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U~~.~~.~~~l l~;~~HM WHII:.R CONSULT NO. 077 P.3 '- . .-- Line 171. This sentence needs elaboration, it does not make sense standing on its own. Lille 172. It is not "applying these niles" that "would allow water development to proceed an average annual depletion in the basin to increase above the level set in the 1991 biological opinion , .." This implies, quite incolTeCt\y, that ifthesc m1es are not met as written that there will be no ii"l\4t"4~ ill iJ,vQ'igC IWnwU ucpiciions. This \5 not me cue. T~ mgo.w1;iluon af!~aVBjo Dml operations to meet the flow recommendations "or !!Ome reasollllblc alternative thereto" plus other actions taken by the Recovery Program will provide ESA compliance for existing and future depletions_ There is no ironclad rule that the flow recommendations have to be met in order to increase depletion levels in the San Juan basin. I Line 290-291. A statement" . ' .this ErS is designed to accommodllle as many of these over-lapping terms as possible," and then references severa1 federal laws and Clt8Cutive orders. This appears to be saying that you are going to comply with as many of these federal laws and Cltccutive orders "as possible." Is Reclamation complying Of !lot? This needs to be restated. Chapter II. Proposed Action Alternatives. Line 31. Rewrite the sentence as follows: "The Implementation Program will monitor endangered fish populations and their habitats, and use the adaptive management process to recommend any modifications to the flow recommendations." Line B2. Pursuant to the agreement in the discussion at the November 28-29 meeting, the alternative entitled "de-commission Navajo Dam" has been deleted. Line 98. Add the underlined phrase "This includes, but is not limited to. , . ." Line 1 05. Delete" As a typical water supply project_" Lines 120-129. Delete the line "By retUrning designated critical habitat in the San Juan River to a more natural condition." . . The itc:ms listed beginning on line 129 are, according to lines 124 through 126 "Objectives for identilYing and analyzing the action alternatives." TiuI criteria for analyzing the action alternatives do not include the general objective of "support the gea1& of the San Juan River Basin Recovery Implementation Program" other than meeting the tlowrecommendations "or a reasonable alternative thereto." Then:fore, the paragraph on line 129 is not an objective that was used to identify and analyze action alternatives, other than as expressed in the flow recommendations "or reasonable alternative thereto." Clarification is needed. ..: , .' Line 137. Meeting the S.JRn> flow recommendations is a subset of supporting the goals of the San Juan River Basin Recovery Implementation Program. Line 145. It is not clear in the discussion ofany of the alternatives how this objective was used in evaluating the alternatives, i.e_, "follow flood control procedures. _ ." 2 OOf;97