versions and the "definitely and probably yes" models) are
    relevant for discussions of scope tests, and much of that evidence is
    stronger.

    --------------------
    \22 Drawing on methods developed by psychologists, contingent
    valuation researchers often examine three issues relevant to a
    study's reliability.  These are content validity, construct validity,
    and criterion validity.

    \23 For instance, the pilot survey proposal describing the Seasonally
    Adjusted Steady Flow alternative stated that "There would be a major
    improvement in conditions for native fish.  Populations of most
    native fish, including one of the species in danger of extinction,
    would increase." The final survey proposal describing this flow
    alternative stated that "There would be a major improvement in
    conditions for fish.  Native fish, including one of the endangered
    species, would most likely increase in numbers.  However, competition
    from non-native fish may still limit the growth of native fish
    populations."

    \24 Because the multiple-bounded approach was new, the researchers
    decided to use the more traditional single-bounded form in the final
    versions.  Using an additional bound would allow a finer partition of
    the willingness-to-pay range.  For instance, if a respondent
    indicates a willingness to pay $10 but an unwillingness to pay $20,
    the upper bound has been established.  The concern with providing the
    respondent with another dollar amount is that it may provide a
    valuation cue to the respondent and thereby introduce a response
    bias.

    \25 Additionally, in the national sample pilot test, survey versions
    were similar except that one mentioned improved conditions for fish
    while the other did not produce different willingness-to-pay
    estimates.

    \26 In a regression, one of a set of mutually exclusive and
    exhaustive dummy variables is omitted as an explanatory variable.  In
    this way, the "omitted" category can be thought of as the reference
    case.  In the Glen Canyon study, the moderate fluctuation flow
    version is the reference case.

    \27 In the national sample, the referendum proposal described effects
    on households and farmers using power generated at Glen Canyon Dam.
    The fluctuating flow versions contained the following language:  "The
    average electric bill would increase by $3 per month for 1.5 million
    households receiving power from Glen Canyon Dam.  This average
    reflects a maximum increase of $9 per month for 3,600 households and
    a minimum of no increase for 800,000 households.  On average, farm
    incomes would not change significantly.  However, about 300 farmers
    in southern Utah would see their incomes drop by 3%." The steady flow
    version stated:  "The average electric bill would increase by $9 per
    month for 1.5 million households receiving power from Glen Canyon
    Dam.  This average reflects a maximum increase of $21 per month for
    3,600 households to a minimum of no increase for 300,000 households.
    On average, farm incomes would not change significantly.  However,
    about 300 farmers in southern Utah would see their incomes drop by
    6%."

    \28 Specifically, the second version of the steady flow proposal
    included descriptions of the adverse effects on power customers and
    farmers that were identical to those used in the fluctuating flow
    versions.

    \29 The use of two survey versions describing the seasonally adjusted
    steady flow also permits investigation into whether a description of
    the power impacts possibly provides a cue to respondents in answering
    the referendum question.  For example, the value of the dummy with
    the higher power impacts would be greater in magnitude than the dummy
    with the lower power impacts if respondents interpreted the larger
    dollar impacts on power users as an indication of the magnitude of
    the environmental problem.  Conversely, if respondents empathized
    with the plight of power users, the results would be the opposite.

       RESULTS OF THE NON-USE VALUE
       STUDY COULD BE SIGNIFICANT IN
       THE DECISION-MAKING PROCESS
    -------------------------------------------------------- Appendix VI:4

    Non-use values represent the highest estimated economic impact from
    changing the Glen Canyon Dam's operations.  Non-use values were based
    on estimates of the public's willingness to pay for downstream
    environmental improvement that would likely result from changes in
    the dam's operations.  Willingness-to-pay estimates for the national
    sample ranged from less than $15 per household annually to about $20
    per household annually.  Because there are close to 100 million
    households in the United States, an average household's willingness
    to pay estimated to be $15 per year yields an aggregate non-use value
    of $1.5 billion annually, which is very large when compared to the
    estimated annual power costs.

    Although the final EIS discusses non-use values and notes that they
    are positive and significant, the actual quantified results are not
    included in the final EIS.  Reclamation did not include the non-use
    value study results in the final EIS because they were not available
    when the final EIS was published.  Nonetheless, the non-use value
    study will be among the materials provided to the Secretary and, as a
    result, could be used in the final decision-making.  In fact, the
    National Research Council in its 1996 report stated that the non-use
    value study results "deserve full attention as decisions are made
    regarding dam operations."\30

    Because the actual quantified results of the non-use value study were
    not in the draft or final EIS, they were not available to the general
    public to offer comments similar to other EIS results.  While
    acknowledging the lack of formal public comment, Reclamation
    officials point out that the non-use value study was subjected to
    extensive peer review at key decision points in the process and that
    the final non-use value study received a positive review by the
    National Research Council.  Reclamation also states that interests
    likely to be affected by the changes in the Glen Canyon Dam, such as
    power groups or environmental groups, were involved in the non-use
    value study process.

    --------------------
    \30 River Resource Management in the Grand Canyon, Committee to
    Review the Glen Canyon Environmental Studies, National Research
    Council, Washington, D.C.  National Academy Press, 1996, p.  135.

       SCOPE AND METHODOLOGY
    -------------------------------------------------------- Appendix VI:5

    To gain an understanding of Reclamation's non-use value study
    methodology and results, we reviewed the final report GCES Non-Use
    Value Study, September 8, 1995.  We also reviewed the economics
    literature on non-use values and the contingent valuation method for
    estimating them.  We interviewed the principal author of the report,
    a Senior Associate at Hagler Bailly Consulting.  We examined reports
    prepared by peer reviewers and we also discussed the study with some
    members of the non-use value committee.

    The following is a list of individuals we contacted.

    David Harpman, Natural Resource Economist, Bureau of Reclamation
    Michael P.  Welsh, Hagler Bailly Consulting
    Bruce Brown, ECOPLAN Consultants

    RECREATION
    ========================================================= Appendix VII

    The purpose of this appendix is to review (1) the methodology and key
    assumptions that the Bureau of Reclamation used to estimate the
    economic impact on recreation of alternative water releases at Glen
    Canyon Dam and (2) the reasonableness of the estimated impacts.  The
    section of the Colorado River below the dam is used by a variety of
    recreationists, including anglers, boaters, day-rafters, campers, and
    hikers.  We found that the methodology that Reclamation used to
    estimate the economic impact of alternative flows on recreational
    activities is generally reasonable.  For example, recreationists were
    surveyed to assess the impact of changes in the dam's operations on
    recreation activities.  In addition, modeling was used to estimate
    the economic benefits accruing to the national economy from
    recreational activities under the different flow regimes.

    Reclamation has estimated that the economic impact on recreational
    activities of changing the operations at the dam could range from $0
    under the Maximum Powerplant Capacity and High Fluctuating Flow
    alternatives to benefits of $4.8 million under the Seasonally
    Adjusted Steady Flow alternative (in 1991 nominal dollars, relative
    to a No-Action alternative).  However, we found several limitations
    in Reclamation's recreation analysis that suggest that the estimated
    economic benefits could be over- or understated.  For example,
    because the initial recreation study was completed in 1985 and some
    recreation conditions have changed since then, some of the study's
    data may not reflect more recent trends in recreational activities
    below the dam.  Also, recreationists were surveyed during an
    unusually high water year, limiting the ability of the researchers to
    capture representative recreational experiences, and some of the
    survey instruments were not adequately pretested to minimize bias and
    confusion on the part of survey participants.  In addition, anglers
    who fish within the Grand Canyon were not included in the survey.
    Because of the inherent uncertainty associated with future events,
    the actual economic impacts on recreation may differ from those
    estimated.  Nonetheless, despite these limitations, we believe that
    the estimated impacts can be useful for generally assessing the
    impacts that may be associated with moving from a No-Action
    alternative to a fluctuating or steady flow alternative.  Moreover,
    Reclamation and National Park Service officials told us that they
    were generally aware of the limitations in the recreation analysis
    but believe that revising the study would not change the basic
    conclusions of the EIS, the preferred alternative, or the ranking of
    alternatives.  Furthermore, a reviewer of the recreation study for
    the National Research Council told us that the recreation analysis
    reflected current professional practices and was well done.

       INTRODUCTION
    ------------------------------------------------------- Appendix VII:1

    Recreation is an important use of the Colorado River below the Glen
    Canyon Dam.  The 15-mile segment of the river below the dam--located
    within the Glen Canyon National Recreational Area--is the last
    remaining riverine section of the 189-mile, river-carved channel that
    once was Glen Canyon.  A variety of recreationists use this portion
    of the river, including anglers, boaters, day-rafters, campers, and
    hikers.  Downstream from Glen Canyon, the Colorado River runs through
    Marble Canyon and Grand Canyon.  This segment of the river is the
    longest stretch of river (278 miles) for recreational use that is
    entirely located within a national park.  A large number of rapids,
    as well as the river's isolation within the Grand Canyon, enhance
    recreational activities along this portion of the river.  After
    passing through the Grand Canyon, the Colorado River is impounded by
    the Hoover Dam and forms the largest reservoir in the Western United
    States--Lake Mead.  According to Reclamation, about 100,000 boaters
    annually use this stretch of the Colorado River and Lake Mead for
    scenic boating, camping, fishing, and water-skiing.

       EFFECTS OF PRE- AND POSTDAM
       CONDITIONS ON RECREATION
    ------------------------------------------------------- Appendix VII:2

    The Glen Canyon trout fishery has flourished since the construction
    of the dam.  Water flows from the dam are colder, carry less silt,
    and are more stable on an annual basis than before the dam was
    constructed.  According to the Department of the Interior, following
    the completion of the Glen Canyon Dam, the first 15 miles of flat
    water between the dam and Lees Ferry, once stocked with trout, became
    an excellent coldwater fishery.  This section of the river is also
    used for half-day commercial raft trips, which, depending upon the
    flow level, depart either from a dock near the Glen Canyon Dam and
    float down to Lees Ferry or from Lees Ferry and motor part way
    upstream before floating back downstream.\1

    Before the early 1960s, and before the dam was completed, few
    visitors entered the canyon or ran the river.  However, Reclamation's
    EIS indicates that white-water boating in the Grand Canyon is a major
    industry today, with 15,000 to 20,000 commercial and private boaters
    annually, paralleling an increasing trend nationwide in white-water
    boating.  In order to help minimize impacts by recreationists, the
    National Park Service established a ceiling on the number of user
    days allowed each year along with stricter river-use regulations.
    Before the dam, riverflows were highly variable and ranged from low
    flows (frequently less than 3,000 cubic feet per second) to peak
    flows (occasionally in excess of 100,000 cfs) in spring and early
    summer.  Now, riverflows are within a much narrower range--generally
    from 3,000 cfs to 31,500 cfs (20,000 cfs under the interim operating
    criteria)--and show less seasonal variation, reducing the high- and
    low-water risks associated with recreating on the river.

    Before the construction of the Glen Canyon Dam, spring runoff carried
    sediment down the Colorado River to Lake Mead.  After construction of
    the dam, sediment from side canyons and beaches continued to be
    transported down the river, but in smaller quantities.  Over the
    years, these sediment deposits have built up to form broad mud flats
    at the upper end of Lake Mead.  When the water level in Lake Mead
    falls below 1,180 feet, boat navigation is difficult because the
    river is too shallow at low flows and the channel changes with water
    fluctuations.

    --------------------
    \1 High discharges associated with flood flows preclude rafting trips
    from departing near the dam.  The probability that such flows will
    occur is diminished by several features of the action alternatives
    described in Reclamation's EIS.

       ISSUE
    ------------------------------------------------------- Appendix VII:3

    The major issue addressed by Reclamation in its EIS analysis of
    recreation was how do dam operations affect recreation in the study
    area?  Specifically, Reclamation's assessment focused on how changes
    in the dam's operations would affect angling, day-rafting, and
    white-water boating along the Colorado River in the Glen and Grand
    canyons, as well as the recreationists using lakes Powell and Mead.

       INDICATORS
    ------------------------------------------------------- Appendix VII:4

    Reclamation evaluated the impact of alternative flow regimes on a
    series of indicator activities.  The indicators are:

      -- Fishing trip attributes, safety, and access.

      -- Day-rafting trip attributes and access.

      -- White-water boating trip attributes, camping beaches, safety,
         and wilderness values.

      -- Lake activities and facilities.

      -- Net economic value of recreation.

       EFFECTS OF FLOW ALTERNATIVES ON
       RECREATION
    ------------------------------------------------------- Appendix VII:5

    According to Reclamation's EIS, fishing in the Glen Canyon occurs
    mostly from boats, but some anglers wade in the area around Lees
    Ferry.  The magnitude and rate of change in the river's stage
    increases the danger for anglers wading in the Glen Canyon reach.
    Therefore, fishing safety would improve under the Moderate, Modified
    Low and the Interim Low Fluctuating Flow alternatives, because
    fluctuations are reduced and the rate at which the river's stage
    rises is constrained.  Upstream fishing access by boat under the
    Maximum Powerplant Capacity alternative is the same as under the
    No-Action alternative.  Increased minimum flows under the High
    Fluctuating Flow alternative would result in a negligible increase in
    the ease of upstream access by anglers.  Because damage to boats and
    motors is more likely during the low-flow periods that typically
    occur in the morning before peak power generation occurs, increased
    minimums and changes in the magnitude of upramp and downramp rates
    (that is, changes in cfs per hour) would greatly improve upstream
    access under all other alternatives.

    Reclamation's EIS states that the flood control measures included in
    the restricted fluctuating and steady flow alternatives would reduce
    the probability of flood events and the corresponding need to launch
    from Lees Ferry, thus improving the quality of the day-rafting
    experience in Glen Canyon.  In addition, the risk of white-water
    boating accidents would be highest under the No-Action and Maximum
    Powerplant Capacity alternatives, slightly lower under the High
    Fluctuating Flow alternative, and lower under the remaining
    restricted fluctuating flow alternatives.  All steady flow
    alternatives would decrease the risk of white-water boating accidents
    over the No-Action alternative.

    According to the EIS, wilderness characteristics would improve as
    variations in riverflow are reduced.  To the extent that habitat
    maintenance and beach/habitat-building flows maintain beaches and
    reduce the rate of vegetative encroachment, the alternatives with
    these flows would further enhance wilderness values.

    In the short term, the greatest increase in available beach area
    would occur under the steady flow alternatives.  In the long term,
    low steady flows would remove all of the system's natural variation.
    The absence of natural system cycles is likely to encourage
    vegetative growth and result in a net loss of camping beach area.
    The available beach area would be slightly increased under the
    Moderate, Modified Low, and Interim Low Fluctuating Flow alternatives
    in the short term.  In the long term, habitat maintenance flows
    (included in the Moderate and Modified Low Fluctuating and Seasonally
    Adjusted Steady Flow alternatives) would help maintain the number of
    beaches and their camping areas.

