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J> . . Page 54 "Cold Water Releases" - Refer to the comment above for Measure 2. The USFWLS does not have data to support the assumption that releases of cold Navajo Reservoir water are the reason that San Juan River water temperatun:s are too low for endangered fish spawning, Page 56 third paragraph - The USFWLS uses a totally unproven method, the Pacific Oscillation Cycles, to predict that the next 10 to 25 years will be drier than in the past. We doubt that this weather prediction system has been peer reviewed or accepted by qualified meteorologists. Predicting future weather is simply beyond the scope of USFLWS expertise. This entire section of the 80 should be removed and all conclusions based on this section should also be removed. This analysis not only does not address the proposed action, it is based on unproven scientific theories. "The Effects of Action on Endangered Fish and Willow flycatcher" Pages 57 to 60 - This entire section compares current species habitat conditions with the pre-Navajo Dam habitat conditions as idealized by the author. This is an entirely inappropriate analysis because the baseline for the proposed action is not pre-Navajo Dam conditions but post- Navajo Dam conditions from 1965 to 1991. This discussion of the impacts of Navajo Dam on the endangered fish, and especially on the willow flycatcher, is misleading because, as presently written, it does not address the action in the EIS. This EIS section should be rewritten to present the effects of the proposed federal action. The USFWLS bases its analysis of "Effects" on the endangered species on several assumptions, described below, that have either proven to be incorrect or are simply unproven theories. There are no research results, only theory, linking the recovery of the endangered fish with the type of habitat that the flow recommendations were designed to create and support. At best, the current data indicate that the flow recommendations have been neutral as to the recovery effort. The most effective recovery effort has been stocking. The SJRIP is just beginning an analysis of whether the current flow recommendations are actually assisting in fish recovery and whether modifications to the recommendations are appropriate. There is no hard evidence, only theory, that the amount and timing of water flows are critical to recovery of the endangered fish. Recovery efforts to date would indicate that stocking is far more important to recovery than meeting a theoretical flow pattern. There is hard evidence that water quality is NOT a limitation in the San Juan Ri ver on the recovery of the endangered fish. The entire discussion on water quality as a limitation on endangered fish and willow flycatcher recovery is unsupported by the data. The author's "conclusion" that certain flows are needed for willow flycatcher habitat is total speculation, without any supporting evidence. This is an 01273