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<br />,f) <br /> <br />. <br /> <br />. <br /> <br />disingenuous in seeking to use the Navajo Reservoir Re-Operation EIS to recover <br />the willow flycatcher. Not once, during the entire SJRIP effort has USFWLS <br />discussed with the SJRIP Coordination Committee its interest in including the <br />willow flycatcher in the SJRIP. This inclusion requirement in the BO for the <br />Navajo Re-Operation EIS appears to be hastily conceived, is destructive to the <br />fish recovery efforts and is totally unacceptable. <br /> <br />In order to maintain the focus of the SJRIP in meeting its two Congressionally authorized <br />goals, it is essential that USFLWS remove the willow flycatcher condition which has the <br />potential to unravel the entire SJRIP and end the recovery effort for the endangered fish. <br /> <br />SWCD strongly urges the USFWLS to remove all references to the willow flycatcher <br />from the BO. The proposed action will not impact the willow flycatcher. <br /> <br />Comments on Terms and Conditions <br />Items 1.1 and 1.2 have been addressed by the SJRIP. <br /> <br />Item 1.3 assumes that increasing the temperature of the Navajo Reservoir releases is <br />necessary when the best information to date indicates this is incorrect. Rather than spend <br />a huge amount of the limited SJRIP funds on an "engineering feasibility study and cost <br />estimate for retrofitting Navajo Dam to release warmer water to facilitate pikeminnow <br />and razorback sucker spawning further upstream", the existing water temperature model <br />should be used to determine the extent to which Navajo release temperatures can be <br />modified to affect the temperature of water in the San Juan River. <br /> <br />Items 3.1, 3.2, 4.1 and 4.2 should be removed. <br /> <br />Specific Comments <br />Page 6 second line under "Operational Flexibility" - Use of the word "errors" is incorrect <br />because the inflow forecasts are based on the snow pack measurements at a specific point <br />in time, Increases and decreases in the snow pack are not errors, but changes in <br />circumstances. <br /> <br />Page 16 bottom and Page 17 top and Pages 41 to 44 - Water quality has been determined <br />NOT to be a factor limiting the recovery of the endangered fish. The cite included in the <br />paragraph is from 1979. Data collected and published as part of the SJRlP in the past ten <br />years shows water quality is not a factor limiting recovery. This paragraph should be <br />deleted or modified accordingly and all other references to water quality issues should be <br />removed or modified for accuracy. Focus on the issue of water quality is an example of <br />how USFWLS has failed to modifY its pre-conceived ideas based on the results of the last <br />twelve years of on-the-ground research. <br /> <br />Pages 53 and 54 "Entrairnnent" - USFWLS should consult the SJRlP Biology Committee <br />to detemline the actual impact that "entrairnnent" has on recovery of the endangered fish. <br /> <br />01272 <br />