    Because riverflows and the magnitude and frequency of fluctuations
    differ under each alternative, the net economic value of recreation
    would also differ.  The majority of recreational benefits are derived
    from commercial white-water rafting, which in general is positively
    related to average daily flows and negatively related to
    fluctuations.  Those alternatives that increase average summer flows
    or eliminate daily fluctuations in excess of 10,000 cfs tend to
    increase recreational benefits.

       RECLAMATION'S METHODOLOGY FOR
       MAKING IMPACT ASSESSMENTS
    ------------------------------------------------------- Appendix VII:6

    In assessing the effects on recreation of the different operating
    regimes for the Glen Canyon Dam, the final EIS gives numerical values
    where possible; otherwise, it gives qualitative assessments that are
    based on physical, biological, and economic research.  There are
    three distinct and independent components to the recreational
    material presented in the EIS.  The first is a quantitative
    assessment of the net economic value of river-based recreation
    associated with the different flow alternatives.  The second
    component is a qualitative assessment performed by resource managers
    using the results of scientific studies of the impact of flow
    alternatives on individual resources.  The third recreation component
    involves an analysis of the regional economic impacts of recreation.
    Regional economic impact refers to expenditures and their importance
    to the local economy in the study area.  The first two components are
    based on a study of visitors' preferences conducted by Bishop et al
    (1987).  This appendix will address only the specifics of the first
    component--the economic benefits associated with recreation.

       RECLAMATION'S RECREATION IMPACT
       METHODOLOGY IS GENERALLY
       REASONABLE
    ------------------------------------------------------- Appendix VII:7

    We found that the methodology that Reclamation used to estimate the
    economic impact of alternative flows on recreation activities is
    generally reasonable.  For example, to obtain information from river
    recreationists, the researchers used a two-stage research design.
    They conducted two sets of surveys to obtain information from
    white-water boaters, anglers, and day-rafters.  In addition, the
    researchers analyzed the survey data using a "logit" regression model
    to determine the amount of money that recreationists would be willing
    to pay to experience recreational activities under different flow
    regimes.  Also, they used a national economic perspective in the
    analysis to estimate the recreation benefits accruing to the national
    economy.

    To design and conduct the recreation study, Reclamation contracted
    with a private consulting firm, HBRS, Inc.  (now Hagler Bailly
    Consulting; hereinafter, the contractor or researchers).  The
    contractor completed an initial study in 1987 and an updated study in
    1993.\2 The updated study was used as the basis for the recreation
    benefits cited in the final EIS.

    --------------------
    \2 Glen Canyon Dam Releases and Downstream Recreation:  An Analysis
    of User Preferences and Economic Values, 1987; and Analysis of the
    Impact of GCDEIS Alternatives on Recreational Benefits Downstream
    From Glen Canyon, Madison, Wisconsin:  HBRS, Inc., 1993.

          A TWO-STAGE RESEARCH DESIGN
          WAS USED TO OBTAIN SURVEY
          DATA
    ----------------------------------------------------- Appendix VII:7.1

    The contractor used a two-stage research design to determine the
    potential impact of alternative flows at the Glen Canyon Dam on three
    groups of recreationists--white-water boaters, day-rafters, and
    anglers.  Because riverflows during the period the research was
    carried out were predominately high and steady, there was no way to
    ensure that a representative sample drawn from the three groups would
    include recreationists who had experienced the full range of flows
    being evaluated.  Therefore, the contractor asked the respondents to
    evaluate their actual trips as well as written descriptions
    (scenarios) of recreational experiences under a variety of flow
    levels that they may not have experienced.

    During the first stage, the contractor surveyed each recreational
    group to identify the important characteristics (or attributes) of
    the recreational experience on the Colorado River and what effect, if
    any, riverflows would have on these experiences.  The contractor also
    administered these attribute surveys to commercial white-water
    boating guides and private trip leaders to get a more informed view
    of how riverflows affect the experiences of boaters on the river.
    White-water boating participants in the attribute survey were
    selected from the National Park Service's records of trip launches
    for the 1982 and 1984 seasons.  For anglers, the contractor attempted
    to survey anglers at Lees Ferry during selected days in November and
    December 1984.  The researchers chose day-rafters from a
    concessionaire's list of individuals who took a Glen Canyon raft trip
    during the months of April through October 1985.

    The contractor applied what had been learned from the attribute
    surveys to the design of the scenarios for the contingent valuation
    survey.\3 A contingent valuation survey attempts to measure the
    willingness of a group of people to pay for hypothetical projects or
    programs.  The contractor used questionnaires to ask individuals
    about their dollar valuation of a series of specific hypothetical
    changes in Colorado River flows.  Because the valuation is contingent
    on the specific hypothetical change identified, these values are
    called "contingent values" and the method of obtaining data is termed
    the "contingent valuation method," or CVM.\4

    The scenarios described white-water trips and angling trips at
    various flow levels in terms of identified flow-sensitive
    attributes.\5 The scenarios also distinguished between constant and
    fluctuating flows.  A fluctuating flow primarily occurs when the dam
    is being operated for peak power production.  Fluctuations in excess
    of 10,000 cfs within a 24-hour period constituted a fluctuating flow
    for the recreation study's purposes.  The 10,000-cfs threshold was
    based on the results of the attribute surveys.

    In the second stage, the contractor used the scenarios as the basis
    of the contingent valuation survey.  Along with the actual trip
    experience and its total cost, the contractor used these hypothetical
    descriptions to quantify the effects of different flow regimes on the
    recreational experience.  Specifically, the contractor described the
    change in the recreational experience and asked those surveyed
    whether they would still take such a trip if their expenses were to
    increase by a certain randomly assigned dollar amount over their
    trip's actual cost.  The respondents were limited to "yes" and "no"
    answers.  The researchers also provided the respondents with
    riverflow information corresponding to the date of their actual trip
    in order to gain information about the trip and establish a context
    for the responses to the scenarios.  In addition to this information,
    the researchers asked the recreationists about the characteristics of
    their actual trip and reasons for taking the trip.  Also included
    were questions about the respondent's income level and indicators of
    how well the respondents understood the survey and thought the
    results would affect the cost of future recreation.

    A 1987 review by the National Research Council stated that the use of
    the contingent valuation technique to address the public's
    willingness to pay for angling and rafting opportunities through the
    Grand Canyon was "a bold application of this promising method.  The
    researchers, who are well known for their development of the
    technique, have ably and creatively analyzed the satisfaction of
    recent recreationists."\6

    --------------------
    \3 Another approach for measuring recreation impacts is the travel
    cost method.  This method uses travel and related costs that are
    incurred during a recreational activity to approximate the market
    price for a recreation trip.

    \4 In our review of the contingent valuation survey, we relied on
    Dillman's total design method as well as on economic reasoning in
    assessing the reasonableness of Reclamation's application of the CVM
    approach.  Dillman's method is an accepted standard in survey
    research for achieving the maximum quality and quantity of responses
    to mail questionnaires.  By achieving the maximum quality of
    responses, for example, researchers can have greater confidence in
    the validity of the work; that is, they can be more sure of measuring
    what they intend to measure.  By achieving the maximum quantity of
    responses, researchers can have greater confidence in the reliability
    of their work that repeated investigations will produce similar
    results.  A more detailed discussion of the CVM approach is presented
    in app.  VI of this report; the total design method is described in
    Dillman, Don A., Mail and Telephone Surveys:  The Total Design
    Method, John Wiley & Sons, New York, 1978.

    \5 Because the attribute survey found day-rafters insensitive to
    flows, no scenarios were presented to this sample group.

    \6 River and Dam Management:  A Review of the Bureau of Reclamation's
    Glen Canyon Environmental Studies, National Academy Press, Washington
    D.C., 1987, p.  63.

          ECONOMIC ESTIMATES DEVELOPED
          USING FEDERAL PRINCIPLES AND
          GUIDELINES
    ----------------------------------------------------- Appendix VII:7.2

    We found that the contractor followed federal principles and
    guidelines for water resources planning where applicable in
    developing estimates of the recreation benefits.  For example,
    federal principles and guidelines state that the federal objective of
    water and related land resources planning is to contribute to
    national economic development (consistent with protecting the
    environment).\7 In addition, the guidelines state that the benefits
    arising from recreational opportunities created by a project are
    measured in terms of willingness to pay.  The contractor defined
    recreational benefits in terms of consumers' willingness to pay and
    calculated the net economic benefit, or "surplus value," associated
    with the recreational experiences under different flow conditions.
    Surplus value is the value that the recreationists placed on their
    recreational experience over and above what they actually paid for
    the recreational experience.  Expenditures, such as the price of a
    Grand Canyon white-water boat trip, were excluded from the net
    economic benefit calculations because the expenditures represent a
    transfer payment to the local economy.  Transfer payments simply
    redistribute income from one group in society to another, and
    therefore they do not reflect an economic benefit to the national
    economy.

    Nonetheless, expenditures are important because they support local
    businesses and provide employment for local residents.  For this
    reason, recreational expenditures were the focus of a separate
    analysis of regional economic activity that Reclamation performed.

    --------------------
    \7 Economic and Environmental Principles and Guidelines for Water and
    Related Land Resources Implementation Studies, U.S.  Water Resources
    Council, Mar.  10, 1983.

          ECONOMIC BENEFITS WERE
          ESTIMATED USING ECONOMETRIC
          MODEL
    ----------------------------------------------------- Appendix VII:7.3

    The contractor used a now standard econometric approach to evaluate
    the contingent valuation response data.  For example, surplus values
    were estimated using a "logit" model, that was based on the "yes" and
    "no" answers to the survey's valuation question.  Using the logit
    model, the contractor estimated the probability that a respondent
    would be willing to pay a specific dollar amount (termed "offer
    amount") above his/her actual trip cost to recreate under the various
    flow regimes.  This probability was assumed to be a function of
    several independent variables, including the offer amount, the amount
    the recreationist spent to take an actual trip, and the number of
    days spent on the river.

    To update the estimated values obtained during the 1985 survey, the
    contractor used the 1985 model with the hydrologic conditions for
    1991 to generate surplus values for various alternatives by month and
    by recreational activity.  The contractor then multiplied the surplus
    values by the observed 1991 monthly participation rates for each
    activity.  The resulting estimates were then inflated to 1991
    dollars.  In addition, because the initial recreation study was
    completed before Reclamation developed the alternative flow regimes
    in the EIS, the contractor extrapolated from the flow regimes used in
    the contingent valuation survey to the EIS flow regimes using a
    combination of historical data on the dam's operations and
    projections of future hydrologic conditions over a 20-year planning
    period.  The 20th year was repeated for 30 years to complete the
    50-year analysis period.  The Colorado River Simulation System model
    was used to develop the future hydrologic projections, which were
    identical to those used in the power analysis.

    To determine the present value of future recreation benefits over the
    50-year analysis period, the contractor discounted future annual
    benefits using the federal discount rate of 8.5 percent.\8

    The present value was "levelized" over the 50-year analysis period to
    determine equivalent annual benefits.  Table VII.1 shows the
    estimated net economic benefits for recreation associated with the
    nine alternatives discussed in the final EIS.  The table reflects the
    net benefits associated with white-water boating and angling
    activities.  The number of white-water boating and angler trips were
    held constant at 1991 levels over the 50-year analysis period.  The
    researchers found that day-rafters are not sensitive to river stage
    and fluctuations; thus, the economic impact of changes in the dam's
    operations on day-rafters was estimated to be zero.

                                  Table VII.1

                       Economic Benefits Associated With
                     Recreation Activities, Relative to the
                      No-Action Alternative (1991 Nominal
                              Dollars in Millions)

                                             Present value
                                                    of net
                                             benefits over
                                                   50-year      Equivalent
                                                  analysis      annual net
    EIS alternatives                                period        benefits
    --------------------------------------  --------------  --------------
    No Action                                           $0              $0
    Maximum Powerplant Capacity                         $0              $0
    High Fluctuating Flow                               $0              $0
    Moderate Fluctuating Flow                         $4.6            $0.4
    Modified Low Fluctuating Flow                    $43.3            $3.7
    Interim Low Fluctuating Flow                     $45.6            $3.9
    Existing Monthly Volume Steady Flow              $45.6            $3.9
    Seasonally Adjusted Steady Flow                  $55.0            $4.8
    Year-Round Steady Flow                           $23.5            $2.9
    ----------------------------------------------------------------------
    Source:  Bureau of Reclamation.

    --------------------
    \8 The net recreation benefits in each year in the analysis period
    were inflated by the projected gross national product price deflator
    for that year.  The same deflator and discount rate were also used in
    the hydropower analysis.

       SHORTCOMINGS IN RECREATION
       ANALYSIS SUGGEST ECONOMIC
       IMPACTS COULD BE OVER- OR
       UNDERSTATED
    ------------------------------------------------------- Appendix VII:8

    Although the recreation methodology is generally reasonable, we found
    limitations in the analysis.  For example, because the initial
    recreation study was completed in 1985 and some recreational
    conditions have changed since then, some of the study's data may not
    reflect more recent trends in the recreational activities below the
    dam.  Also, the researchers gathered the survey data during an
    unusually high-water year, limiting the ability to capture
    representative recreational experiences, and they did not adequately
    pretest some of the survey instruments to minimize bias and confusion
    on the part of the participants.  In addition, the contractor did not
    include Grand Canyon anglers in the survey.  Finally, some of the
    econometric results are inconsistent with expectations based on
    conventional economic reasoning.  These limitations indicate that the
    estimated recreation benefits could be over- or understated.  Because
    of the time and expense that would be required to recompute the
    results with revised methodology and data, we did not determine the
    net effect of the limitations on the estimated economic impacts.

          RECREATION CONDITIONS MAY
          HAVE CHANGED SINCE THE
          SURVEY
    ----------------------------------------------------- Appendix VII:8.1

    We found that some of the data used to develop the economic benefits
    may be dated because of changes in the recreation environment since
    recreationists were surveyed in 1985.  The contractor used 1985
    surplus values and number of trips taken in 1991 to derive recreation
    benefits for alternative flows.  However, because the estimated
    benefits were derived using 1985 surplus values, they may not account
    for more recent changes in recreational activities that could affect
    value.\9

    The years 1985 and 1991 combined for use in the model were different
    in terms of the number of recreational trips taken, especially for
    anglers.  For example, according to study statistics, the actual
    number of fishing trips at Lees Ferry more than doubled between 1985
    and 1991, from 6,064 to 12,902.  In addition, the fishing regulations
    changed during this period, strictly limiting anglers to artificial
    lures and imposing new restrictions on the size and number of fish
    caught.  Because of the substantial change in the number of fishing
    trips taken and a change in fishing regulations, it may not be
    reasonable to assume that the value per fishing trip, relative to
    other goods and services, would have remained unchanged between 1985
    and 1991.

