WSP00178

• File Number: 8220.105
• Description: Colorado River-Water Projects-Navajo
• State: CO
• Basin: Colorado Mainstem
• Water Division: 5
• Date: 12/2/2002
• Title: Re-Operation of Navajo Dam-Department of Water Resources Water Management Branch Comments on Navajo Reservoir Operations EIS
• Water Supply Pro - Doc Type: Report/Study

COMMENTS ON THE DEIS NAVAJO RESERVOIR OPERATIONS
Navajo Nation Department of Water Resources & Department of Justice
Page 5

accurate methodology may demonstrate that the consumptive uses are
1 owe r ,

Comment 8, Page 111-15, No Action Alternative, First Paragraph

The DEIS states that under the No Action Alternative, the
average reservoir elevations would generally be higher, As
presented. these higher reservoir elevations may be interpreted as
benefits of the No Action Alternatives; however, the primary reason
that reservoir levels are higher is the assumption that NIIP and
r, other authori zed water demands do not occur, The DEIS should
I.' distinguish between the impacts attributable to the flow
1\: recommendations as described under the Preferred Alternative. and
V. the impacts associ ated with the completion of NIIP and other
, authorized purposes,

Comment 9, Page II1-15, Last Paragraph & Page 1II-17, 5ee/5eee
Alternative, First Paragraph 6

The DEIS should elaborate on the risks to non-Indian water
rights and non-Indian water users under the No Action and the
~5BB/5BBB Alternatives, Costly litigation is one. almost certain
~ consequence, Uncertainty and disruption in existing water
I'deliveries are also possible, These disruptions have economic
~ consequences that should be described,

Comment 1e, Page II1-22, Table II1-]

Table 111-3 purports to include the San Juan River Basin water
uses, However, the existing Navajo Nation uses listed in this
table exclude the current municipal water use in the Shiprock area,
It also excludes the Navajo tributary irrigation. Navajo
evaporation from stock ponds and reservoirs. and groundwater used
for livestock and municipal purposes, Even if these uses are not
precisely quantified in the basin, they do occur and their omission
from Table 111-3 should be included in a footnote,

Comment 11, Page 111-25, First Paragraph

The DEIS states that it is not currently economically
.practicable. to construct pipelines and pump water to many
irrigation tracts or projects scattered throughout the Navajo
Indian Reservation, This phrase should be rewritten without the
word .practicable," That word may be construed to have legal
implications in future irrigation claims asserted for the Navajo
Nation, Although it may be true that there are many irrigation
tracts that cannot be economically irrigated directly from the San
Juan River. many irrigation tracts may be economically irrigated,
Furthermore. many of the San Juan River Basin tributary irrigation

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