WSP08787

• File Number: 8240.300.11
• Description: San Juan River Recovery Program - Coordination Committee
• State: CO
• Basin: San Juan/Dolores
• Water Division: 7
• Date: 6/1/2001
• Title: Low Flow Test San Juan Test Final Environment Assessment
• Water Supply Pro - Doc Type: EIS

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Comments on the draft EA were categorized into general groups as presented below.
Reclamation's responses to the comments are included. Where appropriate, changes have also
been made in the final EA to respond to comments.

1. Comment:
Response:

2. Comment:

Response:

3. Comment:
Response:

4. Comment:

Response:

NEPA Compliance and Alternatives

The purpose of the test needs to be clarified.
The purpose of the low flow test is to allow Reclamation, local and state
agencies, and the general public a better understanding of the effect of
lowering releases from Navajo Dam to 250 cfs during the summer months.
Results from the test will allow Reclamation to more accurately present
impacts of the low releases in the EIS to be prepared on the operation of
Navajo Reservoir.

EA needs to clarify that water development as well as endangered fish are
driving the low flows.
Thefinal EA has been clarified on this point. Reclamation is preparing an
EIS on Navajo Reservoir operations to help meet flow recommendations to
protect endangered fish and their critical habitat. Meeting these flow
recommendations will in turn provide Endangered Species Act compliance
for new water development and protect existing water uses. Reducing
flows to 250 cfs at certain times in the summer and winter would serve
several purposes: helping to maintain flows downstreamfrom Farmington
between 500 and 1,000 cfsfor fish habitat, saving water for the following
years spring peak, saving water for development, and following
recommendations in Biological Opinions for other projects.

Does the U.S. Fish and Wildlife Service support the test?
The Fish and Wildlife Service, in its letter to Reclamation dated March 30,
2001, stated that "Provided the duration of the test and the conditions
outlined in the DEAfor terminating the test are followed, the U.S. Fish
and Wildlife Service does not anticipate any negative impacts to
threatened or endangered species". The low flows being tested have been
included by the Fish and Wildlife Service in San Juan River biological
opinions.

If the EA is revised to accurately assess impacts, it is hard to believe that
an EA is the appropriate NEP A document.
The purpose of the EA is to identify impacts of the low flow test and then
to determine whether or not a Finding of No Significant Impact is

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