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COMMENTS ON THE DEIS NAVAJO RESERVOIR OPERATIONS Navajo Nation Department of Water Resources & Department of Justice Page 16 Service would likely require reoperation of Navajo Dam for the benefit of endangered fish. Comment 44. 111-139. 25e/5eee Alternative (Preferred Alternative) (Flow Recommendations). Fourth Paragraph The statement that the 250/5000 Alternative "provides a more natural hydrograph than does the No Action Alternative, and thus would be expected to benefit the fish" is an understatement. The Service has already opined that without reoperation of Navajo Dam. the fish will be extirpated from the river. Thus. under the No Action Alternative, the fish will eventually be extirpated. Comment 45. 111-144, Navajo Reservoir. No Action Alternative & San Juan River. No Action Alternative As discussed above, the No Action Alternative cannot be sustained without causing jeopardy to endangered fish. Thus. the conditions described in this section for reservoir levels and river flows are unlikely to be sustained. Comment 46. 111-144. Navajo Reservoir. 5ee/5eee Alternative & 111- 144 through 146. San Juan River. 5ee/5eee Alternative Nor does the 500/5000 Alternative satisfy the Flow Recommendation. Thus. this alternative is not likely to pass legal muster under the EsA. Thus, the conditions described in this section for reservoir levels and river flows are unlikely to be sustained. Comment 47. III-154, CULTURAL RESOURCES. Impacts Analysis. No Action Alternative Again, the DEIs assumes that the No Action Alternative can be sustained. In this case. the DEIs states that "the No Action Alternative would result in net impacts similar to those experienced from 1973-1991." Based on that assumption, the DEIs states that "water releases under this alternative would not result in levels as low as those identified under the action alternatives." However, as discussed at Comment 43 above, in 1990, the Fish & Wildlife Service opined that under the conditions existing at that time. the endangered fish were likely to be extirpated from the San Juan River. Thus, it does not appear likely that the No Action Alternative can be sustained. Under these circumstances. it is unclear what the water release patterns may be. The Service could requi re dam releases to mimic the natural hydrograph or for the dam to be removed entirely. In any event, water releases will be lower than the 1973-1991 levels. In short. the 1973-1991 conditions are not sustainable: therefore, the UU1<lJ;,)