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Volume III - Comments and Responses FE1S - Navajo Reservoir Operations - In total, an estimated $4.0 to $10.0 million reduction in annual impacts at an annual cost of $6.5 million could be achieved if the Horn Canyon Pumping Plant and Pipeline were constructed and operated to allow a 500-cfs minimum release from Navajo Dam during the irrigation season. Under the concept of flexibility, this method of delivering water would not be used until full development occurs. At this time, Reclamation does not have the authorization or the funding to study this option. General Comment 9: More alternatives that meet the Flow Recommendations should be presented. Reclamation has confused RPA (reasonable alternatives) under the ESA and reasonable alternatives under NEPA. RPAs other than the Flow Recommendations could be derived, so long as the Flow Recommendations were substantially met. The Flow Recommendations are not binding on Reclamation, and they should be interpreted in the least damaging way. Response: Prior to public release of the DEIS, Reclamation modeled numerous hydrologic scenarios/ alternatives to determine if a release pattern other than the Flow Recommenda- tions (250/5000 cfs) would provide necessary spring peaks and minimum flows in the endangered fish critical habitat below Farmington while allowing for completion of the NIIP and ALP Project. However, no other alternatives were found that would meet the Flow Recommendations while maintaining the authorized purposes of the Navajo Unit, which include enabling future water development to proceed in the Basin in compliance with applicable laws, compacts, decrees, and Indian trust responsibilities. Reclamation not only has an obligation to protect endangered species but also an obligation to try to minimize adverse impacts on other resources while doing so. However, within the Flow Recommendations there exists some flexibility in reservoir releases until full development of NIIP and the ALP Project occurs because water committed for present or future development is not currently used. Under NEPA, Reclamation compares the impacts of reasonable alternatives that meet the need of a project and the No Action Alternative. These alternatives are different from a "reasonable and prudent alternative" under the ESA. A reasonable and prudent alternative is developed when it is determined that a proposed plan will jeopardize a threatened or endangered species. General Comment 10: Concerns were expressed that the goal of the Preferred Alternative is really to facilitate water development-completion of the ALP Project and NIIP and other water development-rather than endangered fish recovery. Political and/or development interests have driven the present process. The SJRBRIP Biology Committee is staffed by consultants of the major water user groups. The Preferred Alternative was s