WSP01241

• File Number: 8220.106
• Description: Animas-La Plata
• State: CO
• Basin: San Juan/Dolores
• Water Division: 7
• Date: 1/1/2000
• Title: Correspondence regarding the Preliminary Final Supplemental Environmental Impact Statement
• Water Supply Pro - Doc Type: EIS

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06/27/00 Tl~ 10:28 F~, 303 312 6897

SUPERFUND

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The ability to operate Navajo Reservoir to meet flow recommendations for endangered
fish will be further constrained by allocation of water to the proposed ALP Project. The
available water to meet future Indian trust water development needs for the Navajo Nation and
the Jicarilla-Apache also depends upon the water supply in Navajo Reservoir. Together, the
Navajo Nation and Jicarilla-Apache need approximately 70,000 acre-feet per year of water to
meet their needs. The BOR predicts that, without the ALP Project, only 20,000 of the
approximately 70,000 acre-feet per year of depletion required can be delivered. The DSEIS
indicates (page 3-23) that, with Refined Alternative 4 of the proposed ALP Project, only 6,000 of
the 20,000 acre-feet per year will be available. With Refined Alterative 6, because the Navajo
Dam would be operated to meet ALP Project demands, no storage in Navajo Reservoir would
remain to deliver water to the Navajo Nation or the Jicarilla-Apache Tribe. (See DSEIS,
page 3-30,)

Of particular concern to EP A is the pressing need for domestic water supply for the
eastern side of the Navajo Nation, where approximately 40 percent of the population does not
have a reliable supply of safe drinking water. The lack of an adequate water supply creates
public health risks to this Tribal population. The 2,340 acre-feet per year of depletion to be
provided to the Navajo Nation under the ALP Project would satisfY only a small portion of the
water needs of the Navajo Nation, (DSEIS. page 4-20.) The proposed Navajo-Gallup water line
that could serve these needs requires depletion from the San Juan River that will be difficult to
obtain consistent with the flow requirements for the endangered fish.

The BOR indicates that it will work with the Navajo Nation and the City of Gallup to
develop the Navajo-Gallup Project. It suggests the following mitigation measures:

* The Navajo-Gallup Project could be modified to reduce demands.
* The Navajo Nation could elect to use a portion of the water allocated to completing the
Navajo Indian Inigatiori Project to meet its domestic water supply needs.

Either of these measures could be seen as imposing additional burdens on the Navajos,
many of whom, as mentioned above, lack basic domestic water supplies.

On June 12, 2000, an article in the F~gton Times stated that a BOR model that had
shown excess water was available for the Navajo-Gallup Project had been erroneous. The EP A
requests that the BOR provide clarification as to whether the results of its modelling are valid
and, ifnot, how the results would change the availability of water for the Navajo-Gallup Project
after correcting any errors. This new information should be updated and presented in the Final
Supplemental EIS.

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Refined Alternatives 4 and 6 also reduce the supply available to meei the water rights of
the Jicarilla-Apache Tribe. This impact is cumulative with the impacts to the water supply
needed for the proposed Navajo-Gallup Project. (See DSEIS, page 4-21.)

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