    --------------------
    \9 Surplus values were adjusted for inflation between 1985 and 1991.

          SURVEY DATA BASED ON A YEAR
          WITH UNUSUALLY HIGH WATER
    ----------------------------------------------------- Appendix VII:8.2

    The researchers were not able to capture representative recreational
    experiences because of the river conditions present during the
    recreation study.  The sample year--1985--used to develop the
    statistical relationship between flow rates and surplus values was an
    atypical year for the Colorado River, characterized by relatively
    high, constant flows and poor fishing.  To address this data issue,
    the contractor used hypothetical scenarios (developed using the
    attribute survey information) to determine the effect of different
    flow regimes on recreational experiences.  However, two potential
    problems with the use of the high-water year and scenario data are
    (1) the estimated surplus values depend heavily on the ability of the
    respondents to meaningfully interpret the scenarios using their
    high-water experience and (2) the surplus values generated from
    scenario data may differ from those based on actual experiences.

    Ideally, the respondents should be asked about their willingness to
    pay for alternative flow regimes that they have actually experienced.
    At the time of the recreation survey in 1985, however, there had been
    already 2 consecutive years of high-water flows.  In addition,
    according to Reclamation, it was not feasible to adjust the Glen
    Canyon Dam's operations to create alternative flow conditions for the
    recreation study.  Therefore, the contractor constructed hypothetical
    scenarios to simulate recreational experiences under different flow
    conditions.  The contractor then asked the recreationists to compare
    their actual trip experiences with the hypothetical trip experiences.

    However, because 1985 and the preceding years were unusually
    high-water years characterized by constant flows, some recreationists
    may not have experienced a variety of flow conditions.  For example,
    the researchers could not make inferences about the influence of
    fluctuating flows on white-water boaters using information from
    actual trips because only 12 percent of the respondents experienced
    these fluctuations.  Similarly, because there was little variation in
    the actual trip experiences for anglers, the researchers were unable
    to make a direct link between the actual trip's surplus value and the
    flow levels experienced by the respondent.  This condition is
    attributable to all anglers having experienced such small variation
    in flow conditions that substantially all of the respondents compared
    the scenarios with essentially the same limited actual flow
    experiences.  Consequently, there was no way to determine whether
    recreationists who experienced other types of flows would have valued
    the scenarios differently.  For example, a recreationist who had
    experienced low, fluctuating flows might value a medium flow more
    than a recreationist who experienced only a high constant flow.

          SOME QUESTIONNAIRES WERE NOT
          ADEQUATELY PRETESTED
    ----------------------------------------------------- Appendix VII:8.3

    Although the researchers used Dillman's total design method for the
    implementation of the surveys and tested proposed questions to
    determine which wording options offered the highest response rates,
    they did not adequately pretest some survey instruments to detect
    defects in wording, construction, presentation, or other
    inadequacies.  As a result, we cannot be completely confident that
    the surveys actually measured what they were intending to measure.

    Reclamation's contractor used mail questionnaires to gather data on
    recreational attributes and contingent values.  We found that the
    contractor generally followed Dillman's total design method in the
    design and implementation of these questionnaires.  For example, the
    contractor met Dillman's standards for questionnaire design and
    mailing procedures, which helped to obtain response rates between 70
    and 93 percent.  These response rates allow the researchers to have
    greater confidence that they do not have a biased picture of the
    sample caused by differences between the respondents and
    nonrespondents.

    However, we also found that the contractor did not follow Dillman's
    pretesting standards.  For example, the attribute survey for anglers
    and the questionnaire used for white-water guides were pretested in
    person, while other questionnaires were pretested through the mail.
    According to Dillman, mail pretesting is "destined to be of very
    limited value." Only by having respondents fill out the draft in the
    presence of the researchers can they discover such information as:
    Is each question measuring what it is intended to measure?  Are all
    the words understood?  Are the questions interpreted similarly by all
    respondents?  Is any part of the questionnaire biased?  Because such
    pretesting was not done, neither we nor the contractor can be
    confident about the validity of the questions or the instruments as a
    whole.

    An example of problems that may have resulted from inadequate
    pretesting can be seen in the interpretation of the water levels
    experienced by anglers.  In the in-person interviews performed for
    the angler attribute questionnaire, the researchers found problems
    with the responses to questions that dealt with water levels
    experienced by the anglers.  The authors of the recreation study
    noted that for the 2 years before the attribute survey, steady high
    water was the rule.  However, some respondents who had fished at Lees
    Ferry only during 1984 and 1985 answered that they had experienced
    low, medium, or fluctuating flows.  The authors conclude that some
    anglers may have answered the water-level experience question
    incorrectly.  These responses are evidence of possible problems in
    the validity of the measures used.  We do not know the extent of
    misunderstanding between the respondents and the contractor, but this
    example suggests that there was some.  Adequate pretesting may have
    detected and corrected this misunderstanding.

          GRAND CANYON ANGLERS WERE
          EXCLUDED FROM SURVEY
    ----------------------------------------------------- Appendix VII:8.4

    The contractor assumed that fishing in locations other than Lees
    Ferry was an incidental activity and therefore did not include these
    anglers in the survey.  As a result, the data for anglers are based
    solely on the recreational experiences of anglers at Lees Ferry.  To
    the extent that other anglers who fish downstream in the Colorado
    River or its tributaries have surplus values that are different from
    the Lees Ferry anglers (but also positive), the estimated benefits
    may understate the total benefits to anglers resulting from
    alternative flow regimes.

    The researchers defined the angling population to include those who
    access the river from Lees Ferry in Glen Canyon, which had the effect
    of excluding anglers in the Grand Canyon.  According to the
    researchers and recreation subteam members, the Grand Canyon anglers
    were not included in the study for a variety of reasons.  For
    example, they were thought to represent only a small percentage of
    fishing activity; they might be difficult to sample; and fishing
    itself was not considered to be the focus of a Grand Canyon
    recreational experience.  Although little information exists on the
    extent of angling in the Grand Canyon or the characteristics of these
    anglers, the EIS makes reference to 15 sites in the Grand Canyon that
    are managed for anglers who want to catch "fish that are naturally
    reproduced in the wild." In addition, the National Park Service and
    Arizona Game and Fish Department officials we contacted indicated
    that some anglers fish in the vicinity of Marble Canyon to avoid the
    restrictions on natural bait enforced at Lees Ferry, and other
    anglers hike down into Phantom Ranch to fish in Bright Angel Creek.
    The difficulty or expense of reaching or staying at a location other
    than Lees Ferry, a preference for "wild" rather than hatchery fish,
    and reasons for going to the river other than fishing could mean that
    these groups of anglers have different opinions of the values of
    flows than those who were sampled.

          SURVEY DATA DO NOT PRECISELY
          CORRESPOND TO EIS FLOW
          ALTERNATIVES
    ----------------------------------------------------- Appendix VII:8.5

    Because the researchers designed and conducted the recreation
    contingent valuation survey well before the EIS operating regimes
    were proposed for the Glen Canyon Dam, the flow regimes used in the
    survey scenarios do not precisely correspond to the flow alternatives
    identified in the final EIS.  As a result, there is some uncertainty
    as to whether the survey data reflect the same environmental changes
    proposed in the EIS alternatives.

    An unusual aspect of the recreational modeling effort is that it is
    composed of two separate segments of work, several years apart,
    occurring within the framework of the Glen Canyon Environmental
    Studies.  Reclamation's contractor began the initial study of
    recreational values in 1984, and the results were published in 1987.
    The 1987 study, however, predated the development of the preferred
    alternative.

    In order to allocate the estimated recreation benefits to the
    alternative flow regimes in the EIS, the contractor converted the EIS
    alternatives into the same terms as those used in the original
    survey.  This was done by translating the EIS alternatives into
    average flow terms and identifying fluctuations in flow using a
    mixture of theoretical data and data from the dam's actual
    operations.  However, the recreation survey was based on broad
    groupings of flows, while the EIS flow alternatives are much more
    detailed in their characteristics.  As a result of this sequencing,
    it is not clear that the aggregate recreational values captured in
    the 1987 study reflect the same environmental changes proposed in the
    EIS alternatives.  The recreation analysis may not have captured the
    nuances that distinguish the individual EIS flow alternatives.  For
    example, the scenarios used in the 1987 study used average flow
    figures (such as 13,000 cfs) to ask individuals about their dollar
    valuation of a hypothetical change in riverflows, while the EIS
    describes complex alternatives stated both in terms of minimum and
    maximum flows (for example, 1,000 cfs to 31,500 cfs) as well as the
    rate of change in flows per hour (that is, ramping up or down).
    Although ramping can affect the recreational experience, by using
    these averages, the recreation analysis was not able to assess the
    impact of ramping on recreational activities.  For example, rapid
    changes in the upramp rate of the dam's operations can put wading
    anglers at risk of inundation, as well as affect the "naturalness" of
    a wilderness boating experience.  Similarly, rapid changes in the
    downramp rate of the dam's operations can strand anglers in boats, as
    well as fish in backwaters.

    A Reclamation official and the contract researchers acknowledge that
    there is no systematic linkage between the scenarios used in the
    contingent valuation surveys and the flow regimes in the final EIS.
    A Reclamation official told us that translating the EIS alternatives
    into the same terms used in the 1985 scenarios involved a great
    simplification.  For example, the scenarios were based on a
    dichotomous approach:  a single mean monthly flow rate and the
    presence or absence of fluctuations.  If the flow levels varied by
    more than 10,000 cfs, they were considered fluctuating.  If the flow
    levels varied by less than or were equal to 10,000 cfs, they were
    considered steady.  By contrast, the EIS alternatives involve complex
    variables, including flow ranges and rates that change hourly.  As a
    result of this simplification, the recreation model cannot
    distinguish between several alternatives.  That is, the model
    predicted the same economic benefits for the No-Action, Maximum
    Powerplant Capacity, and High Fluctuating Flows, as well as for the
    Interim Low Fluctuating Flow and the Existing Monthly Volume Steady
    Flow.

          SOME ECONOMETRIC RESULTS ARE
          INCONSISTENT WITH
          CONVENTIONAL ECONOMIC
          REASONING
    ----------------------------------------------------- Appendix VII:8.6

    Some of the econometric results indicate a positive and significant
    relationship between surplus value and the expenditure variable,
    which is inconsistent with conventional economic reasoning.  For
    example, in the analysis of white-water boaters' and anglers'
    responses, the contractor found that the respondents' surplus values
    increased with the amounts they spent to take their actual trips.
    This result is inconsistent with conventional economic reasoning
    because we would expect that the more an individual spends on a trip,
    the lower would be his or her surplus value, all else being the same.
    Because this result may be symptomatic of a technical problem, such
    as a misspecification of the model, a measurement error, or an
    insufficient sample size, it suggests that the results lack
    precision.\10

    Some members of the contract research team acknowledged this
    inconsistency between the results of the model and conventional
    economic reasoning.  One of the contractor's researchers told us that
    the positive relationship between surplus value and expenditure may
    be attributable to an omitted price variable.  In his opinion,
    however, this omission does not affect the validity of the results
    incorporated into the EIS.

    --------------------
    \10 Researchers were unable to calculate a standard error because the
    appropriate statistical techniques were not available at the time of
    the study.  However, a Reclamation official told us that the
    estimates are subject to an error of about plus or minus 20 percent.

       THE EIS TEAM USED ESTIMATED
       RECREATION BENEFITS ONLY TO AID
       DECISION-MAKING
    ------------------------------------------------------- Appendix VII:9

    Reclamation and National Park Service officials involved in the EIS
    process told us they were generally aware of the limitations of the
    recreation analysis but believe that addressing the limitations would
    not change the basic conclusions of the EIS, the choice of the
    preferred alternative, or the ranking of alternatives.  No such
    changes would occur because the study results were used more as an
    adjunct in developing a preferred alternative, rather than a focal
    point.

    A Reclamation official involved in the selection of the preferred
    alternative told us that the first criterion applied to the nine
    proposed alternatives was how the sediment balance in the canyon
    would be affected.  Alternatives that negatively affected the amount
    and location of sediment were eliminated, leaving only three
    alternatives, none of which posed a safety threat to recreationists
    except at very low flows.  Since two of the three remaining
    alternatives were identical except for a habitat maintenance flow,
    the EIS team had to choose between only two alternatives.  In
    choosing between these two alternatives, the EIS team weighed the
    power costs associated with each, the recreational benefits, and
    unquantified ecological concerns, such as benefits to the aquatic
    food base.  According to this official, the EIS team selected the
    Modified Low Fluctuating Flow as the preferred alternative because
    the loss of power revenues was roughly offset by the gains to the
    other resources.

    National Park Service and Reclamation officials told us that
    Reclamation considered revising the recreation economic study after
    the EIS alternatives were developed to get better data on how
    respondents valued a wide variety of actual flow conditions and on
    anglers' participation in the Lees Ferry fishery.  In particular, a
    researcher raised the prospect of further investigating anglers'
    values to overcome the limitations of the original study.  However,
    Reclamation decided not to spend additional resources on revising the
    recreational analysis in order to further study areas that were
    deemed more critical.  A National Park Service representative told us
    that because most of the unanswered questions were in the areas of
    sediment, vegetation, and endangered fish, funds were directed to
    these "higher-priority data gaps."

       RECREATION RESULTS CAN BE
       USEFUL DESPITE LIMITATIONS
    ------------------------------------------------------ Appendix VII:10

    Because there is inherent uncertainty associated with projecting
    future impacts, the actual economic impacts on recreation may differ
    from those estimated.  The limitations we have identified suggest
    that the estimated impacts could be over- or understated.
    Nonetheless, despite these limitations, we believe that the estimated
    impacts can be useful for generally assessing the impacts that may be
    associated with moving from a No-Action alternative to a restricted
    fluctuating or steady flow alternative.  Moreover, a reviewer of the
    recreation study for the National Research Council indicated to us
    that the recreation modeling was conducted using current professional
    practices and was a state-of-the-art effort given the budget and time
    constraints.  In addition, this reviewer indicated that the work on
    the economics of recreational use was well done and a good use of
    taxpayer money given the many other demands on the Glen Canyon
    Environmental Studies budget.

