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Volume III - Comments and Responses <br />FEIS - Navajo Reservoir Operations <br />(b) The environmental baseline leaves out projects with unexercised but adjudicated <br />senior rights and is otherwise inconsistent. <br />Response: Reclamation has included existing projects and planned projects with ESA <br />compliance in the baseline. There may be inconsistencies in the determination of baseline <br />depletions, but these are based on the nature of the depletion (i.e., legislated depletions for <br />NIIP versus unajudicated water rights for the Navajo Nations Hogback and Fruitland <br />Projects) or on ways in which the States of Colorado and New Mexico have identified their <br />rights. <br />(c) The hydrology model supplies water for baseline depletions that exceed actual <br />current and anticipated future depletions. <br />Response: The hydrologic model included all current depletions, all depletions that <br />could occur without further Federal action, and all other projects with completed ESA <br />consultations. <br />General Comment 22: A more thorough Summer Low Flow Test needs to be completed <br />prior to completion of the EIS. The summer test was too short and occurred during a period <br />of significant rainfall and during haying when water demands were low, and, thus, the <br />effects were moderated. <br />Response: A Summer Low Flow Test was conducted by Reclamation from July 9-15, 2001. <br />The purpose of this test was to assess the effect of low summer riverflows on various <br />resources. This test, along with results of the 1996-97 Winter Flow Test (Reclamation, 1998), <br />provided data to be considered during preparation of the EIS. <br />The 7-day test period allowed for physical changes to be observed and extrapolated to <br />approximate long-term conditions. A shorter length of time would not have permitted the <br />river to reach equilibrium after flow changes were initiated, and a lengthier period could <br />have resulted in significant impacts to affected resources. <br />The Summer Low Flow Test provided enough information to analyze impacts for the DEIS, <br />and Reclamation believes no significant new data would be derived by conducting another <br />low flow test prior to finalization of the DEIS. <br />Reclamation recognizes that potential limitations of the Summer Low Flow Test included <br />the following: its duration, the unpredictability of riverbank storage, sporadic localized <br />rainfall that augmented riverflows, mechanical equipment limitations preventing the release <br />of exactly 250 cfs, and lower rates of water diversion than anticipated. These limitations <br />were taken into consideration when the impacts were analyzed and extrapolated in the EIS. <br />