October 14, 2004

To: Kitty Roberts
From: Christopher Peterson,
Glen Canyon Institute
RE: Glen Canyon Institute urges National Park Service to adopt a management plan for emerging canyons at Lake Powell reservoir

Dear Superintendent Roberts,

On behalf of Glen Canyon Institute, I respectfully ask the National Park Service to adopt a management plan that ensures proper protection for the emerging areas within Glen Canyon National Recreation Area.
The receding waters of Lake Powell Reservoir have exposed hundreds of miles of canyons in the Glen Canyon region, including more than forty miles of the main stem Colorado and San Juan Rivers. The Glen Canyon National Recreation Area (GCNRA), established by Congress to manage the lands surrounding the reservoir, is administratively responsible for protection and management of the recreation use of the reservoir and the surrounding lands. As the reservoir waters recede, GCNRA must identify and protect critical habitat for endangered species that is now taking hold and ensure that emerging American cultural and environmental treasures are protected for future generations.

The historical and ecological importance of what is being exposed at Glen Canyon cannot be ignored. During the salvage studies organized by the Department of Interior in the late 1950’s, tens of thousands of artifacts and ecological samples were collected as the waters of the rising reservoir drowned the side canyons. This environment is unique, sensitive to increased use, and has historic importance for the Tribes of the Southwest, including the Hopis, Paiutes, Navajos and others. We must recognize the need for special management of these areas, adopting a plan to protect their sensitive and unique nature before they are subject to extensive use and impact.

Glen Canyon Institute calls upon the Department of the Interior and the National Park Service (NPS) to provide leadership in reviewing management protocols for Glen Canyon during current low-water circumstances. Since significant scientific evidence predicts current low-water levels will exist at Glen Canyon for a decade or longer, the review should focus on implementing regulations to protect the integrity of newly exposed ecological habitats and culturally significant areas. The integrity of the emerging endangered species habitat, culturally-rich areas, and ecologically sensitive zones will likely suffer without special consideration in the National Park Service management plan. Specific actions by the NPS should include:
 1 Designation and protection of culturally significant side canyons in consultation with relevant Native American Tribes.
 2 A management plan for environmentally sensitive side canyons and potentially high visitation areas such as Cathedral in the Desert and Gregory Natural Bridge.
 3 A plan to comply with the Clean Water Act, including special efforts to clean up high-traffic areas such as marinas and popular beaches.
 4 A plan to comply with Endangered Species Act to evaluate and identify new habitat for native fish species in the reemerging riparian environments of Narrow Canyon in the mainstem Colorado River, San Juan River, and lower Escalante River.
 5 Implementing an education program for the Glen Canyon National Recreation Area to provide tourists with information on the exposed areas and their cultural and ecological significance.
 6 Implementing a moratorium on the issuing of commercial permits for access to identified sensitive cultural and ecological areas.
 7 A safety plan for visitor-use of emerging side canyons that recognizes fluctuating dangerous conditions and minimizes incidents. (ex.: Quicksand)
 8 Identification of roads and trails into the emerging areas, and implementation of a plan to ensure delicate areas are protected from OHV impacts.

Thank you very much for your consideration of these important matters. Please let me know what steps will be taken toward these recommendations.
Glen Canyon Institute is willing and available to assist in the process of identifying emerging areas, as well as the task of implementing a management plan that will protect them.

Sincerely,


Christopher Peterson
Executive Director
Glen Canyon Institute