       RECLAMATION'S AND THE NATIONAL
       PARK SERVICE'S RESPONSE TO THE
       RECREATION ISSUES RAISED
    ------------------------------------------------------ Appendix VII:11

    We discussed our findings with a National Park Service and a
    Reclamation official who, as EIS team members, were responsible for
    incorporating recreation and the economics of recreational use into
    the EIS.  These officials, a resource management specialist with the
    National Park Service and an economist with the Bureau of
    Reclamation, generally agreed with our statements concerning the
    strengths and weaknesses of the recreation analysis.  Reclamation's
    economist acknowledged that recreational conditions may have changed
    since the study's survey was implemented in 1985.  Both officials
    said that the methodology was reasonable and appropriate and the data
    were the best available at the time of the study.  For these reasons,
    they told us that neither the ranking of alternatives nor the choice
    of a preferred alternative would change, even if the issues we
    identified as shortcomings were resolved.

       SCOPE AND METHODOLOGY
    ------------------------------------------------------ Appendix VII:12

    To gain an understanding of general recreational issues we reviewed
    studies on recreation use in the Glen and Grand canyons.  To assess
    the reasonableness of the recreation methodology, assumptions, and
    results, we reviewed the documents that describe Reclamation's
    methodology, assumptions and data, and literature on the contingent
    valuation method, and we used standard economic principles.  Our
    assessment was limited to a review of the general analytical
    framework and an assessment of the reasonableness of key assumptions
    and data.  We did not validate data inputs.

    The documents we reviewed include the following:

    Analysis of the Impact of GCDEIS Alternatives on Recreational
    Benefits Downstream From Glen Canyon (draft report).  Madison,
    Wisconsin:  HBRS, Inc., 1993.

    Bishop, R., C.  Brown, M.  Welsh, and K.J.  Boyle.  "Grand Canyon
    Recreation and Glen Canyon Dam Operations:  An Economic Evaluation,
    W-133," Benefits and Costs in Natural Resource Planning:  Interim
    Report 2.  Edited by Kevin J.  Boyle and Trish Heekin.  Orono, Maine:
    Department of Agricultural and Resource Economics, University of
    Maine, 1989.

    Bishop, R., K.  Boyle, M.  Welsh, R.  Baumgartner, and P.  Rathbun.
    Glen Canyon Dam Releases and Downstream Recreation.  Glen Canyon
    Environmental Studies Technical Report.  Salt Lake City, Utah:
    Bureau of Reclamation, 1987.

    Boyle, K., M.  Welsh, and R.  Bishop.  "The Role of Question Order
    and Respondent Experience in Contingent-Valuation Studies," Journal
    of Environmental Economics and Management, pp.  80-99, 1993.

    Boyle, K., M.  Welsh, R.  Bishop, and R.  Baumgartner.  "Analyzing
    the Effects of Glen Canyon Dam Releases on Colorado River Recreation
    Using Scenarios of Unexperienced Flow Conditions, W-133," Benefits
    and Costs in Natural Resource Planning:  Interim Report.  Compiled by
    John B.  Loomis.  Davis, California:  Department of Agricultural and
    Resource Economics, University of California, 1988.

    Chestnut, L., R.  Raucher, and R.  Rowe.  A Review of the Economic
    Studies Conducted in Phase I of the Glen Canyon Environmental
    Studies.  Report to Mr.  Dave Wegner, Bureau of Reclamation - Upper
    Colorado Region, Flagstaff, Arizona.  Economic Studies for the Glen
    Canyon Environmental Studies, Phase II.  RCG/Hagler, Bailly, Inc.,
    1991.

    Cummings, R.G., D.S.  Brookshire, and W.D.  Schulze.  Valuing
    Environmental Goods:  An Assessment of the Contingent Valuation
    Method.  Rowman & Littlefield Publishers, 1986.

    Diamond, P.A., J.  Hausman.  "Contingent Valuation:  Is Some Number
    Better than No Number?" Journal of Economic Perspectives, Vol.  8,
    No.  4, pp.  45-64, 1994.

    Economic and Environmental Principles and Guidelines for Water and
    Related Land Resources Implementation Studies, U.S.  Water Resources
    Council, Mar.  10, 1983.

    Final Report:  Hualapai Recreation Studies.  SWCA, Inc.
    Environmental Consultants.  Feb.  1995.

    Final 1993 Annual Report:  Hualapai Recreation Studies.  SWCA, Inc.,
    Jan.  1994.

    Glen Canyon Environmental Studies Final Report.  Salt Lake City,
    Utah:  Bureau of Reclamation, U.S.  Department of the Interior, 1988.

    Hanemann, W.  M.  "Valuing the Environment Through Contingent
    Valuation," Journal of Economic Perspectives, Vol.  8, No.  4, pp.
    19-43, 1994.

    HBRS, Inc.  Glen Canyon Dam Releases and Downstream Recreation:  An
    Analysis of User Preferences and Economic Values, 1987.

    Jalbert, L.  The Influence of Discharge on Recreational Values
    Including Crowding and Congestion and Safety in Grand Canyon National
    Park.  Grand Canyon National Park Division of Resources Management,
    1992.

    Jalbert, L.  Monitoring Visitor Distribution and Use Patterns Along
    the Colorado River Corridor:  River Contact Survey and Attraction
    Site Monitoring (status report).  Grand Canyon National Park Division
    of Resources Management and Planning, 1991.

    Kearsley, L.  Monitoring the Effects of Glen Canyon Dam Interim Flows
    on Campsite Size Along the Colorado River in Grand Canyon National
    Park (final report).  Grand Canyon National Park Division of
    Resources Management, National Park Service, 1995.

    Kearsley, L., J.  Schmidt, and K.  Warren.  "Effects of Glen Canyon
    Dam on Colorado River Sand Deposits Used as Campsites in Grand Canyon
    National Park, USA," Regulated Rivers:  Research and Management, Vol.
    9, pp.  137-149, 1994.

    Kearsley, L., and K.  Warren.  River Campsites in Grand Canyon
    National Park:  Inventory and Effects of Discharge on Campsite Size
    and Availability (final report).  Grand Canyon National Park Division
    of Resource Management, National Park Service, 1993.

    Operation of Glen Canyon Dam Final Environmental Impact Statement.
    Bureau of Reclamation, U.S.  Department of the Interior, 1995.

    Operation of Glen Canyon Dam Draft Environmental Impact Statement:
    Public Comments Analysis Report.  Prepared by the Bear West
    Consulting Team for the Bureau of Reclamation, 1994.

    Portney, P.R.  "The Contingent Valuation Debate:  Why Economists
    Should Care," Journal of Economic Perspectives, Vol.  8, No.  4, pp.
    3-17, 1994.

    Reger, S., K.  Tinning, and L.  Piest.  Colorado River Lee's Ferry
    Fish Management Report, 1985-1988.  Phoenix, Arizona:  Arizona Game
    and Fish Department, 1989.

    Richards, M., and D.B.  Wood.  "The Economic Value of Sportfishing at
    Lees Ferry, Arizona," Riparian Ecosystems and Their Management:
    Reconciling Conflicting Uses.  Proceedings of the First North
    American Riparian Conference.  Apr.  16-18, 1985.  Tucson, Arizona.
    U.S.D.A.  Forest Service General Technical Report RM 120.  Ft.
    Collins, Colorado:  Rocky Mountain Forest and Range Experiment
    Station.

    River Resource Management in the Grand Canyon, Committee to Review
    the Glen Canyon Environmental Studies, National Research Council,
    Washington, D.C.:  National Academy Press, 1996.

    River and Dam Management:  A Review of the Bureau of Reclamation's
    Glen Canyon Environmental Studies, Committee to Review the Glen
    Canyon Environmental Studies, National Research Council.  Washington,
    D.C.:  National Academy Press, 1987.

    Schulze, W., R.  d'Arge, and D.  Brookshire.  "Valuing Environmental
    Commodities:  Some Recent Experiments," Land Economics, Vol.  57, No.
    2, pp.  151-172, 1981.

    Shelby, B., T.C.  Brown, and R.  Baumgartner.  "Effects of
    Streamflows on River Trips on the Colorado River in Grand Canyon,
    Arizona," Rivers, Vol.  3, No.  3, pp.  191-201, 1992.

    Stevens, L., K.  Buck, B.  Brown, and N.  Kline.  Dam and Geomorphic
    Influences on Colorado River Waterbird Distribution, Grand Canyon,
    Arizona, USA, 1995 (unpublished original research).

    We also interviewed researchers, members of the EIS and recreation
    teams, including Reclamation officials and their contractors, as well
    as representatives from the National Park Service and the Arizona
    Game and Fish Department.  In addition, we spoke to academic experts
    in economics and members of the National Academy of Sciences Glen
    Canyon Dam EIS review team.  A list of the researchers, officials,
    and experts follows.

    Richard Bishop, Professor, University of Wisconsin
    Kevin Boyle, Associate Professor, University of Maine
    Curtis Brown, Social Psychologist, Bureau of Reclamation
    Bonnie Colby, Associate Professor of Agricultural and Resource
     Economics, University of Arizona, Tucson
    Galen Collins, Assistant Dean of Hotel and Restaurant Management,
     Northern Arizona University
    Diane Dupont, Associate Professor of Economics, Brock University -
     Ontario, Canada
    Marshall Flug, Water Resources Engineer and Research Hydrologist,
     National Biological Service and Colorado State University
    Rusty Gattis, Acting Superintendent, Glen Canyon Dam, Bureau of
     Reclamation
    Terry Gunn, Owner, Lees Ferry Angler's Guides and Fly Shop
    W.  Michael Hanemann, Professor of Agricultural and Resource
      Economics, University of California, Berkeley
    Martha Hahn, Idaho State Director, Bureau of Land Management
    David Harpman, Natural Resource Economist, Bureau of Reclamation
    Amis Holm, Environmental Planner III, SWCA, Inc.  Environmental
     Consultants
    Brice Hoskins, Project Manager, SWCA, Inc.  Environmental
     Consultants
    Charles Howe, Professor of Economics, University of Colorado
    Linda Jalbert, Biological Technician, National Park Service
    Lisa Kearsley, former National Park Service employee and researcher
    Mark Law, Colorado River Subdistrict Ranger, National Park Service
    Jerry Mitchell, Chief, Cultural Resource Management, National Park
     Service
    Mike O'Donnell, Supervisory Natural Resource Specialist, Bureau of
     Land Management
    Timothy Randle, Hydraulic Engineer, Bureau of Reclamation
    Larry Riley, Supervisor, Arizona Game and Fish Department
    Michael Welsh, Senior Associate, Hagler Bailly Consulting

    SEDIMENT
    ======================================================== Appendix VIII

    Sediment is unconsolidated material that comes from the weathering of
    rock and is transported and deposited by water or wind.  It is seen
    as a key indicator resource for the Grand Canyon ecosystem because
    nearly all of the canyon's resources are strongly linked to sediment.
    For example, sediment is critical for stabilizing archeological sites
    and camping beaches, for developing and maintaining backwater fish
    habitats, for transporting nutrients, and for supporting the
    vegetation that provides wildlife habitat.  The amount of sediment
    transported through the Glen and the Grand canyons depends to a large
    degree on the volume of water released by the Glen Canyon Dam.

    According to the EIS team members and sediment researchers that we
    interviewed, the data used in the preparation of the sediment section
    of the Glen Canyon Dam's EIS were the latest and best scientific
    information available at the time.  Furthermore, they told us that
    the EIS is as good a document as can be done for reviewing and
    transferring technical information for use in public policy
    decision-making.  While some sediment study results were based on
    data that were preliminary, draft, and/or unpublished at the time of
    the draft and final EIS, the researchers told us that no new or
    additional information has subsequently been obtained that would
    alter the information or conclusions presented in the final EIS.
    Also, for the most part, these researchers agree that the modeling
    tools used in the sediment impact determinations, while fairly crude
    in some respects, were the best available at the time and that their
    use resulted in appropriate conclusions.

       DESCRIPTION OF THE RESOURCE
    ------------------------------------------------------ Appendix VIII:1

    Sediment currently entering the Colorado River comes from tributaries
    downstream from the Glen Canyon Dam, primarily the Little Colorado
    and Paria rivers.  Through several complex processes, the sediment in
    the river is transported, deposited, and then eroded for further
    transport.  The quantity of the sediment in motion at a given time
    and its location depend on the amount and particle size of the
    sediment available, the dimensions and slope of the channel, and the
    magnitude of the water's flow.  Four general classes of sediment, by
    size, are found in the Glen and Grand canyons:

      -- silts and clays (finer than 0.062 millimeter),

      -- sand (0.062 to 2 millimeters),

      -- gravels and cobbles (2 to 256 millimeters), and

      -- boulders (greater than 256 millimeters).

    The transport and deposition of sediment vary with the size of the
    particles.  Silts and clays are easily transported and generally pass
    through the system in a relatively short time, although some may be
    deposited in the low-water-velocity areas on sandbars and in
    backwaters.  Silt and clay-sized particles provide important
    nutrients for vegetation, and clay also provides cohesion.  The most
    abundant class of sediment found along the river is sand.  Many
    sandbars, frequently called "beaches," are used as campsites by
    boaters and rafters and are also important sites for riparian
    vegetation and wildlife habitats.  Some sandbars also contain
    important cultural resource sites for Native American tribes.  Gravel
    and cobblestones cover the bottom of some streambeds.  Some fish
    species use shallow gravel beds for spawning.  The larger boulders
    fall from the canyon walls or reach the river during flash floods in
    steep tributary canyons.  Boulders create and modify most of the
    major river rapids and are an important factor in the creation of
    sandbars.

    The river's capacity to transport sediment increases exponentially
    with the amount of water flowing in the river.  The greater the
    river's flow, the greater the velocity and the greater the
    turbulence.  The turbulence of flowing water is the uplifting force
    that causes sediment particles to be carried in suspension or roll
    along the streambed.  Because sediment particles weigh more than
    water, they tend to settle to the bottom of the river channel.  Small
    clay and silt particles can be carried in suspension by nearly all
    dam releases.  Riverflows often are large enough to carry sand grains
    in suspension.  The grains may be temporarily deposited in areas
    where the velocity of the water is insufficient to move them.  Larger
    flows and velocities are needed to move gravel and cobbles, whereas
    the largest boulders may remain in place in the river channel for
    decades.

       EFFECTS OF PRE- AND POSTDAM
       CONDITIONS ON SEDIMENT
    ------------------------------------------------------ Appendix VIII:2

    The Colorado River historically carried large quantities of sediment
    from the states in the Upper Colorado River Basin.  The Glen Canyon
    Dam has caused three major changes to the sediment resources in the
    canyon.  First, the supply of sediment has been reduced.  The
    construction of the Glen Canyon Dam caused virtually all of the high
    concentration of sediment from the upper basin to be trapped by the
    dam and deposited in Lake Powell.  Second, by controlling the annual
    historical peak flows that had a tremendous capacity to transport
    sediment, the dam has reduced the capacity of the river to transport
    sand and other sediment.  Third, the height of the annual deposition
    of sediment, which is responsible for the size of sandbars, has been
    reduced because the dam now controls flood flows.

