ALP 3

November 19, 2012
Ryan Christianson
Bureau of Reclamation
185 Suttle Street
Durango, CO 81303
Dear Mr. Christianson,
Thank you for the opportunity to comment on the September 2012 draft of
Reclamation's Technical Memorandum No. 86- 68290 -12 -01 on the RBD Sleeve
Valve Passage Analysis of Nonnative Fish (the "Memo "). The San Juan Water
Commission ( "Commission ") has the following comments and concerns on the
Memo:
Page 1, last paragraph: The reservoir will be operated in the range of
6,828 feet, which is 54 feet below a full reservoir. The Memo states that fish
survival was "statistically significantly reduced" at this elevation, and that non-
native rainbow trout embryos survived. This finding could create significant
challenges if rainbow trout and other non - native fish are stocked, given the need
to meet Conservation measure number 5 (page 2). Reclamation states (at 2)
that the plan to stop escapement was based on the sleeve valve, but testing now
has shown that the sleeve valve does not effectively destroy rainbow trout
embryos. If Reclamation determines that additional measures are needed, who
will be responsible for their design, operation, monitoring and maintenance? The
Commission supports the conservation measure, but it should not be responsible
for funding or providing the manpower to deploy any additional plan, if needed.
That clearly is a mitigation cost for which Reclamation is responsible. Also, ALP
Project operations should not be subject to modification based on the need to
ensure that non - native fish do not escape. The Commission spent millions of
dollars to pay for its portion of the project, and the ALP OM &R Association needs
the maximum amount of flexibility possible in operations to serve ALP
beneficiaries, including the population of San Juan County, N.M.
Page 4: The reference to "1968 Animas -La Plata Project' probably should
be the "1986" project. The maximum pumping capacity noted in the second
paragraph and on page 5 should be referred to as "approximately 280 cfs"
because actual capacity is somewhat higher and has not been fully tested.
Page 69, Recommendations: The Commission agrees with the
recommendation to not stock non - native game fish that can negatively impact