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L J Volume III - Comments and Responses . 5 FEIS - Navajo Reservoir Operations - The ALP Project EIS did discuss Navajo Reservoir reoperation as a connected action, but negative impacts were not considered a cost of the ALP Project because Navajo Reservoir reoperations will occur whether or not the ALP Project proceeds. 0 • (c) The EIS fails to distinguish between effects of reoperation and future depletions. Response: Reoperation may create immediate, short-term effects that would be offset by flexibility in release patterns before future development occurs. However, the long-term - effects of future development are analyzed for each action alternative to analyze the • worst-case scenario. Thus, the EIS does not distinguish between the short-term effects of reoperation, temporarily reduced by flexibility, and the long-term effects of future development. For example, impacts to the hydropower water supply result from additional • water being diverted from the reservoir to complete the N11P as well as from reoperation of reservoir releases. Reclamation believes the approach used gives the most accurate picture of future conditions under the alternatives considered. Also see the response to General Comment No. 11. - (d) An extensive analysis /discussion is needed of irreversible /irretrievable commitment of resources. - Response: Reclamation believes that the impacts stemming from changes under the - action alternatives would not be irreversible or irretrievable and that future SJRBRIP adaptive management efforts may refine the Preferred Alternative. Refer to chapter III, "IV. Environmental Resources Summary." (e) DEIS does not follow the mission statement of Reclamation. Response: Reclamation's mission is to manage, develop, and protect water and related resources in an environmentally and economically sound manner in the interest of the American public. By issuing this EIS, Reclamation proposes to operate (manage) Navajo Dam and Reservoir to implement ESA-related flow recommendations on the San Juan River, or a reasonable alternative to those recommendations, in a manner that enables both current and future2 water depletions to proceed in compliance with the ESA. Through this action, Reclamation is fulfilling its mission to manage and protect water and related resources. General Comment 2: The DEIS proposes an inadequate level of mitigation. Comments included the following: Z Future water depletions include those that have obtained appropriate environmental compliance but are not yet implemented.