       ISSUE
    ------------------------------------------------------ Appendix VIII:3

    As defined in the final EIS, the issue of concern for sediment
    resources is how the dam's operations affect sediment throughout the
    Glen and the Grand canyons.

       INDICATORS
    ------------------------------------------------------ Appendix VIII:4

    The indicators for the sediment resource listed in the final EIS are

      -- the probability of net gain in riverbed sand;

      -- the active width and height of sandbars;

      -- the erosion of high terraces (high sediment deposits having a
         relatively flat surface and steep slope facing the river);

      -- the constriction of debris fans (sloping masses of boulders,
         cobbles, gravel, sand, silt, and clay formed by debris flows at
         the mouth of a tributary) and rapids; and

      -- the elevation of lake deltas (sediment deposits formed where the
         Colorado River and other streams enter Lake Powell or Lake
         Mead).

       METHODOLOGY USED TO MAKE IMPACT
       DETERMINATIONS
    ------------------------------------------------------ Appendix VIII:5

    The EIS sediment team used a combination of historical riverflow and
    sediment discharge data, established computer modeling techniques,
    preliminary research results, and professional judgment to determine
    the potential impacts of the nine flow alternatives on the various
    types of sediment (especially riverbed sand).  The long-term impacts
    on riverbed sand were estimated using empirical data and computer
    modeling, while the potential impacts on sandbars, high terraces,
    debris fans, and lake deltas were developed using preliminary
    research results, modeling, and professional judgment.

    The sediment team was comprised of two individuals, a civil engineer
    with Reclamation and a hydrologist with the U.S.  Geological Survey.
    In order to obtain the most recent scientific information, they
    obtained the preliminary results of the Glen Canyon Environmental
    Studies phase II research and attended the meetings of the phase II
    sediment researchers.  The sediment team also attended a special
    session at an American Geophysical Union symposium to discuss the
    latest research on backwaters and also participated in several raft
    trips down the canyon with researchers in order to personally observe
    the sedimentation processes.

    Other researchers involved in the sediment impact determinations
    included U.S.  Geological Survey and National Park Service officials
    experienced in the sediment resource area.  In addition, researchers
    from Utah State University, the University of Tucson, and the
    University of Northern Arizona were also active in various projects.
    All of the researchers were experienced in sedimentation data
    collection and analysis.

    The data used in drafting the sediment section of the EIS were
    obtained from measurements and observations at selected canyon sites
    under various conditions, including during floods, historic
    powerplant operations and operations under the interim operating
    criteria, and also under specially designed research flows.  The data
    collected underwent several different reviews.

    The data obtained by the U.S.  Geological Survey and used in the
    final EIS received additional reviews.  Within the Geological Survey,
    each report was reviewed by at least two other researchers, plus an
    additional review at the regional level.  External review was
    provided by the editors of outside publications or other
    professionals when the work was published in a U.S.  Geological
    Survey professional paper.

    In addition, the National Academy of Sciences, through its National
    Research Council, reviewed the preliminary draft EIS and provided
    official comments.  The draft EIS was also made available for public
    review and comment.  Over 470 public comments were received that
    related to sediment.  The public comments reflected many differing
    and even contradictory views and opinions.  For example, some
    commentors suggested that the dam's historical operations have
    damaged the beaches and increased erosion.  Other commentors said
    that without the dam, there would be fewer beaches or that the
    increases in erosion are overstated.  The effect of steady flows
    versus fluctuating flows on beach erosion was also argued on both
    sides.  Some believed that steady flows would preserve beaches, while
    others said that they would destroy beaches.  Other commentors
    expressed the belief that controlling fluctuation within certain
    parameters can control erosion, while others said that as long as
    there is a flow of any kind, erosion will occur.

    The EIS team needed detailed analyses of the projected flow patterns
    for the various alternatives to evaluate different impacts.  To
    develop these technical analyses, the EIS team used the Colorado
    River Simulation System (CRSS), a package of computer programs and
    databases designed to assist water resource managers in long-range
    planning and operations studies.  The development of CRSS took place
    over a 10-year period and stemmed from the need for a comprehensive
    model of the Colorado River Basin that would incorporate all areas of
    interest, including legislative requirements.  According to
    Reclamation and other experts, today, CRSS is the most comprehensive
    and detailed simulation of the Colorado River system that exists.

    The CRSS database contains reconstructed natural flow data for the
    Colorado River between 1906 and 1990.  The CRSS model can simulate
    the Colorado River's operations and the effects of changes to the
    Glen Canyon Dam's operations for the entire river basin.  The
    modeling process begins with the assumption that previous natural
    flows in the river are indicative of future activity.  Thus, the
    model uses the historical data to project future water availability.
    The CRSS can address many of the "what if" questions stemming from
    proposed changes in the Colorado River's operations, from proposed
    Colorado River basin development or from changes to present water use
    throughout the basin.  The model's long-term estimates are widely
    accepted by water resource managers.  The short-term estimates,
    between 5 and 10 years, are considered to be somewhat less precise.

    The model produces data on a monthly basis, whereas the EIS team
    needed hourly projections in order to make their analyses for the
    fluctuating flow alternatives.  The steady flow alternatives did not
    require this analysis because they provide for essentially steady
    monthly flows.  To make the necessary adjustments for analyzing the
    fluctuating flows, a peak-shaving model was used to calculate the
    hourly distributions from the CRSS-projected monthly release volumes.
    (Peak shaving is the concept whereby hydroelectric powerplants are
    used to serve (shave) the highest electric load (peak) during a
    24-hour period.) These hourly distributions were produced for the
    No-Action and Maximum Powerplant Capacity alternatives and for each
    of the restricted fluctuating flow alternatives.

    The combined outputs of the CRSS model and the peak-shaving model
    were then used in the development of a sand-mass balance model.  This
    model used 85 different hydrological scenarios (for 50 years each) to
    estimate the changes in riverbed sand due to differing flow
    alternatives from the Glen Canyon Dam.  Using regression analysis,
    the sediment team calculated a sand-load discharge rating curve using
    the water flow rate as the independent variable and total sand load
    as the dependent variable.  This curve shows the amount of sediment
    transported for any given discharge rate.  The sand-load discharge
    rating curves were used as input into the 85 water release scenarios
    to determine the probability that a given flow alternative would
    result in higher amounts of sand in the riverbed over 20- and 50-year
    periods.  EIS team members stated that the resulting numbers were
    reasonably accurate indicators of the relative differences between
    the nine flow alternatives considered in the EIS.

       EFFECTS OF FLOW ALTERNATIVES ON
       SEDIMENT
    ------------------------------------------------------ Appendix VIII:6

    According to the final EIS, the type of water release pattern
    selected for the dam's operations will greatly affect sediment.  The
    analysis of the impacts on sediment was limited to the Colorado River
    corridor from Glen Canyon Dam to Lake Mead and the deltas in Lake
    Powell and Lake Mead.  The direct impacts on sediment will vary with
    the level and pattern of riverflow.  The direct impacts include
    changes in riverbed sand storage, aggradation (the process of filling
    and raising the level of a streambed, flood plain, or sandbar by the
    deposition of sediment) and degradation (the process wherein the
    elevation of streambeds, flood plains, and sandbars is lowered by
    erosion) of sandbars, and changes in the capacity to move large
    boulders from rapids.  Future levels of riverbed sand will vary
    depending on the amount of riverbed sand available and the water
    volume and release patterns of the alternative implemented.

    On the basis of the results of computer models and the most recent
    scientific research, the EIS sediment team determined what the
    potential impacts of the various alternatives would be:

      -- The No-Action, Maximum Powerplant Capacity, and High Fluctuating
         Flow alternatives all had excessive sand transport capacity,
         which jeopardized the long-term storage of sediment.

      -- The Interim Low Fluctuating Flow, Existing Monthly Volume, and
         Year-Round Steady Flow alternatives all maximized long-term sand
         storage but provide limited ability to build sandbars.  These
         alternatives would result in vegetation encroachment on sandbars
         and net erosion of sandbars above the normal river stage.

      -- The Seasonally Adjusted Steady Flow, the Moderate Fluctuating
         Flow, and the Modified Low Fluctuating Flow alternatives all
         provided long-term sand storage and system dynamics.

    On the basis of this analysis, the sediment team focused on the
    Seasonally Adjusted Steady Flow, the Moderate Fluctuating Flow, and
    the Modified Low Fluctuating Flow alternatives as the ones that would
    provide preferable potential impacts on sediment.

       ASSESSMENT OF IMPACT
       DETERMINATIONS
    ------------------------------------------------------ Appendix VIII:7

    The EIS team members and sediment researchers whom we contacted
    provided us with comments on a variety of subjects, including the
    sand-mass balance model, the quality of the data used, the accuracy
    of the EIS in reflecting the research data, and whether other
    evidence existed that would change the impact determinations in the
    EIS.  Generally, they agreed that the sand-mass balance model was the
    best modeling tool available at the time, although two researchers
    told us that more refined models are currently being developed by
    U.S.  Geological Survey researchers.  However, according to two
    Geological Survey researchers, none of the preliminary results from
    these newer models contradict the conclusions reached from the
    sand-mass balance model.

    The researchers we spoke to generally complimented the way
    Reclamation interpreted and used their work in the impact
    determination process and said that the quality of the data used was
    the best available at the time.  A limitation on the use of the more
    recent research results was that the data were preliminary (in draft
    form or unpublished) and the newer models were too complex to
    simulate multiple years of dam operations.  In some cases, definitive
    information on the impacts of a specific flow alternative was not
    available.  Therefore, the team had to extrapolate from the existing
    data using their professional judgment to estimate the potential
    impact of the alternative.  However, they always verified the
    reasonableness of their conclusions and extrapolations with the
    researchers involved.

    The officials we contacted also agreed with Reclamation's selection
    of a preferred alternative and could find no evidence to change the
    outcomes of the impact determinations for the sediment resource.

    Specific comments made by some of those with whom we spoke included
    the following:

      -- Some commentors described the sand-mass balance model as
         simplistic or fairly crude.  However, they agreed that it was
         the best and only tool available at the time.  Also, they agreed
         that the impact determinations reached as a result of the model
         were correct.  The leader of the sediment team agreed that the
         sand-mass balance model is simplistic, but he believed it
         produced reliable results for general, long-term information
         needs.  He did not think that any other model now available
         would have been better.  In fact, he stressed that the models
         available today cannot handle the amount and types of data that
         were required for the EIS process.

      -- Some commentors believed that the sediment information in the
         EIS was somewhat out of date in that it reflected the scientific
         data of 1992-93.  However, there was a general belief that the
         EIS team did an excellent job of using the latest sediment
         research.  While more is known about the sedimentation processes
         in the canyon today than was known when the EIS was written, the
         EIS does contain the best information available at the time.
         Also, they told us that even if the newer data had been
         available, the same decisions would have been reached.  The
         discontinuity between the research and the administrative time
         frames was a limitation on the EIS process, but they said that
         the only impact would have been changes in some of the
         statements made in the EIS.  For example, they said that the
         reasons for the selection of the preferred alternative would
         have been more clearly supported.

      -- Most of the researchers we contacted believed that their work
         was properly used and interpreted in the EIS.  With only a few
         exceptions, discussions and communication between the EIS team
         and the researchers were frequent and thorough enough to ensure
         that the work was properly integrated into the EIS.
         Consequently, the researchers believe that the sediment team
         came up with the right conclusions.  We found no examples that
         would contradict or change the impact determinations in the EIS
         or the selection of a preferred alternative.  According to one
         researcher, the sediment team examined all of the existing
         professional papers and "followed up every lead, public or
         private, for additional work."

    The sediment team leader's overall position, taking into
    consideration the various perspectives and opinions expressed, was
    that

      -- the process used in making the impact determinations for
         sediment was reasonable,

      -- the methodologies employed in this process were appropriate, and

      -- the data used were the best available.

       SCOPE AND METHODOLOGY
    ------------------------------------------------------ Appendix VIII:8

    To determine the process used in developing the impacts on the
    sediment resource, we identified and reviewed the following
    documents:  the draft and final Glen Canyon Dam environmental impact
    statements and associated appendixes, the public comments on the
    draft and final environmental impact statements, and Reclamation's
    responses to the comments on the draft.  We obtained and reviewed
    copies of the minutes from the EIS team meetings and summaries of the
    cooperating agencies' meetings.  We also reviewed the Colorado River
    Simulation System Overview, the Final Analysis Report on Scoping
    Comments, the Glen Canyon Dam EIS Preliminary Alternatives Report,
    and the newsletters issued by the Colorado River Studies Office from
    June 1990 to February 1995.  We also obtained and studied the Glen
    Canyon Dam:  Beach/Habitat-Building Test Flow, Final Environmental
    Assessment and Finding of No Significant Impact, issued in February
    1996.

    In addition, we reviewed the paper entitled "Sediment Transport in
    the Colorado River Basin" by Edmund D.  Andrews.  This paper was
    published in Colorado River Ecology and Dam Management by the
    National Academy of Sciences.  This book contains various papers
    presented in a 1990 symposium on the Grand Canyon.

    We also reviewed Reclamation's paper entitled "Assessment of Changes
    to the Glen Canyon Dam Environmental Impact Statement Preferred
    Alternative From Draft to Final EIS." This paper explained the
    background and scientific basis for the changes to the preferred
    alternative between the draft and the final EIS.

    To assess the procedures followed and obtain views on the quality of
    data used in developing the impact determinations, we interviewed the
    members of the sediment resource team and reviewers of the sediment
    section of the draft EIS.  We also identified and interviewed several
    key Glen Canyon Environmental Studies principal investigators on
    sediment issues.

    Finally, we asked a member of the sediment team to review our
    description of the impact determination process for factual accuracy.
    He agreed that our description was generally accurate but made some
    suggestions for changes.  We have incorporated these changes into our
    description of the process.  We also presented him with our summary
    of the resource process in order to provide him with an opportunity
    to comment on and respond to the various issues raised through our
    audit work.

          KEY STUDIES IDENTIFIED
    ---------------------------------------------------- Appendix VIII:8.1

    Beaus, S.S., and C.C.  Avery (editors).  The Influence of Variable
    Discharge Regimes on Colorado River Sand Bars Below Glen Canyon Dam.
    Flagstaff, Arizona:  Northern Arizona University, 1992.

