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. . Ms. Carol DeAngelis February .19,2004 Page :3 Draft Opinion recognizes. the San Juan River constitutes only a small portion of the range of the southwestern willow flycatcher. Nevertheless, the Draft Opinion at page 72 states that the Service believes that it is both necessary and appropriate for the purpose of reducing incidental take of southwestern willow flycatcher to require Reclamation to expand the mission or goals of the Program to include recovery of southwestern willow flycatcher. It is not clear how operating Navajo Dam to mimic a natural hydrograph may cause incidental take of flycatcher, as opposed to maintaining the historic 1963-1990 dam operations. Also, Reclamation has no authority to unilaterally expand the scope of the Program under the Cooperative Agreement establishing the Program or Public Law 106-392 that authorized the Program in federa/law, and Reclamation cannot use the funds that are provided by Congress. power users or the Upper Basin states for purposes of recovering Colorado pikeminnow and razorback sucker to fund projects to recover southwestern willow flycatcher or other species. Non-Native Veaetation alona San Juan River The Draft Opinion at several places attributes the spread or establishment of salt cedar and Russian olive along the San Juan River valley to reductions in flooding that resulted from construction and operation of Navajo Dam, and further insinuates that this is the cause of river channel narrowing and reduction of low-velocity habitat. It is not proven that operation of Navajo Dam is the cause of the invasion of non-native vegetation along the San Juan River in New Mexico and Utah that occurred during the 20th century. To the extent that the area of salt cedar and Russian olive in the San Juan River valley increased since closure of Navajo Dam in 1962, the area of the two vegetative species in the vaHey would have incr~a:;ed even if the d:;:lm had not been constructed. For example, overbank flooding results in germination and vigorous spread of salt cedar. In the Pecos River valley near Artesia, New Mexico, tens of thousands of acres of salt cedar became established during the 20 years prior to construction of a dam upstream on the Pecos River in the mid 1930s. Salt cedar also established itself along the Gila River in the Safford Valley in Arizona even though there is no major dam on the Gila River stream system above the Safford Valley. In the San Juan River Basin, salt cedar and Russian olive have grown in floodplains of tributary streams that are not dammed. Perhaps by reducing flooding, Navajo Dam may have actually slowed the expansion of salt cedar acreage along the San Juan River. The Service shOUld not insinuate a need to use the Navajo Reservoir water supply to attempt to control non-native vegetation for channel maintenance purposes or for flycatcher habitat. Such use of water would be inappropriate, ineffective and a waste of water. Physical habitat improvements, not. excessive flood flows. should.be considered for improving southwestern willow flycatcher habitat. OUIJ64 B8H BIO/IIOd 895-1 I090BfZOlS NOI1~Nnr aNV~D J,O V3~V OJ N~31S3M ~08.-WOJ, welZ:BO ~nD7-~n_Je.