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Specific Comments In Chapter II, page II-II. line 376, there is a statement that there are no restrictions for the time ,,&'._1____ _~.~L_ _:_:__.._ __...I __..:_n_ C1____ __________...J_..:___ -rt..:~ _L_..LJ L_ _I~-=&:_...I...;..t. V11\;U;a;:)'i; VI LUI;; UUIUIlIUIU auu IJ1aAllUUUI llUW II;;LUIlUUli;UuaUVII;:), 1111;:) ;:)UUUIU Uo;; \,..11111U....U ""111.1 the flow recommendation document Holden (1999). There are specific time frames given for peak Bows and when those flows should occur and when Bows are ramped up and ramped down depending upon the magnitude of the release. The duration of those flows depends on the water year and the estimated volume ror the water year. That should be explained in the report to clarifY that there are restrictions on when the releases and the volume of releases are meant to occur from Navajo Dam. Chapter III. page III-15.line 481. there is a reference to '.acTUal conditions" causing lower flows than the 63 cfs measured during the summer low Bow test. This statement should be clarified. It is my understanding that the objective of the low flow test was to mimic "aCTUal conditions" during a 250 cfs release. It is unclear why the fuTUre volume in the river would be lower than that measured during a test. [f there were conditions immediately below the Citizens Ditch that resulted in elevated Bows, those should be explained in detail and also a calculation made as to what the aCTUal observed flow would be. This condition. ir Bows truly were elevated over what is to be expected. in the long term would seem to invalidate some of the results or the low flow test that were collected during the summer of 200 I. In the recreation section, in Chapter III, the impact indicator was a 10% decline in recreation activity as the threshold value to determine a significant impact. The discussion under the alternatives does not present changes in terms or percent change from existing or a reference condition. This reference value and percent change should be included in the EIS. Page IU-34, line 946 to the end of the page and on to page III-35, the conclusions under the fly- fishing impacts appear to be based on the resource specialist's speculation about what will occur in the long term, not on the data collected during the low flow test. There are a wide range of values of impacts reported although no data summarizing what was collected or what has been reported in terms of monetary value by outfitters and others in the previous years. That information is needed to determine what the magnitude of these losses would be under a low flow operation. This section would benefit from a dara table that compares a baseline condition with the condition observed during the low flow test. Table III-II has a 50% reduction in rafting impacts under the 250/5000 alternative. It is unclear how this 50% reduction was determined from the data presented. This is particularly important since, on page 3-36, line [037, it is noted that if the commercial companies contacted their clients to assure them that rafting on the San Juan River would be fine during the low flow test, the rafters continued with their trips. It was the majority of private rafters that cancelled trips during the low flow test based on their perception of what would occur. It appears that it was a lack of information regarding actual conditions that would occur in the rafting areas during the low flows rather than the actual conditions that occurred during low flows lliat caused cancellations. This would seem to have an effect on the long term as rafters become aware of change in operational flows out of Navajo, that there may be some change in river usage but it is not clear that there would be a 50% reduction in usage as shown in Table III-II. Comments on Navajo Reservoir Operations Preliminary Draft Environmental Impact Statement Miller Ecological Consultants, IDC Page :! December 18, 2001 00740