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<br />U.S. Fish and wildlife Service <br />January 30, 1996 <br /> <br />~3.;= 4: <br /> <br />projects because the depletions by more than one entity, or more <br />than one proj ect, were combined in most of the items. The <br />depletion of 30,700 acre-feet listed in the 1991 baseline for <br />Hogback includes about 8,000 acre-feet of the depletion <br />at tributable to Farmer's Mutual Ditch. Therefore, it must be <br />clearly understood that the depletion listed in Table 2 of the <br />draft, which combines Fruitland and Hogback depletions in the total <br />amount of 31,300 acre-feet still includes the depletion <br />attributable to the Farmer's Mutual Ditch. <br /> <br />Pages 35 and 36. Under the heading "Reasonable and Prudent <br />Alternative", item 1, page 35, discusses depletion of an "annual <br />maximum of 57,000 acre-feet in any year as calculated at the <br />Shiprock gage", and on page 36 discusses "57,100 acre-feet as an <br />average annual depletion". As noted above, under the normal <br />calculation of depletion resulting from supplying water for <br />beneficial consumptive use in a municipal and industrial demand, <br />the two values, maximum annual and average annual, would be nearly <br />the same neglecting routing the depletion from the mouth of the <br />Animas River to the Shiprock gage. The depletion term is crucial <br />in understanding how operation of the project is to function. <br /> <br />The last sentence on page 35 seems to contradict the first <br />sentence on page 36. Page 35 states that depletion cannot exceed <br />an annual maximum of 57,100 acre-feet until all elements of this <br />reasonable and prudent alternative are complete. It can be <br />inferred from this statement that once all elements of the <br />reasonable and prudent alternative are complete the depletion can <br />be an average of 57,100 acre-feet. However, page 36 seems to add <br />a further constraint by coupling the operation of Navajo Reservoir <br />to release 300,000 acre-feet 96% of the time. Further, page 36 is <br />not clear as to the period for operation of the dam; i.e., during <br />and/or after the research period. <br /> <br />Also, on page 36, item 1 states that operation of Navajo Dam <br />such that 300,000 acre-feet of storage is available for release for <br />endangered fishes 96% of the time allows Stage A of ALP to be <br />operated then and only then with a 57,100 acre-foot average annual <br />depletion. If Navajo Dam is operated to provide 300,000 acre-feet <br />of storage for endangered fishes 96% of the time to enable Stage A <br />of ALP to effect an average annual depletion of 57,100 acre-feet, <br />