    Budhu, M.  "Mechanisms of Erosion and a Model to Predict
    Seepage-Driven Erosion due to Transient Flow," in The Influence of
    Variable Discharge Regimes on Colorado River Sand Bars Below Glen
    Canyon Dam, S.S.  Beaus and C.C.  Avery, editors.  Flagstaff,
    Arizona:  Northern Arizona University, 1992.

    Ferrari, R.L.  1986 Lake Powell Survey.  Bureau of Reclamation,
    Report no.  REC-ERC-88-6, 1988.

    Hereford, R., H.C.  Fairley, K.S.  Thompson, and J.R.  Balsom.
    Surficial Geology, Geomorphology, and Erosion of Archeological Sites
    Along the Colorado River, Eastern Grand Canyon, Grand Canyon National
    Park, Arizona.  U.S.  Geological Survey Open-File Report 93-517,
    1993.

    Leopold, L.B.  "The Rapids and the Pools--Grand Canyon." U.S.
    Geological Survey Professional Paper 669-D, 1969.

    Pemberton, E.L.  "Sediment Data Collection and Analysis for Five
    Stations on the Colorado River from Lees Ferry to Diamond Creek,"
    Glen Canyon Environmental Studies Technical Report.  Salt Lake City,
    Utah:  Bureau of Reclamation, 1987.

    Randle, T.J., and E.L.  Pemberton.  "Results and Analysis of STARS
    Modeling Efforts of the Colorado River in Grand Canyon," Glen Canyon
    Environmental Studies Technical Report.  Salt Lake City, Utah:
    Bureau of Reclamation, 1987.

    Randle, T.J., R.I.  Strand, and A.  Streifel.  "Engineering and
    Environmental Considerations of Grand Canyon Sediment Management,"
    Engineering Solutions to Environmental Challenges:  Thirteenth Annual
    USCOLD Lecture, Chattanooga, Tennessee.  Denver, Colorado:  U.S.
    Committee on Large Dams, 1993.

    Schmidt, J.C.  "Temporal and Spatial Changes in Sediment Storage in
    Grand Canyon," The Influence of Variable Discharge Regimes on
    Colorado River Sand Bars Below Glen Canyon Dam, S.S.  Beaus and C.C.
    Avery, editors.  Flagstaff, Arizona:  Northern Arizona University,
    1992.

    Schmidt, J.C., and J.B.  Graf.  "Aggradation and Degradation of
    Alluvial Sand Deposits, 1965 to 1986, Colorado River, Grand Canyon
    National Park, Arizona." U.S.  Geological Survey Professional Paper
    1493, 1990.

    Smillie, G.M., W.L.  Jackson, and D.  Tucker.  "Colorado River Sand
    Budget:  Lees Ferry to Little Colorado River." National Park Service
    Technical Report NPS/NRWRD/NRTR-92/12.  Fort Collins, Colorado:
    National Park Service, 1993.

    Webb, R.H., P.T.  Pringle, and G.R.  Rink.  "Debris Flows From
    Tributaries of the Colorado River, Grand Canyon National Park,
    Arizona." U.S.  Geological Survey Professional Paper 1492, 1989.

          OFFICIALS INTERVIEWED
    ---------------------------------------------------- Appendix VIII:8.2

    We interviewed the following individuals about the sediment impact
    determination.

    Edmund (Ned) Andrews, U.S.  Geological Survey, Boulder, Colorado
    Julia Graf, U.S.  Geological Survey, Tucson, Arizona
    Bill Jackson, National Park Service, Ft.  Collins, Colorado
    Dick Marzolf, U.S.  Geological Survey, Boulder, Colorado
    Margaret Matter, Western Area Power Administration, Denver,
     Colorado
    Timothy Randle, Bureau of Reclamation, Denver, Colorado
    Spreck Rosekrans, Environmental Defense Fund
    Jack Schmidt, Utah State University
    James Smith, U.S.  Geological Survey, Boulder, Colorado
    Robert Webb, U.S.  Geological Survey, Tucson, Arizona
    James Wilson, U.S.  Geological Survey, Cheyenne, Wyoming

    VEGETATION AND WILDLIFE/HABITAT
    ========================================================== Appendix IX

    The resources downstream from Glen Canyon Dam through the Grand
    Canyon are interrelated, or linked, since virtually all of them are
    associated with or are dependent on water and sediment.  This link is
    true for vegetation and wildlife and their habitat.  The complex
    Grand Canyon ecosystem contains a variety of native and nonnative
    plants and animal communities that began developing before the
    construction of the dam.  However, since the dam was completed, the
    ecosystem immediately surrounding the Colorado River has been
    significantly influenced by the operations of the dam.

    We have combined our analysis of the vegetation and the
    wildlife/habitat impact determinations in this appendix because (1)
    with the exception of the abundance of aquatic food base for
    wintering waterfowl, similar indicators were studied in making the
    impact determinations for these resources; (2) the riparian
    vegetation that developed along the Colorado River corridor plays an
    important role as habitat to support the diversity of wildlife within
    the Glen and the Grand canyons; and (3) the same EIS team member was
    responsible for the impact determinations for both resources.

    There has been little controversy surrounding the results of the
    impact determinations as presented in the final EIS for the
    vegetation and wildlife/habitat resources.  Generally, the team
    leader and other experts we interviewed believed that the processes
    used in making the impact determinations were reasonable, the
    methodologies employed in these processes were appropriate, and the
    data used were the best available.

       DESCRIPTION OF THE RESOURCE
    -------------------------------------------------------- Appendix IX:1

    The plant communities surrounding the Grand Canyon reflect the
    influences of desert conditions.  These plants include barrel cactus,
    brittle bush, creosote bush, ocotilla, and cholla cactus.  The
    Colorado River and the operations of the Glen Canyon Dam have little
    effect on these plants.  However, the dam's operations, which
    modified the natural hydrology within the Colorado River corridor, do
    affect a narrow band of vegetation known as the riparian (near water)
    zone.  The availability of water in the riparian zone supports plants
    that could not otherwise survive in a desert climate, and the types
    and abundance of vegetation that exists reflect the water regime that
    supports it.  Among the plants found in areas of the riparian zone
    are netleaf hackberry, honey mesquite, catclaw acacia, seep-willow,
    arrowweed, desert broom, coyote willow, and tamarisk.

    The riparian zone is the focus of both the vegetation and the
    wildlife/habitat studies for the EIS.  The thick growth and variety
    of plant species as well as the several thousand species of
    invertebrates found there make the riparian zone some of the most
    important wildlife habitat in the Grand Canyon region.  For example,
    riparian plants provide cover and food for 26 species of mammals.
    Also, of the 303 species of birds that have been documented in the
    Grand Canyon region, 250 species use the riparian zone within the
    Colorado River corridor.  Over half of the bird species nesting along
    the river corridor nest in riparian vegetation.  Furthermore, 27
    species of reptiles and amphibians are supported by the resources
    found in the riparian zone.  In some Colorado River corridor
    locations, lizard population densities are higher than anywhere else
    in the Southwest.

    Also, during peak winter months, 19 species of wintering waterfowl
    have been found along the river corridor between Lees Ferry and Soap
    Creek.  These waterfowl cannot be directly linked to riparian
    vegetation, but they are attracted to and use the clear, open, cold
    water of the Colorado River that resulted after the dam was
    constructed and that supports the abundant algae that are important
    to the aquatic food chain.  Although survey data are not available,
    the EIS states that before the construction of the dam, the turbid
    river water was probably not very attractive to wintering waterfowl.

       EFFECTS OF PRE- AND POSTDAM
       CONDITIONS ON VEGETATION AND
       WILDLIFE/HABITAT
    -------------------------------------------------------- Appendix IX:2

    Because of the dynamic interaction between riparian vegetation and
    water availability, the construction of the dam and any changes in
    its operations that change specific water release patterns would be
    expected to affect the abundance and distribution of plants.  Before
    the Glen Canyon Dam was constructed, seasonally high riverflows
    carried large sediment deposits through the Glen and the Grand
    canyons and scoured away or buried most vegetation from the river
    corridor below the 100,000 to 125,000 cubic feet per second river
    stage elevation.  Annual floodflows prevented the establishment of
    marsh plants (cattails and similar aquatic plants) along the river
    corridor.  Before the dam, the only riparian vegetation present along
    the river was woody plants (trees and shrubs) that developed in what
    became known as the old high-water zone.  Plants that can withstand
    the conditions created by periodic flooding characterize the old
    high-water zone--netleaf hackberry, honey mesquite, and catclaw
    acacia.

    After the dam began operations and controlled annual spring flooding,
    additional vegetation began to develop near the river below the old
    high-water zone.  This vegetation developed rapidly in what has
    become known as the new high-water zone.  Within this new high-water
    zone are found both woody plants and emergent marsh plants (cattails
    and similar aquatic plants).  Common woody plants found in the new
    high-water zone include both native and nonnative species such as the
    seep-willow, arrowweed, desert broom, coyote willow, and tamarisk.
    Tamarisk is a nonnative tree that has become the dominant woody plant
    in the new high-water zone.  Besides cattails, emergent marsh plants
    found in the new high-water zone include bulrushes and giant reed.
    This new high-water zone provides over 1,000 acres of additional
    habitat for wildlife.  Figure IX.1 illustrates the relative positions
    of the predam and postdam riparian zones in the Grand Canyon.

       Figure IX.1:  Grand Canyon
       Riparian Zone, Predam (Before
       1963) and Postdam (After 1963)

       (See figure in printed
       edition.)

    Source:  Bureau of Reclamation.

       ISSUE
    -------------------------------------------------------- Appendix IX:3

    As developed in the final EIS, the issue of concern is how the dam's
    operations affect vegetation and wildlife and their habitat
    throughout the Glen and the Grand canyons.

       INDICATORS
    -------------------------------------------------------- Appendix IX:4

    Two plant groups found in the Colorado River corridor--woody plants
    and emergent marsh plants--were selected by the EIS team for detailed
    evaluation and to serve as indicators of riparian vegetation.  The
    impact determination for vegetation was generally limited to the
    Colorado River corridor that extends between the Glen Canyon Dam and
    Separation Canyon.  Because of the variety of plants growing in the
    riparian zone and their differing water requirements, EIS team
    members concluded that a comprehensive evaluation of the effects of
    all of the dam's operating alternatives on all plants was beyond the
    scope of the EIS.

    Although very little information on wildlife population exists for
    either the predam or postdam habitats found along the river corridor,
    it was assumed that almost all wildlife concerns could be addressed
    by considering the effects of the operating alternatives on riparian
    vegetation because it serves as habitat for many wildlife species
    that inhabit the river corridor.  Thus, rather than make specific
    analyses of impacts on individual wildlife species, the EIS team
    assumed that almost all wildlife concerns could be addressed by
    considering the effects of each of the dam's alternative operating
    procedures on riparian vegetation.  However, wintering waterfowl do
    not depend on riparian vegetation within the Colorado River corridor
    below the Glen Canyon Dam.  Therefore, the EIS team used the
    abundance of the aquatic food base, mainly Cladophora, as an
    indicator for wintering waterfowl.

       METHODOLOGY USED TO MAKE IMPACT
       DETERMINATION
    -------------------------------------------------------- Appendix IX:5

    Reclamation designated a lead position for each resource and assigned
    that person the overall responsibility for developing the general
    impact determinations.  For example, a riparian specialist was
    assigned for both the vegetation and wildlife/habitat resources.  The
    riparian specialist developed his sections of the EIS through an
    iterative process of report drafting, formal and informal
    presentations to and review by the entire EIS team, and discussions
    with and input from key researchers and colleagues.  In this process,
    it was important that the work of resource specialists responsible
    for other resource impact determinations be considered in the
    vegetation and wildlife/habitat analyses.  For example, sediment is
    critical for supporting the riparian vegetation that provides
    wildlife habitat.  Therefore, the impact determinations for the
    sediment resource are directly linked to the vegetation and wildlife
    and habitat resources and were used in the vegetation analyses.  (See
    app.  VIII for a discussion of the impact determinations for
    sediment.)

    The riparian specialist prepared the vegetation and wildlife/habitat
    sections of the draft EIS and was responsible for any revisions to
    the EIS that were based on the 170 public comments received on these
    sections of the draft EIS (123 on vegetation and 47 on wildlife and
    habitat).  In the preparation of material for the EIS impact
    determinations, he relied extensively on the research work of other
    scientists that was specific to the canyon's resources.  For example,
    an ecologist, who is considered a leading authority on vegetation in
    the Grand Canyon region, was a major contributor of science-based
    information on the vegetation and wildlife and habitat resources of
    the canyon area.  Key documented research considered by the riparian
    specialist in his analyses of impacts on vegetation and
    wildlife/habitat can be found in the scope and methodology section of
    this appendix.

    The ecologist was also one of the peer reviewers of the impact
    determinations prepared by the riparian specialist.  Others who
    reviewed the riparian specialist's work were a zoologist, who has
    done extensive fieldwork in the Glen Canyon, and a senior Glen Canyon
    Environmental Studies scientist affiliated with Arizona State
    University.

       EFFECTS OF FLOW ALTERNATIVES ON
       THE RESOURCES
    -------------------------------------------------------- Appendix IX:6

          SUMMARY OF IMPACTS ON
          VEGETATION
    ------------------------------------------------------ Appendix IX:6.1

    According to the final EIS, in the short-term period of analysis,
    which was considered in the EIS to be between 5 and 20 years, the
    alternative operations of the Glen Canyon Dam would affect riparian
    vegetation within the river corridor in several different ways.
    While some plants do well in drier conditions, others require wetter
    conditions to survive.  Some plants would likely decline as others
    adjusted to new water regimes.  The reduced frequency of major,
    uncontrolled flood releases would result in an unknown, but assumed
    equal, decline in the area of coverage of riparian vegetation in the
    old high-water zone under all alternatives.  Some plant species found
    in the old high-water zone would expand into the new high-water zone.

    The Maximum Powerplant Capacity alternative would result in reduced
    areas of riparian vegetation in the new high-water zone because of
    the higher maximum flows permitted under this alternative.  Under the
    No-Action alternative, woody plants within the new high-water zone
    would be maintained within stage boundaries equivalent to flows
    between about 22,000 cfs and 40,500 cfs.  Periodic flooding that is
    similar to existing conditions would maintain emergent marsh
    vegetation at sites that are currently occupied at elevations between
    flows ranging from 10,000 cfs to 20,000 cfs.

    Under alternatives with lower maximum flows--the restricted
    fluctuating and steady flow alternatives--new areas of sediment would
    be exposed, and these areas would be available for plant growth.
    These flow alternatives would all permit riparian vegetation to
    expand into sites created by the reduced maximum flows.  Woody
    plants, such as coyote willow and arrowweed, found in the new
    high-water zone would continue to increase.  Some new establishment
    of emergent marsh plants would occur at suitable sites; however,
    existing areas of emergent marsh plants that lose their water supply
    would become dominated by woody plants and eventually disappear.

