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" COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT NAVAJO RESERVOIR OPERATIONS NAVAJO UNIT - SAN JUAN RIVER, NEW MEXICO, COLORADO, UTAH () Prepared by The Department of Water Resources. Water Management Branch & The Department of Justice. Natural Resources Unit The Navajo Nation December 2. 2002 GENERAL COMMENTS Although Reclamation reached the correct conclusion with respect to the selection of the preferred alternative. Reclamation undervalued the negative impacts of the No Action Alternative (Historic Operation) and the 500/5000 Alternative. and over valued the likely negative impacts of the 250/500 Preferred Alternative, The preferred alternative is the only scenario that is consistent with the flow recommendations promulgated by the 5an Juan River Recovery Implementation Program, Under all the other alternatives, those water uses that are subject to Section 7 of the Endangered Species Act (ESA) would be forced to reinitiate consultation with the U,S, Fish & Wildlife Service, and the Service would likely opi ne that those uses j eopardi ze the conti nued exi stence of the endangered fi sh or damage the eriti cal habitat, Moreover. all other water uses could conceivably be enjoined or curtailed if found to be in violation of Section 9 of the ESA ("take" of endangered species), The Final Environmental Impact Statement should clarify that 'adoption of the No Action Alternative would not result in Jcontinuation of the status quo because the status quo cannot be 1 maintained without violating the ESA, The Service previously opined in its Biological Opinion for the Animas-La Plata Project that even without further water development, the endangered fish would be extirpated from the San Juan River without implementation 0013H