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<br />.~ <br /> <br />. <br /> <br />. <br /> <br />ineffective attempt to try to tie a willow flycatcher program to the SJRIP. No case <br />that the San Juan River corridor is essential to willow flycatcher can be made <br />based on the finding of only one nest in a remote vicinity. <br /> <br />Cumulative Effects, Pages 60 to 63 - The seven cumulative effect items do not apply to <br />the proposed action. The USFWLS ignores the focus of this BO or the re-operation of <br />Navajo Dam to provide flows that may assist in the recovery of two endangered fish, <br />The BO must not serve as an opportunity for USFWLS to present a wide range of <br />unrelated issues. For example, none of the seven effects, especially coalbed methane <br />development, have anything to do with the proposed action. This entire section needs to <br />be rewritten. <br /> <br />Conclusion, Pages 63 to 68 - The premise that wanner releases from Navajo Reservoir <br />are needed for endangered fish recovery is incorrect. See the comments on measure 2 <br />above. The USFWLS should check the results of the USBR water temperature model <br />before including this assumption. <br /> <br />On Page 67, USFWLS states that USSR will have difficulty meeting the flow <br />recommendations without legal protection of the Navajo releases. USFWLS does not <br />understand the operation of the San Juan River. USSR makes Navajo releases to assure <br />that the appropriate flow is met through the critical habitat, regardless of intervening <br />diversions. Legal protection may help to minimize the releases needed to implement the <br />flow recommendations but is not required to meet the flow recommendations. <br /> <br />Also on Page 67 - USFWLS proposes at least two new studies concerning water <br />temperature and entrainment. The Biology and Hydrology Committees of the SJRIP <br />have already addressed these issues. USFLWS must first explain why the existing work <br />is not adequate. <br /> <br />Extent of Take, Pages 69 to 71 - USFWLS implies that the result of cold water releases <br />from Navajo Reservoir is an incidental take. This statement is contrary to the best <br />available data. See the comments on measure 2 above. <br /> <br />USFWLS also implies that because USBR is operating Navajo Reservoir to recover the <br />endangered fish but does not have a program for willow flycatcher recovery, the result of <br />Navajo Reservoir re-operation will be a taking of willow flycatcher. Throughout the BO, <br />USFWLS states that mimicking the natural hydrograph improves the habitat for both the <br />endangered fish and the willow flycatcher. Even though the proposed action allows <br />USBR to pennanently mimic the natural hydrograph, USFL WS appears to have <br />concluded that mimicking the natural hydrograph is a taking of willow flycatcher. This is <br />illogical and does not make sense. If the willow flycatcher is impacted at all by the <br />proposed action, it will be helped. USFWLS uses convoluted logic to justify forcing <br />USBR to create a willow flycatcher program. <br /> <br />In short, the BO requires extensive revision to confonn to the results of twelve years of <br />endangered fish research and avoid curtailment of endangered fish recovery efforts <br /> <br />0127,1 <br />