    The habitat maintenance flows included under the Moderate and
    Modified Low Fluctuating Flow alternatives and the Seasonally
    Adjusted Steady Flow alternative are assumed to affect the area
    available for vegetation, but the magnitude of the effect is unknown.
    Beach/habitat-building flows that restructure sediment deposits would
    disturb plants and interrupt succession in the riparian community.
    As a result of these flows, some woody vegetation would be buried and
    lost as sand is deposited on higher elevations, and patches of
    emergent marsh plants would be lost through scouring or burial.  Both
    woody plants and emergent marsh vegetation would develop in the years
    following beach/habitat-building flows that would induce periodic
    changes in the combination of vegetation and open, bare areas.

    In the long-term period of analyses (20 to 50 years), the differences
    among the alternatives would continue to develop.  Because at least
    one major flood event is assumed to occur in the long term under the
    No-Action and Maximum Powerplant Capacity alternatives, riparian
    vegetation would decrease.  However, woody and emergent marsh plants
    would recover after the flooding to a level comparable to baseline or
    no-action conditions.  Also in the long term, riparian vegetation
    that is supported by Lake Mead would increase by an unknown but
    assumed equal amount under all alternatives.

    The restricted fluctuating and steady flow alternatives include
    measures to reduce the frequency of floods that would support
    increases in the coverage of woody plants at the end of the long-term
    period of analysis.  Over the long term, habitat maintenance and
    beach/habitat-building flows would maintain woody and emergent marsh
    plants that developed during the short term.  The dryer conditions
    created in the upper elevations of the new high-water zone would
    shift species composition from tamarisk and willow to mesquite and
    other plants.  Tamarisk, willow, and other plants would favor the
    wetter sites at lower elevations.

          SUMMARY OF IMPACTS ON
          WILDLIFE/HABITAT
    ------------------------------------------------------ Appendix IX:6.2

    According to the final EIS, wildlife and habitat would be affected in
    ways similar to riparian vegetation under the operating alternatives,
    i.e., those dam-operating alternatives that tend to increase riparian
    vegetation would result in increased wildlife habitat.  In the short
    term, woody plant coverage, and therefore riparian habitat, would
    increase under most alternatives.  Emergent marsh plants would either
    remain similar in coverage to the no- action condition or decrease.

    The No-Action alternative would maintain the existing riparian
    vegetation area, while the Maximum Powerplant Capacity alternative
    would create conditions leading to a decline in habitat area.  The
    remaining alternatives would permit woody riparian vegetation to
    expand.  It is assumed that as the area of woody riparian vegetation
    increases, so too will the size of the area of wildlife habitat that
    would provide valuable food resources and shelter.  Habitat
    maintenance and beach/habitat-building flows would move and deposit
    sediment that would bury some vegetation, thus temporarily reducing
    its value as habitat.  Vegetation that is not buried or that grows up
    through new sediment deposits would be unusable to area wildlife
    during the period of inundation.

    Generally, individual animals would not be directly affected by the
    daily operations of the Glen Canyon Dam because animals are mobile
    and would move as required by the daily fluctuations in water
    releases.  Birds using the riparian zone as a travel lane through the
    Grand Canyon would not be directly affected by any of the
    alternatives.  However, species that nest in riparian vegetation
    would be indirectly affected by changes in area coverage of plants.

    Wintering waterfowl would be affected by changes in minimum
    discharge.  The No-Action and Maximum Powerplant Capacity
    alternatives have a minimum discharge of 1,000 cfs.  The remaining
    alternatives increase minimums from 3,000 cfs to 11,400 cfs.
    Increased minimum discharges, as well as brief high release periods
    during habitat maintenance and beach/habitat-building flows, are
    assumed to benefit the aquatic food base and ultimately wintering
    waterfowl.

       ASSESSMENT OF IMPACT
       DETERMINATIONS
    -------------------------------------------------------- Appendix IX:7

    EIS team members and researchers we contacted were generally
    complimentary of the process used in making the impact determinations
    of the dam's various operating procedures on the vegetation and the
    wildlife/habitat resources.  Also, scientists we interviewed believed
    that the data used in the analyses were the best and most current
    available at the time and that the research used in the analyses was
    properly interpreted.  While some scientists believe that some data
    may have been incomplete at the time the EIS segments were prepared,
    subsequent research only served to confirm and refine the analyses
    presented in the final EIS.  Therefore, according to one official,
    there was little controversy associated with these resources and the
    presentation of impact determinations in the EIS.  This opinion seems
    to be supported by the relatively low number of comments received on
    the draft EIS in connection with these resources.

    Also, many people we talked to were supportive of the preferred
    alternative selected by Reclamation.  There were, however, some
    concerns expressed.  For example, one researcher believed that to
    further improve the aquatic food base, the Seasonally Adjusted Steady
    Flow may be a more advantageous operating regime.  However, the
    riparian specialist disagreed with the researchers who favored the
    Seasonally Adjusted Steady Flow because he believes that the
    preferred alternative provides for higher water levels during the
    summer months, which would be more beneficial to plants that are
    important as an aquatic food base.  Overall, he believes that the
    preferred alternative was the proper choice and that it would create
    conditions that permit the recovery of downstream resources to
    acceptable management levels while maintaining some hydropower
    capability.  Overall, the riparian specialist believed that the
    results of the impact determinations for the vegetation and
    wildlife/habitat resources were reasonable.  The riparian specialist
    thought that the methodology used in making the impact determinations
    was appropriate and properly implemented and the data used were the
    best available.

       SCOPE AND METHODOLOGY
    -------------------------------------------------------- Appendix IX:8

    Our analyses of the impact determinations on the vegetation and
    wildlife/habitat resources were based on an evaluation of scientific
    studies used by the riparian specialist in his assessments, the study
    review process used, the impact determinations themselves, and
    extensive interviews with officials involved in the process.  In
    addition, we provided the riparian specialist with our description of
    the processes followed in making the impact determinations for his
    review and comment.  He agreed that our description accurately
    presented the facts.

          KEY STUDIES IDENTIFIED
    ------------------------------------------------------ Appendix IX:8.1

    We reviewed the following studies and research materials that
    Reclamation officials said were instrumental in making EIS decisions:

      -- Anderson, L.S., and G.A.  Ruffner.  "Effects of Post-Glen Canyon
         Flow Regime on the Old High Water Line Plant Community Along the
         Colorado River in Grand Canyon," Glen Canyon Environmental
         Studies Technical Report.  Salt Lake City, Utah:  Bureau of
         Reclamation, 1987.

      -- Carothers, S.W., and B.T.  Brown.  "The Colorado River Through
         Grand Canyon:  Natural History and Human Change." Tucson,
         Arizona:  University of Arizona Press, 1991.

      -- Pucherelli, M.J.  "Evaluation of Riparian Vegetation Trends in
         the Grand Canyon Using Multitemporal Remote Sensing Techniques,"
         pp.  172-181.  Anchorage, Alaska:  American Society of
         Photogrammetry and Remote Sensing Technical Papers, 1986.

      -- Stevens, L.E., and T.  J.  Ayers.  "The Impacts of Glen Canyon
         Dam on Riparian Vegetation and Soil Stability in the Colorado
         River Corridor, Grand Canyon, Arizona," Draft Annual Report.
         National Park Service Cooperative Studies Unit.  Northern
         Arizona University, Flagstaff, Arizona.  1991.

      -- Stevens, L.E., J.C.  Schmidt, and B.T.  Brown.  "Geomorphic
         Control of Vegetation Establishment and Marsh Development Along
         the Colorado River in Grand Canyon, Arizona," in AGU 1991 Fall
         Meeting Program and Abstracts.  American Geophysical Union EOS
         Transactions, supp.  to vol.  72, No.  44, p.  223, 1991.

      -- Stevens, L.E., and G.L.  Waring.  "Effects of Post-Dam Flooding
         on Riparian Substrates, Vegetation, and Invertebrate Populations
         in the Colorado River Corridor in Grand Canyon, Arizona," Glen
         Canyon Environmental Studies Technical Report.  Salt Lake City,
         Utah:  Bureau of Reclamation, 1986.

    In addition to the above studies, which directly addressed vegetation
    resources, we examined the following other relevant documents in the
    wildlife and habitat resource area:

      -- Threatened Native Wildlife in Arizona.  Phoenix, Arizona:
         Arizona Game and Fish Department, 1988.

      -- Brown, B.T.  "Monitoring Bird Population Densities Along the
         Colorado River in Grand Canyon," Glen Canyon Environmental
         Studies Technical Report.  Salt Lake City, Utah:  Bureau of
         Reclamation, 1987.

      -- _____.  Abundance, Distribution, and Ecology of Nesting
         Peregrine Falcons in Grand Canyon National Park, Arizona.  Final
         report submitted to Grand Canyon National Park, Grand Canyon,
         Arizona, 1991b.

      -- _____.  Nesting Chronology, Density, and Habitat Use of
         Black-Chinned Hummingbirds Along the Colorado River, Arizona,
         1991c.

      -- Brown, B.T., R.  Mesta, L.E.  Stevens, and J.  Weisheit.
         "Changes in Winter Distribution of Bald Eagles Along the
         Colorado River in Grand Canyon, Arizona," Journal of Raptor
         Research, vol.  23, No.  3, pp.  110-113, 1989.

      -- Brown, B.T., G.S.  Mills, R.L.  Glinski, and S.W.  Hoffman.
         "Density of Nesting Peregrine Falcons in Grand Canyon National
         Park, Arizona," Southwestern Naturalist, Vol.  37, No.  2, pp.
         188-193, 1992.

      -- Jakle, M.D., and T.A.  Gatz.  "Herpetofaunal Use of Four
         Habitats of the Middle Gila River Drainage, Arizona," Riparian
         Ecosystems and Their Management:  Reconciling Conflicting Uses,
         R.R.  Johnson et al.  (technical coordinators).  Forest Service
         General Technical Report RM-120, pp.  355-358, 1985.

      -- Jones, K.B., and P.C.  Glinski.  "Microhabits of Lizards in a
         Southwestern Riparian Community," Riparian Ecosystems and Their
         Management:  Reconciling Conflicting Uses, R.R.  Johnson et al.
         (technical coordinators).  Forest Service General Technical
         Report RM-120, pp.  342-346, 1985.

      -- Warren, P.L., and C.R.  Schwalbe.  "Lizards Along the Colorado
         River in Grand Canyon National Park:  Possible Effects of
         Fluctuating River Flows," Glen Canyon Environmental Studies
         Technical Report.  Salt Lake City, Utah:  Bureau of Reclamation,
         1988.

      -- Wilson, M.F., and S.W.  Carothers.  "Avifauna of Habitat Islands
         in the Grand Canyon," Southwestern Naturalist, Vol.  24, No.  4,
         pp.  563-576, 1979.

          OFFICIALS INTERVIEWED
    ------------------------------------------------------ Appendix IX:8.2

    In addition to the riparian specialist, we interviewed 11 other EIS
    team members and researchers from the government, private, and
    academic sectors.  A listing of the officials we contacted and the
    organizations they represent follows.

    Michael Armbruster, Bureau of Reclamation, Denver, Colorado
    Steven W.  Carothers, SWCA Inc., Flagstaff, Arizona
    Byran Brown, SWCA Inc., Salt Lake City, Utah
    Duncan Patten, Arizona State University (Retired), Tempe, Arizona
    Larry Stevens, Glen Canyon Environmental Studies, Flagstaff,
     Arizona
    Dean W.  Blinn, Northern Arizona University, Flagstaff, Arizona
    Tina Ayers, Northern Arizona University, Flagstaff, Arizona
    Michael Pucherelli, Bureau of Reclamation, Denver, Colorado
    Susan Anderson, The Nature Conservancy, Tucson, Arizona
    William Leibfried, SWCA Inc., Flagstaff, Arizona
    David Wegner, Glen Canyon Environmental Studies, Flagstaff, Arizona
    Mark Sogge, National Biological Service, Flagstaff, Arizona

    WATER
    =========================================================== Appendix X

    The construction of the Glen Canyon Dam altered the historical flow
    pattern of the Colorado River and the characteristics of the water
    being discharged downstream.  While different water flow alternatives
    would alter the pattern of water that is released from the dam,
    existing statutes, compacts, a treaty, and operating criteria guide
    the allocation of water to the seven basin states.\1

    Currently, these laws, known collectively as the "Law of the River,"
    establish minimum annual releases of water from the Glen Canyon Dam.

    The area of potential impact for the resource water includes the
    Colorado River downstream from the Glen Canyon Dam, Lakes Powell and
    Mead, and the upper and lower basin states.  These impacts include
    annual streamflows, reservoir storage, water allocation deliveries,
    upper basin state yield determinations, and water quality.  The EIS
    team used computer modeling studies to project the dam's operations
    for 50 years to estimate the long-term impacts and for 20 years to
    estimate the short-term impacts.

    The EIS team found that the impacts on water issues of the dam's
    various flow alternatives are essentially the same as under the
    No-Action alternative, except for the volume of monthly water
    releases and floodflow frequency.  The annual streamflows, reservoir
    storage, water allocation deliveries, upper basin yield
    determinations, and water quality are only slightly affected by the
    alternatives.

    The EIS team members and researchers we spoke with were confident
    that the computer modeling tools and the data used in the analyses
    were the best available at the time.  Also, while some researchers
    believed that the maximum flow parameters under the preferred
    alternative should be increased, there was general acceptance of the
    selection of the Modified Low Fluctuating Flow as the preferred
    alternative.

    --------------------
    \1 The basin states consist of the upper basin--which covers parts of
    Arizona, Colorado, New Mexico, Utah, and Wyoming; and the lower
    basin--which covers parts of Arizona, California, Nevada, New Mexico,
    and Utah.

       DESCRIPTION OF THE RESOURCE
    --------------------------------------------------------- Appendix X:1

    Most of the Colorado River water flowing into Lake Powell and
    ultimately released into the Glen and the Grand canyons originates in
    the Rocky Mountains.  Runoff from spring snowmelt in the Rockies is
    high during April through July, when the flow in the Colorado River
    above Lake Powell reaches its annual maximum, then recedes for the
    remainder of the year.  During the summer and fall, thunderstorms
    cause flooding in the tributaries originating on the Colorado
    Plateau, producing additional peaks in the river, but they are
    usually smaller than the snowmelt peaks and of much shorter duration.
    Since the Glen Canyon Dam was completed in 1963, flows immediately
    below the dam have consisted almost entirely of water released from
    Lake Powell.

