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. . MS.,Carol DeAngelis February .19, 2004 Page 5 year only. Cooperative recommendations agreements between Navajo Reservoir Supply contractors and direct flow water users made for particular years also do not constitute determinations of the Secretary of the Interior as to how Reclamation may determine and allocate shortages in the future under section 11 of the Act of June 13, 1962, absent agreement of the contractors and the San Juan-Chama Project water users. Also, the Draft Opinion does not appear to adequately address or cover impacts of releasing less than 250 cfs from Navajo Dam during extreme conditions if and when inflow to Navajo Reservoir is less than 250 cfs and reservoir storage is approaching, at or below the Navajo Indian Irrigation Project diversion intake and the bottom of the rip rap protection on the upstream face of the dam. Extreme hydrologic conditions may dictate or mandate a release of less than 250 cfs to match inflow for some period of time. Weather and Runoff Predictions The Draft Opinion at page 56 argues that it is reasonable to expect certain hydrologic conditions In New Mexico for the next ten years based on a suggestion that a measure of sea surface temperatures in the northern Pacific Ocean mimics precipitation in New Mexico. There are uncertainties in any relationship that may exist between sea temperatures and New Mexico precipitation, and it would be advisable not to characterize a 'suggested relationship' as a 'reasonable expectation'. Furthermore, most of the flow of the San Juan River is generated from snowmelt runoff from the San Juan and La Plata mountains in Colorado, not from precipitation in New Mexico. Cooperation of the SeNiee in Adaptive ManaQement The Service is not communicating with its Program psrtners. if the Service believes that the available data indicate that providing flows in the San Juan River in accordance with the flow recommendations and to the extent that water is available may not be providing for the habitat needs of Colorado pikeminnow and razorback sucker, then the Service should be working with the Program to expedite the synthesis of the data and a reevaluation of the flow . recommendations. In addition, it appears that the Service has not acted to complete a Biological Opinion on the proposed action in a timely manner (see Stanley Pollack's email to the cooperating agencies dated February 4, 2004). Nor has the SeNice been as responsive as it needs to be in providing the timely issuance of opinions on Navajo Reservoir Supply subcontracts and cooperative San Juan River Basin administration agreements that are needed to prOVide for adaptive and effective management of limited water supplies in the Basin under extreme conditions. The Commission recommends that Re'clamation and the Service discuss ways to expedite communication, consultation and approval processes consistent with AppendiX B of the Draft Opinion. 001'3 if. 8ES-, 810/EIO.d ESS-! I0908fZOLB NOI!JNnr aNV~~ J,a V3~V OJ N~3!S3M ~08.-WOJ, W'8Z:80 fOOZ-Rn-J'.