WSP00178

• File Number: 8220.105
• Description: Colorado River-Water Projects-Navajo
• State: CO
• Basin: Colorado Mainstem
• Water Division: 5
• Date: 12/2/2002
• Title: Re-Operation of Navajo Dam-Department of Water Resources Water Management Branch Comments on Navajo Reservoir Operations EIS
• Water Supply Pro - Doc Type: Report/Study

COMMENTS ON THE DEIS NAVAJO RESERVOIR OPERATIONS
Navajo Nation Department of Water Resources & Department of Justice
Page 12

available to the City. The Navajo Dam unit provides less than 10
percent of the City's total available power capacity.

Comment 29. 111-75. Federal Energy Regulatory Commission (FERC)

The Ci ty' s FERC 1 i cense has less than 33 years left. The
!related agreement between Reclamation and the City of Farmington
l'cannot be considered permanent obligations. Moreover. the
Iconditions of that license clearly establish that power generation
is an opportunistic use - the City has no water right associated
with the generation of hydropower.

Comment 3e. 111-77. First Full Paragraph

With respect to possible damage to the hydropowerplant. the
DEIS states that "Subsequent investigation has revealed that a
design modification could help to alleviate the problem. The cost
for the modification and its ability to mitigate the damage is
,conservatively estimated at $75.000 to $100.000." Apparently this
, design modification can reduce the potential financial impact by $2
to $3 million per year. significantly reducing the impacts on the
City. This modification should be described in greater detail. To
, the extent that this modification is feasible, the references to
. .the $7 mill ion dollar impact should be clarified throughout the
text.

Comment 31. 111-78, Footnote 37

The replacement power costs cited here appear to be
inconsistent with the costs cited in the Appendix to the DEIS.

Comment 32. 111-79, Paragraph 2

The DEIS suggests that the financial impact of the 500/5000
Alternative on hydropower is approximately $3.2 million. The DEIs
r needs to distinguish between the impacts associated with the full
. development of the authorized water projects. including NIIP. and
1 the impacts associated specifically with the Flow Recommendations.
1'1 The City constructed this hydro-power unit with a full
I'understanding that someday NIIP and other project would be
I constructed. The impacts of to the City should only be based on
the net increase to the Ci ty above and beyond what was al ready
,j anticipated.

Comment 33. 111-111. Overview, Scope

The DEIS states that "Other counties are outside the above
scope may be negligibly affected. and as a result, have not been
included in this analysis of work." However. if the Preferred
Alternative were not implemented. there would be substantial

001::155