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COMMENTS ON THE DEIS NAVAJO RESERVOIR OPERATIONS Navajo Nation Department of Water Resources & Department of Justice Page IS Comment 4e. 111-127. 5ee/5eee Alternative. Agriculture The potential impact to NIIP under the 500/5000 Alternative is nn+.o.n+;""llll (Tro",,+-o.r +h"",., t-ho lnC'C' nT f:l:lf"\rvc Q 1(,\ ':]nn 11 thAt :::lrp t"..........II.............] b'..............' .."...." ...".... ................, ...............n... ""'. ....... ............... .....-- -..- at risk. The discussion at Comment 35 concerning the No Action Alternative may be equally apposite here. We do not know with any certainty how much development would be permitted at NIIP if the Flow Recommendations are not implemented under the No Action Alternative. or if the 500/5000 Alternative were implemented, which does not satisfy the requirement under the ALP Biological Opinion to operate Navajo Dam in a manner consistent with the Flow Recommendations. Moreover, even if the Dam is operated consistent with the Flow Recommendations, if the endangered fish fail to show a positive biological response, consultation may be reinitiated. ~ Clearly. the Preferred Alternative provides the best chance for ~ completion of NIIP. and any alternative that does not meet the Flow "Recommendations puts water development for the Navajo Nation, and ~ all other entities. at greater risk. Comment 41. 111-128. Top of the Page The DEIs does not present any quanti fied impact associ ated wi th the i nabi 1 i ty to complete the ALP Proj ect. These impacts should not remai n unspeci fi ed. In the ALP Envi ronmental Impact Statement, Reclamation has prepared very specific estimates of the !\'benefi ts associ ated wi th the 57,100 acre-feet per year of ALP depletions. These quantified benefits should be described in this : document. Comment 42. 111-129. Hydro-power This section should be modified consistent with the discussion at Comment 27. above. Comment 43. 111-137. No Action Alternative The DEIs characterizes the No Action Alternative with the following: "Under the No Action Alternative, river conditions would be similar to those that occurred from 1973-1991. and riparian habitat conditions would remain similar to those that presently occur." For reasons stated at Comment 35, it is unclear what the river conditions would be under the No Action Alternative. The Service opined in the May 7. 1990 Draft Biological Opinion for ALP that the conditions on the San Juan River were already at the point where the fish would be extirpated from the river. Thus, even under the No Action Alternative. it is impossible to say with any certainty what the river conditions would be 1 ike because the 001::158