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Ms. Carot DeAngelis February 23, 2004 Page 2 of4 . . Furthermore, as explained in the governing documents for the SJRlP and the attached comments concerning the SJRlP, such requirements cannot be implemented unilaterally by either Reclamation or the Service, Neither Reclamation nor the Service has sole authority under the Cooperative Agreement establishing the SJRIP to expand the scope of the SJRIP to include southwestern willow flycatchers. Furthermore, pursuant to P.L.I06-392, Reclamation cannot apply funds provided by Congress, or cost sharing funds provided by the states and power users for the SJRIP, to projects that are related to the southwestern willow flycatcher, or any other species, other than the four listed Colorado River endangered fish. Therefore, the reasonable and prudent measures and the related terms and conditions requiring expansion of the SJRIP to include the southwestern willow flycatcher are not valid, cannot be accepted by Reclamation or the SJRIP, and accordingly must be eliminated from the draft biological opinion, Furthermore, we find the "reasonable and prudent measure" requiring Reclamation to investigate the feasibility of modifYing the Navajo Dam outlet works to release wanner water wrreasonable as well. A gold medal trout fishery currently exists downstream of Navajo Dam. This trout fishery represents a very important recreational resource for the Fannington area and the four corners region as explained in the EIS, This resource is important enough that trout fishing organizations in the region have successfully sued Reclamation over Navajo Dam operations to protect this trout fishery. Research to date for the SJRIP would indicate that the both the trout fishery and endangered native fish can coexist in separate reaches of the river under the existing Navajo Dam operations. We believe it would be a waste of taxpayer dollars to undertake a temperature control investigation for Navajo Dam when such an investigation would only confirm what we already know, that is a choice to sacrifice the existing trout fishery for a little additional wann water fishery habitat. Furthennore, extensive investigations of this very issue are already occurring as part of the Glen Canyon Dam Adaptive Management Program and confirm there are nwnerous other risks associated with temperature control. Given the close proximity of the Glen Canyon Dam research, duplicative research at Navajo seems unwarranted, at least until after the Glen Canyon Dam research is completed. Therefore, we strongly urge Reclamation not to accept the Service's January 24, 2004 draft biological opinion concerning Navajo Dam operations and to request that the Service revise that draft biological opinion, staying within the limits of the EIS purpose and need and within the existing authorities of the SJRlP and the long-term funding legislation for the SJRIP. Again, thank you for the opportunity to comment on this very important matter. Si~, ~ Director CC: w/attachment: Colorado Water Conservation Board Members Regional Director, U.S. Bureau of Reclamation, Upper Colorado Region Field Supervisor, U.S. Fish and Wildlife Service, Grand Junction Ecological Services Field Office, Grand Junction, Colorado Regional Director, U.S. Fish and Wildlife Service, Region 2 Regional Director, U.S. Fish and Wildlife Service, Region 6 Coordination Conunittee, San Juan River Basin Recovery Implementation Program Southwest Colorado Water Conservation District San Juan Water Conunission Flood Protection. Water Project Planning and Finance. Stream and Lake Protection Water Supply protection. Conservation Planning OOH85