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<br />COMMENTS ON THE DEIS NAVAJO RESERVOIR OPERATIONS <br />Navajo Nation Department of Water Resources & Department of Justice <br />Page 3 <br /> <br />I' develop reasonable alternatives is very important and that point <br />chnlllrl he nr'lt-cri 0.1 cQI.,horo ;n t-ht:lo rlnrllmpnt <br />r ............. I..... ......... ".... ............ ........... ...."-.... ... ........ ....... __"'_0. - . <br /> <br />PROPOSED ACTION AND ALTERNATIVES <br /> <br />~ <br /> <br />Comment 1, Page II-1e, First Paragraph <br /> <br />The DEIS recognizes that the largest water projects will not <br />be completed and operational for several years, For instance. <br />Reclamation speculates on Page 111-26 that it will take ten years <br />to complete NIIP and that full irrigation would not be reached <br />until 2032, Consequently. there is an interim period during which <br />flexibil ity may exist to provide supplemental flows for various <br />purposes, However, the impacts presented in this document are <br />based on the presumption that the onset of all of these impacts <br />will occur immediately, This interim period will provide the <br />opportunity to adaptively manage the resources and mitigate <br />impacts, During this interim period a positive biological response <br />may result in the development of other reasonable alternatives, <br />Thus, the adverse impacts that may occur from dam operations under <br />the preferred alternative tend to be overstated throughout the <br />document, <br /> <br />Comment 2, Page 11-12, Paragraph 6 <br /> <br />Reference is made to Reclamation's contractual obligations <br />with the City of Farmington, The DEIS should also describe the <br />~ limits of those contractual obligations. for instance. the limited <br />duration of the related FERC license, The DEIS should also clarify <br />potentially conflicting obligations to the Navajo Reservoir water <br />contractors, <br /> <br />Comment 3, Page 11-17, Figure 11-3, <br /> <br />This figure indicates that the mlnlmum elevation of active <br />storage at Navajo Reservoir is 5,985 feet, However. Reclamation <br />has previously opined that at elevations below 5.990 feet the NIIP <br />, intake may be severely damaged, If 5.985 feet is to be evaluated <br />~.,as the minimum elevation of active storage the DEIS should describe <br />, the hydraulic impacts to the NIIP inlet works with flows at water <br />levels below 5.990 feet, <br /> <br />Comment 4, Page 11-18, Table II-4 <br /> <br />The note below the table indicates that with the 500/5000 <br />Alternative the reservoi r is occasionally drawn below the NIIP <br />inlet, As the water demands have been mOdeled by Reclamation, this <br /> <br />OOU.iS <br />