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COMMENTS ON THE DEIS NAVAJO RESERVOIR OPERATIONS Navajo Nation Oepartment of Water Resources & Department of Justice Page 4 level is only reached during the non-irrigation season, However, the DEIS should describe the consequences of dropping below th~ minimum inlet level during the irrigation season, NIIP's annual gross crop value, which exceeds $30 million, may be at increased risk, In addition, the water contractors that share shortages with NIIP may also be impacted, Comment S, Page 11-22, No Action Alternative, Second Paragraph ~ Under the No Action Alternative the completion of the Animas- La Plata Project and the settlement with the Ute tribes is at risk, As noted in the comments concerning the Executive Summary, the DEIS should expl icitly note that this risk also extends to the Navajo Nation Municipal Pipeline that will convey more than 4,000 acre-feet of water to Shiprock, New Mexico. The No Action Alternative may limit the Navajo Indian Irrigation Project (NIIP) to 54,500 acres, The No Action A lte rnat i ve may a 1 so j eopa rd i ze the proposed $ 70 mi 11 i on potato processing plant and its related industry which will employ more than 400 people, The Navajo Nation has successfully consulted on 450 acre-feet of annual water depletion for this processing plant, This depletion would also be at risk, Comment 6, Page II-Jf3, Table 11-9 For the hydro power resource the DEIS states that with the Preferred Alternative the City of Farmington's annual replacement cost is up to $7 million, This impact is based on taking the unit out of service during the duration of the Low Flow Period. However, because much of this impact can be readily mitigated, the likelihood of the impact reaching $7 million is remote, The hydro power impact for the preferred 250/500 Alternative should include the impact that is most likely, and the $7 million impact should be ~ placed into the appropriate context, Furthermore, the DEIS does 'W.1i I) not distinguish between the impacts due and the Flow )\'.... I, Recommendations and the impacts due to the full development of ~ ) water supplies out of Navajo Reservoir, AFFECTED ENVIRONMENT/ENVIRONMENTAL CONSEQUENCES Comment 7, Page 111-11, Penultimate Paragraph The DEIS states that the total consumptive use in the Upper Basin in Arizona is about 45,000 acre-feet per year, The Navajo Nation Department of Water Resources has questioned Reclamation's consumptive use and loss methodology and anticipates that a more OOUO