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<br />COMMENTS ON THE DEIS NAVAJO RESERVOIR OPERATIONS <br />Navajo Nation Department of Water Resources & Department of Justice <br />Page 9 <br /> <br />Comment 22, Page III-53, Fourth Full Paragraph <br /> <br />The DEIS projects reductions in trout habitat of 38 to 37 <br />nprrpnt ~nin~ frnm ~AA tn )~A rf, rplp~,p,' hnwpvpr thi5 <br />, -. - -.. - 0 - . . . 0 . . - ... - - - - - - - - - . - . - - - -. - - - I .. - .. - - -. . <br />conclusion does not appear to be well documented, Since the DEIS <br />considers this "to be significant adverse impacts," a better <br />j explanation should be included, Even if such a reduction would <br />,occur, the DEIS neglects to describe how the current trout habit <br />J cannot be sustained in the future, Since the Preferred Alternative <br />~ is the only alternative consistent with the Flow Recommendations. <br />J. all other operational scenarios jeopardize the survival of the <br />h endangered fish, Thus the DEIS analysis of the impact on the trout <br />fishery is fundamentally flawed and overstated, <br /> <br />Comment 23, Page 111-67, 258/5888 Alternative (Preferred <br />Alternative) <br /> <br />The DEIS suggests that the 258/5888 Preferred Alternative <br />would have a "moderate" impact on the reservoir recreation, The <br />DEIS estimates that the average reservoi r reduction would be <br />approximately 18 feet, and during infrequent dry periods as much as <br />38 feet, These levels are still above the existing concrete boat <br />ramp, One might just as readily conclude that the associated <br />impacts are minor, <br /> <br />~ The DEIS needs to distinguish between the impacts associated <br />with the full development of Reservoir's authorized purposes. <br />including NIIP. and the impacts associated specifically with the <br />I Flow Recommendations and the Preferred Alternative, <br /> <br />Comment 24, Page 111-68, River Recreation <br /> <br />In this section the DEIS should reemphasize that. until the <br />full authorized project depletions occur, there will be operational <br />flexibility that may enable Reclamation to augment some periods of <br />low flows, The DEIS should quantify the apparent durations of the <br />various flows, For instance, from the figures provided by <br />Reclamation. it appears that the lowest flows that are close to 258 <br />cfs occur only during January and February, During July. August. <br />September and October the flows are closer to 588 cfs than 258 cfs, <br />~ During March. April. May. and June the flows exceed 588 cfs, <br />Thus. the projected adverse impacts to river recreation are <br />overstated in the DEIS, <br /> <br />Comment 25, <br /> <br />The DEI S <br />be reduced 38 <br />258 cfs, As <br />justification <br /> <br />Page 111-69, Bottom of Page <br /> <br />reiterates the expectation that trout habitat would <br />to 37 percent when flows are reduced from 588 cfs to <br />stated above. the DEIS does not provide sufficient <br />for this conclusion, <br /> <br />001352 <br />