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<br />U.S. Fish and Wildlife Service <br />January 30, 1996 <br />Page 5 <br /> <br />then Navajo Reservoir cannot yield water for additional uses, other <br />than for the related depletions listed in the Section 7 baseline of <br />the draft. Such an implication is not consistent with the goals of <br />the San Juan Recovery Implementation Program and it is recommended <br />that such implication be deleted from the draft. <br /> <br />Page 36. The last sentence of item 2 states that the research <br />period will be completed when all required test flows have been <br />provided. However, the first sentence of item 3 states that <br />Reclamation will operate Navajo Dam under study guidelines <br />developed under element 2 for the research period. These sentences <br />appear to be mutually dependent, which is not logical. <br /> <br />Page 37. The last sentence seems to be redundant of the <br />previous explanation in this paragraph. If it is not redundant, it <br />is confusing and should be revised. <br /> <br />Page 39. The first paragraph indicates that the timing of the <br />flows released from Navajo Dam during the research period has not <br />been synchronous with the natural peaks of the Animas River. In <br />view of the long duration of the high releases from Navajo <br />Reservoir, particularly during 1994 and 1995, is difficult to <br />understand how these releases were not synchronized with the peak <br />flows of the Animas River to the maximum practical extent. <br /> <br />Page 39. The third paragraph seems to present a "what comes <br />first" scenario. The first sentence states that there must be a <br />guarantee that Navajo Dam will be operated to mimic the natural <br />hydrograph based on research for the life of Navajo Dam (which <br />apparently should not be read literally). However, the third <br />sentence states that until all research is completed, the required <br />water delivery schedule for the life of Navajo Dam is unknown. It <br />is difficult to understand how something can be guaranteed when <br />that which is to be guaranteed is unknown, and would seem to be <br />analogous to an undated, signed, blank check. <br /> <br />The fourth paragraph on page 39 indicates that the research is <br />directed towards determining how Navajo Dam releases can best be <br />used in terms of mimicking the natural hydrograph. However, the <br />first portion of this paragraph discusses operating the reservoir <br />to provide 300,000 acre-feet 96% of the time, and operating the <br />