9582

• UCREFRP Catalog Number: 9582
• Author: U.S. Bureau of Reclamation.
• Title: Final Environmental Impact Statement - Navajo Reservoir Operations Volume III Comments and Responses.
• USFW Year: 2006.
• USFW - Doc Type: Grand Junction - Durango, CO.
• Copyright Material: NO

Volume III - Comments and Responses
FEIS - Navajo Reservoir Operations
The commitments for fishery and other mitigation and monitoring are vague. Specific
commitments should be made; for example, Reclamation should take the lead, including
funding, in accomplishing mitigation. Would the potential mitigation offset losses of trout
habitat? Instream habitat mitigation should be completed prior to lowering flows.
Reclamation's role in mitigation is inadequate; why should those receiving authorized
purposes pay for the mitigation of impacts on historic, other uses like hydropower? The
costs of mitigation should not be passed on to SJRBRIP participants.
Mitigation for other resources and effects-such as water quality, lost jobs, recreation,
irrigation diversions, and erosion-should be addressed.
Response: Reclamation has recognized in the EIS that the Preferred Alternative would
have adverse impacts on certain resources, including the trout fishery, recreation, water
quality, some riparian resources, and others. The Preferred Alternative, however, is
designed to help conserve endangered fish species and their habitat and to have the overall
effect of creating a more natural ecosystem.
Reclamation will commit to working with the resource agencies responsible for
management of particular resources to implement measures that would reduce adverse
impacts of implementing the Preferred Alternative. However, Reclamation is unwilling to
take the lead responsibility in terms of funding or implementation. Reclamation believes
that any mitigation measures that require funding and that are in response to implementing
the Preferred Alternative should be shared by all parties that benefit from implementation
of the Preferred Alternative. Environmental commitments and mitigation measures are
discussed in greater detail in chapter IV of the EIS.
General Comment 3: There is a need to emphasize that the No Action Alternative does
not maintain the status quo and is not a "legally permissible" alternative. The No Action
Alternative is not viable and has the most negative impacts of any alternative considered. It
would endanger existing and future water uses, lead to possible litigation and job loss,
interfere with Indian water right settlements, disrupt existing water deliveries, and
adversely affect the NIIP and the ALP Project.
Alternatively, many people recommended keeping the present minimum release level of
500 cubic feet per second (cfs).
Response: Under the No Action Alternative, the Flow Recommendations would not be
met. It is anticipated that this would require the Navajo Unit to undergo reconsultation
under the ESA, and other projects-existing private and Federal water projects and such
future projects as completion of the NIIP and the ALP Project-may also require new
consultation under the ESA. This would endanger present water uses and could complicate
the settlement of Indian Tribal/National water resources. Estimated loss of benefits-which
s
i