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Aquatic resources. page II1-74, line 2058. the stated 25% reduction in habitat below Navajo Dam is incorrect. There is a 14% reduction in trout habitat below Navajo Dam as the data in 0""...1.............;........ {I""Q\ ~............. 'T'l..;.. ...\........IA L....... ........_0.....""..:1 ~.........U.L1I1U.UUll \.L /,/'-'/ ,]~u.L\,.~. .L.1II" "uvu.~.... v... ""V.L.L......~........ Page I1I-78, data for concentrations of pollutants should be presented to substantiate the conclusions regarding the effect of change in concentration level with change in flow. Information presented during the summer low now test. the seven years of research on the San Juan River, and other studies associated with water quality in these areas do not show significant impacts in several of the constituents mentioned in the fishery section. These should be consistent throughout the document in both the water quality section and the fishery section. If data does not exist for a panicular constituent such as PAH, then that information should be deleted from the E[S unless there is a value for an existing level of that constituent. Specitic studies under the 7 years of research for the San Juan River did not find problems with P AH values in the system. Fish abundance data for fish mentioned on page 1lI- 78 as common, such as common carp. channel cattish. and white suckers, should be presented in the document. Existing data sources for San Juan monitoring data and also New Mexico Game and Fish data do not show channel catfish as common from the Hammond Diversion to the Animas River. There are occasional captures but this should be noted as an occasional rather than common. Page 111-78, line 2[87 to the bonom of the page, there is a discussion of the San Juan River from Animas River to Lake Powell. This discussion should be rewritten to include a discussion of the aquatic species rather than as a discussion of the San Juan Seven Year Research program and other studies conducted as part of the endangered species consultations. Those discussions, if peninent. should be added to the "species of special concem" section. This section should focus on the species that may be affected by the re-operation rather than a discussion of ongoing studies for the sections of river. Page I1I-81. Line 2303 on to page U1-82, lines 2343. The impact of the change from 500 cfs to 250 cfs is not a 24% loss of trout habitat as noted in this section. There is a reduction in trout habitat for the quality water section of 4 miles at 14%. There is a 24% loss of adult trout habitat from the darn to Texas Hole, a 1.3 mile section of river. There is a 1% increase in habitat from Texas Hole to Archuleta. These data are all presented in Reclamation (1998). There is speculation about a decrease in population numbers, how long that would occur and what that proportion would be. It should be noted in the EIS that the trout population within this section of river is supported mainly by stocking from New Mexico Game and Fish hatcheries. That stocking is the main factor that keeps the trout population at its current level. Impacts should include a discussion of the management directives and management plan for this section of river from New Mexico Game and Fish and how that river is managed to maintain a quality fishery for the fly fishermen. Based on Reclamation (1998), it appears that the data presented on this page should be corrected to reflect the predicted changes in trout habitat with change in flow. Also it should be noted that there was a 5% reduction in wetted area for the reach as compared to the higher reduction in Comments on Navajo Reservoir Operations PreUminary Draft Environmental Impact Statement Miller Ecological Consultants, Ine Page 3 December 18, 200 I 00741