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I I I I I I I I I I I I I I I I I I I following two parts, allowing the project to move forward and the flow recommendations to be honored: 1. ~aYaio depletion offset bv unused depletion in the basin. The balance of the NGWSP depletion not accounted for in the discussion in Section 3.2.2.2, 27,193 acre-feet, is attributed to Navajo Nation uses. This would constitute a new depletion. It is proposed that, until the total depletions in the basin reach baseline plus 1,840 acre-feet listed in Section 3.2.2.2, the full NGWSP depletion of 35,893 acre-feet be allowed, as flow recommendations could be met under these conditions. Up to 27,193 acre-feet of depletions would be offset by these unused depletions. Basin depletions would be monitored and reported every 5 years. This need not begin until the sum of NIIP and ALP reach 290,000 acre-feet. Since these projects are easily tracked, it will limit monitoring requirements for the entire basin. \Vhen monitoring does commence, timing the 5-year cycle to coincide with the Bureau of Reclamation (Reclamation) Consumptive Use and Loss report would be advisable. It is proposed that the data from the Reclamation Consumptive Use and Loss report produced for management of the Colorado River Storage Project, be used to monitor depletions in the basin. This information would be monitored by the SJRIP Hydrology Committee as a part of their overall responsibilities. \\-l1en the total depletion reaches baseline depletion plus 1,840 acre-feet, the conditions of Part 2, below, would be implemented. 2. ~avaio portion of~G\VSP depletion l!uaranteed bv limiting total Navaio depletions. The Navajo Nation projects account for over 300,000 acre-feet of the depletions in the baseline shown in Table 3.2. In the event that the sum of all the actual depletions that are included in the depletion baseline, including the NGWSP depletion, exceeds the level of depletion that is allowable within the flow recommendations at any time in the future, then the Navajo Nation commits to reducing its total depletion to stay below the allowed total for the basin, provided that no other users have exceeded the depletion level specified in the depletion baseline. This could be accomplished by changes in operation of any of the Kavajo projects that deplete water from the San Juan River. By way of example, the operation of the irrigation projects adjacent to the San Juan River could be limited to use less than the full allowed depletion, the operation of the Navajo portion of the KG\VSP could be modified to reduce use or I\lJIP could be modified in terms of service acreage, fallow land or crop mix change to reduce demand. The appropriateness of any of these actions would be demonstrated by modeling the changed operation to assure compliance with the flow recommendations. The maximum guarantee requirement is 27,193 acre-feet. Changes in the flow recommendation or in species status may result in reduction or removal of this guarantee in the future. It is impossible to forecast the manner in which unused depletions in the baseline will occur in the future. To demonstrate the efficacy of part 1 above, one possible scenario was examined. It was assumed that all other baseline depletions occurred, except those from the ALP, and that :\G\VSP was at full capacity. ALP was selected because it was simple to model. An equally valid approach would have been to reduce the private rights that are not being used, but this involves adjusting many diversion points in the model and is subject to greater error. The selection of ALP "vas not meant to indicate a preference for any project over another, but simply to shO'\\- that flow recommendations can be met within existing baseline depletions. This BIOLOGICAL ASSESSMENT NAVAJO GALLUP WATER SUPPLY PROJECT September 3, 2004 Page 20