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COMMENTS ON THE DEIS NAVAJO RESERVOIR OPERATIONS Navajo Nation Department of Water Resources & Department of Justice Page 13 impacts on water users outside the counties identified in this section. For example, the users of water from the San Juan-Chama Project are dependent on the implementation of the Flow Recommendations in order for that project to satisfy the requirements of the EsA. Likewise. there are significant impacts to potential users of ALP water outside of the counties identified in the Scope. Without implementation of the Flow Recommendations, there is no chance that the Navajo-Gallup Water Supply Project can be built. thus. adversely affecting McKinley County in New Mexico. An IMPLAN model should be conducted that reflects the foregone economi c benefi ts due to the i nabi 1 i ty to provi de these water supplies. The impacts of the No Action Alternative clearly affect the economies of McKinley and La Plata Counties. These impacts include the inability to proceed with planned projects, and the unpredictable outcome of lawsuits and litigation. Comment 34. 111-112 through 122. San Juan County The analysis of impacts on San Juan County does not include impacts attributable to the loss of M&I water from the Farmington- to-shiprock Pipeline if ALP is not constructed or the loss of water from the Navajo Gallup Water Supply Project. Nor is any analysis provided concerning the possible closure of the San Juan Generating Station and its associated mines. Comment 35. 11I-12e and 121, Impacts Analysis The No Action Alternative may limit the Navajo Indian Irrigation Project (NIIP) to 54.500 acres. Vertical integration is critical to the success of NIIP and its benefits are far greater than just the gross crop revenues. In addition to these lost NIIP benefits. the No Action Alternative would also jeopardize the proposed $70 million potato processing plant, $20 million in the growing venture for storage buildings and equipment. a 40,000-head feed lot, and a 25-MW steam co-generation plant. This complex alone will employ more than 400 people. The IMPLAN model should explicitly include these components and others for a vertically integrated NIIP. Moreover. the DEIs should not assume that Blocks 1 through 8 1are protected under the No Action Alternative. As stated \;, throughout these comments, it is unclear whether any of the ~existing uses could continue under the No Action Alternative. The Service has never guaranteed that, in the absence of reoperation of Navajo Dam, NIIP could be developed through Block 8 in accordance wi th the requi rements of the EsA. The Reasonable and Prudent Alternative identified in the October 28, 1991 Biological Opinion 001356