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Volume III - Comments and Responses <br />FEIS - Navajo Reservoir Operations <br />(c) The Flow Recommendations may not in fact lead to recovery of endangered <br />species and their habitat, and they could take place in an isolated, artificial <br />environment that could not be sustained except at great expense. Other <br />alternatives to the Flow Recommendations could be formulated that would be <br />equally effective in conserving the endangered species. <br />Response: There is no guarantee that the Flow Recommendations will lead to recovery of <br />the endangered fish in the San Juan River. Flow Recommendations are only one aspect of <br />the SJRBRIP; other aspects or elements of the program include providing fish passage <br />around migration barriers, control of non-native fish that compete with endangered fish, <br />and stocking of endangered fish. The program also includes an adaptive management <br />element. The response of the endangered fish and their habitat to new flow regimes will be <br />monitored by the SJRBRIP and flow regimes modified if determined necessary. <br />(d) There is no guarantee that the flows recommended would be protected from <br />intervening appropriators. <br />Response: Responsibilities of regulating diversions downstream from Navajo Dam he <br />with the New Mexico State Engineer's Office in New Mexico and the Navajo Nation <br />on Navajo Nation Lands. Authorized diversions are anticipated in the Flow <br />Recommendations; excessive diversions not authorized by the State of New Mexico <br />could hinder meeting the Flow Recommendations and thus the recovery of the fish. <br />(e) High releases may have caused the river channel to deepen, and they have not <br />contributed to the formation of sand bars, which aid in fish recovery. <br />Response: The effect of the high spring flows on habitat is being monitored by the <br />SJRBRIP. There are provisions in the SJRBRIP to adjust flows in reaction to habitat changes <br />(adaptive management); long-term monitoring will be needed to determine if desired effects <br />on habitat actually occur. <br />(f) Low releases result in an increased concentration of pollutants and may adversely <br />affect endangered fish in related ways. <br />Response: The SJRBRIP has studied, and continues to study, water quality in the <br />San Juan River. In the studies performed to date, it was concluded that "concentrations of <br />contaminants in biota inhabiting the mainstem of the San Juan River were not consistently <br />correlated with instream flow discharges. Therefore, incorporating a contaminant-related <br />component into the Flow Recommendations for recovery of San Juan River endangered fish <br />is not advised." (Environmental Contaminants in Aquatic Plants, Invertebrates, and Fishes <br />of the San Juan River Mainstem,1990-96, SJRBRIP). In a Program Evaluation Report (2000) <br />it was also stated, "The extensive information collected during the 7-year research period <br />• <br />• <br />i <br />• <br />• <br />i <br />• <br />• <br />• <br />• <br />• <br />• <br />• <br />• <br />• <br />• <br />• <br />• <br />• <br />• <br />• <br />i <br />• <br />• <br />• <br />• <br />• <br />i <br />• <br />i <br />i <br />• <br />• <br />• <br />• <br />• <br />i <br />• <br />i <br />•