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. . Storage vs Yield Approaches September 25, 1990 Page 3 af being available at Navajo Reservoir in four out of ten years was developed by ignoring river conditions, much less fish needs. It could not have been developed based on fish needs since we have been told over and over again that the fish needs are not defined for the San Juan River Basin. The 300,000 af approach was developed with the premise that the peak flows are all important and the non-peak flows are not important. I believe it is in the best interests of water users in Colorado and New Mexico to find as 'permanent' an alternative to the draft jeopardy biological opinion as possible that lets water development continue. I find it difficult to believe that the US Fish and Wildlife Service (USFWS) would subscribe to a yield approach such as that just described for anything but a trial period. I strongly suspect that if the USBR alternative with a five year trial period of making the 300,000 af available from Navajo were implemented, the USFWS would be re-initiating consultations in five years saying they need more control over the hydrologic process in dry periods as well as the wet periods. Therefore, I feel it is in the best interest of water users to propose an approach which gives the greatest initial flexibility to the USFWS or a Recovery Plan and defuses future statements about how the water provided is not adequate for their needs. I believe the provision of storage rather than yield offers the best approach for a 'permanent' solution to the endangered fish problem. The fish biologist hired by the Southwestern District agrees that a storage approach rather than a yield approach stands to provide greater benefits to the endangered fish. New Mexico Control New Mexico is rightfully concerned about having the operation of Navajo Reservoir releases for the endangered fish interfere with New Mexico's ability to provide water entitled to it under its Colorado River Compact. I believe a storage approach rather than a yield approach provides a more definable situation for New Mexico and, therefore, one that should be preferable to New Mexico. With a storage approach, New Mexico would at any point in time know how much water it has available to it for its use. Under a yield approach, the USFWS or Recovery Plan could request a slug release of 300.000 af at any time Navajo Reservoir reached a certain contents. New Mexico would not know when those releases would be requested or at what rate. At current development levels, New Mexico would have the ability to direct how the water which is available for New Mexico's future development (approximately 300,000 a of reservoir firm yield) would be used (i.e. fish flows, power flows, etc.). ~ Leonard Rice Consulling Waler Engineers, Inc.