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<br />MILLER <br />EC()L()GrC.\.l <br />U)NSUTANTS <br />1M:. ;...,.-- ';:',f'; <br /> <br />MEMORANDUM <br /> <br />December 18, 200 I <br /> <br />TO: Cathy Condon; Greene, Meyer & McElroy <br /> <br />From: Bill Miller, Miller Ecological Consultants. Inc <br /> <br />Subject: Comments on Navajo Reservoir Operations Preliminary Draft Environmental Impact <br />Statement <br /> <br />General Comments <br /> <br />The docwnent has several instances in several different resource categories where conclusions <br />are not supported by the data as presented but on the perception of the resource specialist. The <br />conclusions should be based on the data available rather than a hypothesis created during the <br />analysis. In several cases this speculation results in a very large impact to the resource when the <br />data presented shows that the impact would be below the significance criteria set for the resource <br />category, and therefore not a significant impact to the particular resource. These corrections <br />should be made to the docwnent. <br /> <br />The docwnent would benefit from a consistent representation by river mile of locations of <br />significant features. This is particularly true for landmarks referenced in the recreation and the <br />fisheries sections. There are discrepancies within those two that result in changes in reach <br />lengths of nearly 40% between the two disciplines, A consistent analysis basis where feasible <br />and where practical would be beneficial to the document. An example of this is in the discussion <br />of the fly-fishing quality trout water near Navajo Dam. The aquatic resources section states that <br />Texas Hole, a landmark within that area, is approximately 2 miles downstream and based on data <br />presented in Reclamation (1998), that landmark is 1.3 miles downstream fr?m the dam. I would <br />recommend that the miles listed in Reclamation (1998) be verified and used in the EIS. <br /> <br />Comments on Navajo Reservoir Operations <br />Preliminary Draft Environmental Impact Statement <br />Miller Ecological Consultants, IDc <br /> <br />Page I <br /> <br />December 18, 2001 <br /> <br />00739 <br />