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BACKGROUND On August 6, 1991, the Service issued an updated Recovery Plan for the Colorado pikeminnow that identified the San Juan River from Farmington, New Mexico to Lake Powell as a recovery area. The Service issued a final biological opinion for the Animas-LaPlata Project' in 1991 with a reasonable and prudent alternative that included: seven years of research to determine endangered fish habitat needs in the San Juan; operation of Navajo to provide water for a wide range of flow conditions for the endangered fish; a guarantee that the Navajo Reservoir would be operated to mimic a natural hydro graph and such operation would be based on research; legal protection for the reservoir releases to and through the endangered fish habitat to Lake Powell; and a commitment to develop and implement a Recovery Implementation Program for the San Juan River (SJRBRIP). As a result of this opinion, the SJRBRIP was formulated in 1992 (Service, 2000). The SJRBRIP was established to protect and recover Colorado pikeminnow and razorback sucker in the San Juan Basin while water development proceeds in compliance with applicable Federal and State laws, including fulfillment of Federal trust responsibilities to several Indian tribes. The program includes elements to 'protect the genetic integrity of the species, to augment populations through stocking, to protect and augment habitat, to protect water quality, to address nonnative fish competition, and to monitor population status and trends. In 1994 critical habitat was designated for the Colorado pikeminnow and razorback sucker and included the San Juan River from Farmington to Lake Powell. In 2000, the Service issued a new biological opinion on the Animas-LaPlata Project that included a conservation measure in which "...Reclamation is committing to operate Navajo Reservoir to mimic the natural hydrograph of the San Juan River to benefit endangered fishes and their critical habitat. Mimicry of the natural hydrograph will be achieved by following the San Juan River flow recommendations (Holden, 1999) and subject to completion of the Navajo Operations EIS and execution ofa Record of Decision." (Service, 2000). In addition to the Animas-LaPlata Project, other projects in the San Juan Basin, for example completion of the Navajo Indian Irrigation Project (NIlP), rely on reoperation of the Navajo Unit according to the flow recommendations to comply with the ESA. SAN JUAN RIVER The San Juan River Basin encompasses approximately 25,000 square miles and the river extends 350 miles from its headwaters in the San Juan and La Plata Mountains of Colorado to Lake 'The Animas-LaPlata Project would deplete flows from the Animas River, a major tributary of the San Juan River upstream from critical fish habitat. 4 00681.