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o <.) 1',;) (:1. . CO:".", ..;i. >,,/ DRAFT San Juan Flow Recommendation Comments May 8, t998 Page 2 of 5 preliminary flow recommendations and an operating rule decision, The flow recommendations are applicable to the mainstem of the San Juan River at the Shiprock gaging station and on downstream. The purpose of this memorandum is to inform the Coordination and Biology Committees of concerns the Colorado Water Conservation Board and others have with the draft preliminary flow recommendations. Discussion The draft preliminary flow recommendations were developed based on habitat as defined by geomorphology and a statistical analysis of the historic hydro graphs defining how often flows occurred that provided the desired habitats and functions. The recommendations subsequently are designed to maintain those same statistical parameters in the long term. Concerns Based on our review of the draft preliminary flow recommendations, we have a number of questions and concerns, 1. How will the flow recommendations be implemented? Once flow recommendations are adopted by the Coordination Committee, what public process will be followed to determine which recommendations are a priority in a given year. The decision tree proposed offers a good start for reservoir operations, but how does that fit with the actual flow recommendations themselves. What opportunities exist for modification of those decisions should hydrologic conditions change dramatically? 2. How will the flow recommendations be used? It appears that a Section 7 Agreement similar to that developed for the Upper Colorado River Basin Program is in order. 3. How will the flow recommendations be administered or enforced? While an enforcement agreement is already in-place, attaching frequencies and conditions that would require a certain condition to be met at least "once in every some many years" is impossible to administer on a real time basis. Frequencies can not be attached to flow recommendations in a meaningful manner on a real time basis. Frequencies can be useful in deciding how you will operate Navajo Dam in any given year. These conditions can be evaluated either by looking back in time or by projecting hydrologic conditions forward in time, In either case, as a practical matter there has to be some difference given to existing hydrologic conditions, From our perspective, the flow recommendations should not include either frequencies or a "once in every some may years" condition, Rather they should consider current hydrologic conditions and seek to accomplish certain priorities under various hydrologic conditions. The decision tree provided for Navajo operations is a start, but it does not provide priorities for the many parts of the flow recommendations and it is not clear how hydrologic conditions that are occurring in the basin are considered, 4. How will you determine whether or not the flow recommendations are satisfied? If the flow recommendations are not satisfied, how will projects be permitted or