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<br />of the reasonable and prudent alternative. which included <br />reoperation of Navajo Dam, Since neither the status quo nor any <br />scenario arising from any of the alternatives other than the <br />\, preferred alternative. are legally permissible, none of the <br />benefits that could theoreticallv accrue from tho~p ~ltprnatives <br />\ can actual Iv be realized, <br /> <br />SPECIFIC COMMENTS <br /> <br />The following specific comments refer to specific portions of the <br />Draft Environmental Impact Statement (DEIS), <br /> <br />EXECUTIVE SUMMARY <br /> <br />Comment 1, Page S-ll, Second, Third & Fourth Paragraphs <br /> <br />The DEIS correctly concludes that the No Action Alternative <br />would put the completion of the Animas-La Plata Project (ALP) is at <br />risk, However. because this project also includes the Navajo <br />Nation MuniCipal Pipeline, Reclamation should explicitly note that <br />this risk extends to this component, The community of Shiprock, <br />New Mexico is the largest community on the Navajo Nation, Water <br />lfrom ALP is critical to meet the current and future water needs of <br />this community, The DEIS does not fully evaluate the impacts to <br />the Shiprock Community if ALP is not completed, <br /> <br />The DEIS also concludes that the No Action Alternative may <br />limit the Navajo Indian Irrigation Project (NIIP) to 54,500 acres, <br />However, Reclamation undervalues the impact by limiting its <br />analysis to lost crop revenues, A larger NIIP allows for vertical <br />integration which would provide benefits far greater than just the <br />gross crop revenues, By limiting the acreage of NIIP, the No <br />Action Alternative would also jeopardize the proposed $70 million <br />potato processing plant, $20 million in the growing venture's <br />storage buildings, a 40,000-head feed lot, and a 25-MW steam co- <br />generation plant, This complex alone will employ more than 400 <br />people, The Navajo Nation has successfully consulted on 450 acre- <br />feet of annual water depletions for this processing plant, This <br />depletion is also at risk, <br /> <br />INTRODUCTION: PURPOSE OF AND NEED FOR THE ACTION <br /> <br />Comment 1. Page 1-1, First Paragraph <br /> <br />Reclamation clearly states its intention "to operate Navajo <br />Dam and Reservoir to implement Endangered Species Act (ESA)-related <br />flow recommendations on the San Juan River, or a reasonable <br />alternative," (Emphasis added,) The potential opportunity to <br /> <br />0111345 <br />