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. . Ms. Carol DeAngelis Fe,bruary 19, 2004 Page 2 - San Juan River Basin in New Mexico and Colorado, thus allowing the states to utilize. water apportioned to them by the Colorado River and Upper Colorado River Basin compacts. Progress toward recovery of the endangered fish species in the San Juan River also provides compliance with the Act. Yet, while the Draft Opinion at page 6 states that the proposed action to operate Navajo Dam to meet the flow recommendations for the San Juan River adopted by the Program would conserve endangered fish in the San Juan River, the Draft Opinion at page 1 states that the Service has determined that the proposal is likely to adversely affect the Colorado pikeminnow and razorback sucker and their critical habitats. The Draft Opinion also states that the proposal is likely to adversely affect the southwestern willow flycatcher. The Service's determinations also seem at odds with other portions of the Draft Opinion. It is nonsensical for the Service to argue that Navajo Dam operations during 1963-1990 altered the natural hydrograph of the San Juan River and consequently contributed to the decline of the three species, and then to insinuate that changing the operation of the dam to mimic the pre-dam natural hydrogaph would be detrimental to the species. The scope of the EIS and the proposed action is the revised operation of Navajo Dam to meet the flow recommendations or a reasonable alternative, not construction of the dam. In any event, the Draft Opinion suggests that even with operating Navajo Dam to meet the flow recommendations, low-velocity habitats needed for the two endangered fish species and the southwestern willow flycatcher may decline due to insufficient high flows to create overbank flooding, prevent channel narrowing, and form secondary channels. Given that high flows are limited by Navajo Dam release capability and natural variations in available runoff, how would the Service suggest that higher flows be created? The New Mexico State Engineer has been preparing far active water resources management in the San Juan River Basin in New Mexico, including the administration of water rights in the Basin. The State of New Mexico committed to the Program that it would protect to the eldent of its authority flows released from Navajo Dam for the benefit of the populations of endangered fish species in the San Juan River; but, the State Engineer may not recognize or protect releases from the dam made in accordance with the flow recommendations if the status of the current knowledge is that meeting the flaw recommendations is not expected to benefit the species. Recoverv Goal for Southwestern Willow Flvcatcher The Draft Opinion Indicates that the southwestern willow flycatcher occurs seasonally and in small numbers along the San Juan River throughout the action area in Colorado. New Mexico and Utah. The San Juan River valley is near the northem end of the range of the southwestern willow flycatcher, and it does not appear reasonable that Navajo Dam operations should be affected by a questionable recovery goal of providing habitat far as many as 25 or more territories of flycatcher when only one territory may exist within the action area. As the OU1.)0j BE5-, BIO/OIO.d E95-1 1090B~Z016 NOI1JNnr ONVijD J'O V3ijV OJ Nij31S3M ij08.-WOJ, welZ:BO ~OOZ-60-Je~