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COMMENTS ON THE DEIS NAVAJO RESERVOIR OPERATIONS Navajo Nation Department of Water Resources & Department of Justice Page 11 Comment 26. Page III-7e, First Full Paragraph The DEIS assumes that the economic losses would be directly ..rCll~+orl +1'"'1 rh""nn'oC' ;n c+r.Cl":lom C'llrT":Ioro. ':IrQ::lo nr r1;rort'l\l rpl~tprl tn TI''-L...........''-'I ","v ....,I....,'b....~ '" ........,........." .......,.......... ..........., .... .......--....J ._~---_. -- Ii the apparent changes in t rout habitat. Thi s assumpt i on may ~ inadvertently result in over estimating the Flow Recommendation's :\impact on the angler days. The relationship between angler days : and surface area needs to be better justified. Comment 27. Page 111-73, Hydro Power Overview, Summary of Impacts The DEIS suggests that the projected I0-year financial impact to the City of Farmington ranges from $5.3 to $7 million annually for lost power revenues. The $7 million dollar value is based on taking the unit out of service during the low flow period. It is possible that some of these losses can be offset by utilizing some the operational flexibility that exists until the full authorized project depletions occur. Thus, Reclamation may be able to augment dam releases during some periods of low flows. Moreover, Table 11- 4 indicates that during much of the low flow period, the flows are much closer to 500 cfs than 250 cfs. The units will be able to operate more frequently than Reclamation estimates: consequently, the DEI5 overstates the power revenue impacts to the Ci ty. In (\ addition, for reasons discussed at Comment 30 below, the total '/ annual lost power revenues should never approach $7 million if a . relatively modest sum of money were spent on retrofitting the ~ turbines. thereby mitigating the potential loss. Once again. the DEIS should draw a distinction between the impacts associ ated wi th full development the authori zed water projects. including NIIP, and the impacts associated specifically with the Flow Recommendations. The City of Farmington constructed this hydro power unit with a full knowledge that eventually the authorized purposes including NIIP would be developed. Comment 28. 111-74. Affected Environment The impacts of the lost hydro-power under the Preferred Alternative need to be compared to lost power generation that will be foregone if NIIP remains uncompleted. As discussed above, if NIIP development is limited to 54,500 acres, the opportunity for vertical integration may be lost such as the construction of a 25- MW steam co-generation unit associated with the potato processing plant. The DEIS does not consider this lost power, thus undervaluing the benefits of the Preferred Alternative and overvaluing the adverse impacts on the affected environment from the Preferred Alternative. To put the impacts to the City of Farmington into perspective. the DEIS should describe the total power generating capacity 001::154