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<br />COMMENTS ON THE DEIS NAVAJO RESERVOIR OPERATIONS <br />Navajo Nation Department of Water Resources & Department of Justice <br />Page 6 <br /> <br />projects are viable, Even without long pipelines, these tributary <br />tracts could readily utilize water that is tributary to the San <br />Juan River, <br /> <br />Comment 12, Page 111-26, Top Paragraph <br /> <br />The DEIS speculates that it will take ten years to complete <br />NIIP and that full irrigation would not be reached until 2032, The <br />DEIS should provide some justification for this schedule or perhaps <br />provide a range of schedules, Navajo Nation Department of Water <br />Resources opines that a block of NIIP should be fully functional <br />within five years of its completion, Perhaps the DEIS is intending <br />to describe the point in time when NIIP's return flows would reach <br />equilibrium, <br /> <br />Comment 13, Page 111-26, San Juan River Irrigation Projects <br /> <br />The reference to irrigation projects along the San Juan River <br />being initiated between 1900 and 1937 is generally true with <br />respect to non-Indian farming, However, Navajos have been <br />irrigating along the San Juan River prior to the first non-Indian <br />farmers. <br /> <br />(comment 14. Page 111-26, Paragraph #2 <br /> <br />. Contrary to the assertion that the Cudei Siphon is scheduled <br />, to be completed in 2002, the siphon is completed and was <br />~functioning during the 2002 irrigation season, <br /> <br />Comment 15, Page 111-35, ALP Project Construction <br /> <br />The DEIS calculates benefits from the Animas-La Plata Project <br />'water by projecting estimated annual revenue generated from "water <br />'sales," The range of these values is $68,57 to $600 per acre- <br />foot, The $68,57 per acre-foot value is the CRSP M&I rate for raw, <br />untreated water, This is not a market value for the water, The <br />CRSP rate is based on the federal rates for capital repayment, and <br />I for the CRSP operation and maintenance, The $600 value represents <br />the typical retail rates in the surrounding communities for treated <br />M&I water, Thus, the DEIS compares "apples" to "oranges," If the <br />DEI5 evaluation is based on a "market value" for raw water, <br />comparable benchmarks for long-term water leases in the basin <br />should be utilized, <br /> <br />However, the real benefit of the water supply should not be <br />measured by assuming that the water has value only as a commodity, <br />In the case of the Shiprock area, the 4,680 acre-feet of may water <br />may readily sustain a community with a population of 20,000 people, <br />Therefore, the real benefit of this water supply goes beyond the <br />market value of 4,680 acre-feet, Under the No Action Alternative, <br /> <br />DOl::!!,;) <br />