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COMMENTS ON THE DEIS NAVAJO RESERVOIR OPERATIONS Navajo Nation Department of Water Resources & Department of Justice Page 14 for Blocks 1 through 8 did not require reoperation of Navajo Dam: however, that biological opinion was issued after the October 25. 1991 bi ologi cal opi ni on for ALP that requi red Navaj 0 Dam to be operated consistent with the flows that would be determined as a result of the seven-year research program as to the flow requirements for the endangered fish. The Service has never opined that reoperation of Navajo Dam is necessary for the development of NIIP through Block 8: however. it is likely that the Service would request that consultation be reinitiated pursuant to 50 CFR S 402.16 if Navajo Dam were not operated consi stent wi th the Flow Recommendations. Thus, the DEIs understates the potential adverse impacts on NIIP if the No Action Alternative were implemented. Comment 36. 111-122. Jicarilla Apache Nation Third-party Contract wi th PNI1 The IMPLAN model should include the impacts of losing the water supply to the San Juan Generating Station and the mines. It should also include the impacts at TeePee Junction if that area is not able to receive water from the Navajo-Gallup Water Supply Project. Comment 37. 111-123 Bottom Paragraph through 111-124 The DEIs assumes a linear correlation between recreation and trout habitat. Given the sensitivity of the results based on this assumption. the DEIs should include greater justification. For instance, much of the habitat loss will only be temporary in nature during periods of low flows. The DEIs's assumed relationship should be modified based on the short duration of the low flows. Comment 38. 111-125. Second Paragraph The DEIs's assumption regarding the impacts on recreation and trout habitat manifests itself in the results on Page III-I25. The DEIs does not provide a readily defensible relationship to support the contention that there would be a 10 to 34 percent loss in out- of-state anglers. Comment 39. 111-127. First Paragraph Reclamation's IMPLAN model suggests NIIP would employ 921 employees. However, with vertical integration NIIP will generate thousands of jobs. The potato processing complex alone would generate more than 400 jobs. For San Juan County. the IMPLAN model should also include the economic benefits associated with the economic development associated with the Farmington to shiprock pipeline. 00135'7