    For purposes of the resources addressed in the EIS, water was
    described in terms of streamflows, floodflows, reservoir storage,
    annual water allocation deliveries, upper basin state yield
    determinations, and water quality:

      -- The annual streamflows are determined by the Law of the River,
         which currently requires a minimum annual release of 8.23
         million acre-feet of water from the Glen Canyon Dam.

      -- Floodflows are defined as releases in excess of the powerplant
         capacity of 33,200 cubic feet per second (cfs).

      -- The reservoir storage in Lakes Powell and Mead depends on annual
         and monthly reservoir inflow and release volumes.  Storage
         levels affect shore line resources and recreation on the lake.
         Furthermore, the upper basin states use storage in Lake Powell
         to meet their water delivery requirements to the lower basin
         states.

      -- The water allocation deliveries are the deliveries of Colorado
         River water to entities in the seven basin states and Mexico in
         accordance with the Law of the River.  In recent years, the
         demand for water by the lower basin states has approached their
         entitlement of 7.5 million acre-feet.

      -- The upper basin state yield determination is the legal maximum
         volume of water available for annual use by the upper basin
         states.

      -- The Glen Canyon Dam altered downstream water quality by changing
         the water's temperature and clarity.

       EFFECTS OF PRE- AND POSTDAM
       CONDITIONS ON WATER
    --------------------------------------------------------- Appendix X:2

    Before construction of the Glen Canyon Dam, the Colorado River was
    sediment-laden, and its flows fluctuated dramatically during
    different seasons of the year.  Flows of greater than 80,000 cfs were
    common during the spring.  In contrast, flows of less than 3,000 cfs
    were typical throughout the late summer, fall, and winter.  The water
    temperatures ranged from near freezing in the winter to more than 80
    degrees Fahrenheit in the summer.

    The construction of the Glen Canyon Dam altered the natural dynamics
    of the Colorado River.  The dam replaced seasonal flow variations
    with daily fluctuations and greatly reduced the amount of sediment in
    the river.  Lake Powell now accumulates the sediment that would have
    traveled the Colorado River before the dam's construction.  In
    addition, the water released from the dam to produce hydropower is
    withdrawn from the cold depths of Lake Powell, 230 feet below the
    surface when the reservoir is full.  As a result of this water
    withdrawal process, the water temperature downstream of the dam is
    nearly a constant, year-round 46 degrees Fahrenheit.

    The quality of the water has also been affected.  Most of the
    nutrients carried by the river are associated with or attached to
    sediments, and sediments are now trapped by the dam.  Variations in
    the levels of salinity in the water have also been reduced.

       ISSUE
    --------------------------------------------------------- Appendix X:3

    As defined in the final EIS, the issue of concern for water resources
    is how the dam's operations affect the amount and quality of water
    available from Lake Powell at specific times.

       INDICATORS
    --------------------------------------------------------- Appendix X:4

    The indicators for water resources listed in the final EIS are the

      -- acre-feet of streamflows,

      -- frequency and volume of floodflows,

      -- reservoir storage in Lakes Powell and Mead,

      -- acre-feet of annual water allocation deliveries (deliveries of
         Colorado River water to entities in the seven basin states and
         Mexico),

      -- acre-feet of upper basin state yield determination (hydrologic
         assessment of the total water depletion that can ultimately be
         allowed in the upper basin), and

      -- chemical, physical, and biological characteristics of water
         quality.

       METHODOLOGY USED TO MAKE IMPACT
       DETERMINATIONS
    --------------------------------------------------------- Appendix X:5

    Reclamation established a water resource team to make the impact
    determinations for the EIS.  The team consisted of two hydraulic
    engineers from Reclamation; one was a water resource and an
    environmental specialist, and the other was a water quality
    specialist.

    The water resource specialist was assigned the responsibility for the
    hydrology impact assessment and provided information on the Colorado
    River's operations.  He wrote the background sections for the water
    resource area and helped write the technical descriptions of the
    various alternatives presented in the EIS.  The water quality
    specialist was responsible for water quality issues in the EIS.

    The team used the Colorado River Simulation System (CRSS) to analyze
    the impacts of the nine flow alternatives on the annual and monthly
    streamflows, floodflows and other spills, water storage, water
    allocation deliveries, and upper basin yield determinations for the
    EIS.  CRSS, a package of computer programs and databases, is widely
    regarded as the most comprehensive and detailed simulation system of
    the Colorado River.  CRSS is designed to assist water resource
    managers in performing long-range planning and operation studies.

    The CRSS database contains reconstructed natural flow data from the
    U.S.  Geological Survey for the Colorado River during 1906 through
    1990.  The CRSS model can simulate the operations of the Colorado
    River, including the effects of changes to the operation of the Glen
    Canyon Dam.  The modeling process begins with the assumption that the
    previous natural flows in the river are indicative of future
    activity.  Thus, the model uses historical data to project water
    availability in the future.  The CRSS can address many of the "what
    if" questions stemming from proposed changes in the Colorado River's
    operations, from proposed development in the Colorado River Basin, or
    from changes to present water use throughout the basin.  The model's
    estimates are widely accepted by water resource managers.

    CRSS produces data on a monthly basis; therefore, a peak-shaving
    model was used to predict hourly distribution from the CRSS-projected
    monthly release volumes.  (Peak shaving is the concept whereby
    hydroelectric powerplants are used to serve (shave) the highest
    electric load (peak) during a 24-hour period.) These hourly
    distributions were produced for the No-Action and the Maximum
    Powerplant Capacity Flow alternatives and for each of the restricted
    fluctuating flow alternatives.  The hourly projections were needed to
    develop and analyze the effects of fluctuating flows on sediment and
    other resources.  The steady flow alternatives did not require this
    analysis because flows from hour to hour would be essentially steady.

    The water resource specialist developed the technical analyses of the
    alternatives using the CRSS model.  The technical development of the
    alternatives was an iterative process, whereby the team presented the
    results of the modeling program at the EIS team meetings; the EIS
    team would then analyze and discuss the information to determine what
    additional adjustments to the alternatives were needed.  Using the
    CRSS program, the water resource specialist calculated various
    parameters for each alternative, including annual releases, monthly
    releases, reservoir storage, water allocation yield, and floodflows.
    The EIS team members then prepared impact analyses of each
    alternative for the various resource areas.  Their analyses were
    based on the CRSS results, preliminary data from various research
    projects, and their professional judgment.  The results of the impact
    analyses were presented and discussed at the EIS team meetings.

       EFFECTS OF THE FLOW
       ALTERNATIVES ON WATER
    --------------------------------------------------------- Appendix X:6

    According to the final EIS, the annual streamflows would differ only
    slightly from the No-Action alternative under all alternatives and
    are therefore not expected to affect the distribution of water among
    the basin states.  Under the restricted fluctuating and steady flow
    alternatives, the measures included for reducing the frequency of
    floods would reduce the frequency of unscheduled floodflows that are
    greater than 45,000 cfs from an average of once in 40 years to once
    in 100 years.  Other spills would differ only slightly from the
    No-Action alternative under all other alternatives.

    Reservoir storage under all fluctuating flow alternatives would be
    essentially the same as under the No-Action alternative.  Water
    allocation deliveries would be affected slightly under all
    alternatives.  However, if reserving more space in the reservoir is
    used to reduce flood frequency, the amount of water available for use
    by the upper basin states would be reduced.  None of the alternatives
    affect water quality under normal reservoir levels, which occur 95
    percent of the time.

       ASSESSMENT OF IMPACT
       DETERMINATIONS
    --------------------------------------------------------- Appendix X:7

    The CRSS model is widely accepted as the best method available for
    analyzing the effects of changes to the operations of the Glen Canyon
    Dam.  The officials and researchers we interviewed generally stated
    that the CRSS model was the best method available at the time for
    analyzing and describing the various alternatives.  Some alternative
    modeling programs did exist; however, EIS team members told us they
    would not have produced significantly different results.

    The EIS team members and researchers we spoke with generally support
    the preferred alternative.  Two reasons cited were that the
    alternative (1) strikes a balance for the resources at Glen Canyon
    Dam and (2) represents a reasonable compromise among the various
    interest groups.  However, two researchers believe that the preferred
    alternative's operating parameters are still too conservative, even
    after they were increased following public comment on the draft EIS.
    They told us that higher maximum releases and higher fluctuating
    flows are needed and that adaptive management will show that the
    higher flows are acceptable.  They stated that compromises made for
    the benefit of environmental issues may have gone too far because
    one-third of the hydropower capacity of the dam was lost.

    In addition, none of the EIS team members or researchers we
    interviewed provided any data or research that would change the
    conclusions reached by the EIS team.

    The team's water resource specialist provided us with his responses
    to the issues and comments noted above.  He agreed with the comments,
    especially noting that the preferred alternative was a reasonable
    compromise and that adaptive management may lead to less restrictive
    flows.  He stated that

      -- the process used in making the impact determinations for the
         water resource was reasonable,

      -- the methodologies employed in this process were appropriate, and

      -- the data used were the best available.

       SCOPE AND METHODOLOGY
    --------------------------------------------------------- Appendix X:8

    To determine the process used to develop the flow alternatives, we
    identified and reviewed the following documents.

          KEY STUDIES IDENTIFIED
    ------------------------------------------------------- Appendix X:8.1

    Key documents we reviewed were the draft EIS and final EIS and
    associated appendixes, the public comments on the draft EIS and final
    EIS, and Reclamation's responses to the comments on the draft EIS.
    We also obtained and reviewed copies of the minutes of the EIS team
    meetings and summaries of the cooperating agencies' meetings.  We
    studied the Colorado River Simulation System Overview prepared by
    Reclamation and the Glen Canyon Environmental Studies chapter
    prepared by the Power Resources Committee.  We also reviewed the
    Final Analysis Report on Scoping Comments, the Glen Canyon Dam EIS
    Preliminary Alternatives Report, and the newsletters issued by the
    Colorado River Studies Office from June 1990 to February 1995.  We
    also obtained and studied the Glen Canyon Dam:
    Beach/Habitat-Building Test Flow, Final Environmental Assessment and
    Finding of No Significant Impact, issued in February 1996.

    We also reviewed three papers presented at a 1990 symposium on the
    Grand Canyon (published in Colorado River Ecology and Dam Management
    by the National Academy of Sciences in 1991).  These papers were
    "Sediment Transport in the Colorado River Basin" by Edmund D.
    Andrews, "Hydrology of Glen Canyon and the Grand Canyon" by David R.
    Dawdy, and "Reservoir Operations" by Trevor C.  Hughes.

    Furthermore, we reviewed "Assessment of Changes to the Glen Canyon
    Dam Environmental Impact Statement Preferred Alternative from Draft
    to Final EIS," issued by Reclamation in October 1995.  This paper
    explained the background and scientific basis for the changes to the
    preferred alternative between the draft and final EIS.

    EIS team members stated that the documents generated using the CRSS
    model were key to the development of the water resource area.
    Appendix VIII of this report contains a list of those documents.
    Another document that was identified as important to the process was
    Hydrologic Determination 1988:  Water Availability From Navajo
    Reservoir and the Upper Colorado River Basin for Use in New Mexico.
    Salt Lake City, Utah:  Bureau of Reclamation, 1989.

          OFFICIALS INTERVIEWED
    ------------------------------------------------------- Appendix X:8.2

    To assess the procedures followed and obtain views on the quality of
    the data used in developing the flow alternatives, we interviewed the
    water resource team and the internal and external reviewers of the
    work.  Finally, we asked the EIS team's water resource specialist to
    review our description of the impact determination process for
    factual accuracy.  He agreed that our description was generally
    accurate but made some suggestions for changes.  We have incorporated
    these changes into our process description.  A list of the officials
    we interviewed follows.

    Trevor Hughes, Utah State University/National Research Council
    William Lewis Jr., University of Colorado-Boulder/National
     Research Council
    Margaret Matter, Western Area Power Administration, Denver,
     Colorado
    Randy Peterson, Bureau of Reclamation, Salt Lake City, Utah
    Craig Phillips, Bureau of Reclamation, Denver, Colorado
    Tim Randle, Bureau of Reclamation, Denver, Colorado
    Spreck Rosekrans, Environmental Defense Fund
    Thomas Slater, Bureau of Land Management, Salt Lake City, Utah
    Leslie Stillwater, Bureau of Reclamation, Denver, Colorado

    (See figure in printed edition.)Appendix XI
    SUMMARY COMPARISON OF THE
    ALTERNATIVES AND IMPACTS AS
    PRESENTED IN THE GLEN CANYON DAM'S
    FINAL ENVIRONMENTAL IMPACT
    STATEMENT
    =========================================================== Appendix X

    (See figure in printed edition.)

    (See figure in printed edition.)

    (See figure in printed edition.)

    (See figure in printed edition.)

    (See figure in printed edition.)

    (See figure in printed edition.)

    (See figure in printed edition.)

    Source:  Bureau of Reclamation.

    (See figure in printed edition.)Appendix XII
    COMMENTS FROM THE DEPARTMENT OF
    THE INTERIOR
    =========================================================== Appendix X

    (See figure in printed edition.)

       GAO'S COMMENTS
    --------------------------------------------------------- Appendix X:9

    The following are GAO's comments on the Department of the Interior's
    comments enclosed in a letter dated September 13, 1996.

    1.  We have revised the title of the report as suggested.

    2.  We have added the term "periodic" to our description of the
    Modified Low Fluctuating Flow alternative.

    3.  We revised the text to clarify that the computational errors were
    made during the third phase of the power analysis.

    4.  The year was changed to 1968.

    5.  We have deleted the sentence from the report.

    6.  See comment 3 above.

    7.  We deleted the word "load" from the report.

    8.  We revised the footnote to clarify that the energy and capacity
    values referred to in the table are attributable to the Salt Lake
    City Area/Integrated Projects in total, but the change in annual
    economic costs are attributable solely to the Glen Canyon Dam's
    operations.

    MAJOR CONTRIBUTORS TO THIS REPORT
    ======================================================== Appendix XIII

    RESOURCES, COMMUNITY, AND ECONOMIC
    DEVELOPMENT DIVISION, WASHINGTON,
    D.C.

    Jonathan Bachman
    Steve Brown
    Jay R.  Cherlow
    Timothy J.  Guinane
    Barry T.  Hill
    Edward A.  Niemi
    Jim Yeager

    DENVER, COLORADO

    Sandra P.  Davis
    W.  Stephen Lowrey
    Craig D.  Richards
    William J.  Temmler
    Frank B.  Waterous
    Alan J.  Wernz

    OFFICE OF THE GENERAL COUNSEL

    Martin J.  Fitzgerald
    Alan R.  Kasdan

    *** End of document. ***