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<br />\ <br /> <br />Page 5 <br />July 3D, 1990 <br /> <br />page 3 the Draft Opinion admits that "water quality in the Animas, La <br />Plata, Mancos and San Juan River drainages as well as the Project <br />areas' groundwater supply has become a significant concern". <br /> <br />At page 6 and page 7 the Draft sets forth additional action which may <br />have endangered the fish: <br /> <br />Since closure of the [Navajo] dam in 1962 and the accom- <br />panying fish eradication program, physical changes (flow <br />and temperature) associated with the operation of the <br />Navajo Project has [sic] eliminated Colorado squawfish in <br />the upper San Juan River. both from the reservoir basin <br />as well as from several miles of river downstream of the <br />dam. <br /> <br />A marked decline in Colorado squawfish populations can <br />be closely correlated with the construction of dams and <br />reservoirs during the 1960's, the introduction of nonna- <br />tive fishes, and the removal of water from the Colorado <br />River system, . Dams on the mainstems [of the <br />Colorado] have essentially segmented the river system, <br />blocking Colorado squawfish spawning migrations and <br />drastically changing river characteristics, especially <br />flows, temperatures, and channel geomorphology. <br /> <br />The Draft Opinion contains a number of other unsubstantiated con- <br />clusions. Rich Valdez, fishery biologist consultant, has indicated <br />that the conclusion at page 9 of the Draft, that reproduction of <br />Colorado squawfish was highest in 1987, cannot be supported. The <br />number of young of the year Colorado squawfish captured in the San <br />Juan River investigations in 1987 - 1989, only nineteen, is too small <br />to support the Service's conclusion. The difference in numbers of <br />young of the year found by researchers in the three years 1987-1989 <br />could simply reflect sample conditions and sample locations. <br /> <br />Mr. Valdez does not believe that there is evidence to substantiate the <br />conclusion at page 8 of the Draft Opinion, that the Colorado River <br />subbasin populations of Colorado squawfish show particular signs of <br />further decline. Rich Valdez has stated "it cannot be shown statis- <br />tically that the numbers of Colorado squawfish in the Colorado River <br />and the upper basin are declining." <br /> <br />A t Page 8 the D raft states: <br /> <br />A once healthy (pre-Navajo Reservoir) historic population <br />of Colorado squawfish has been reduced to a few fish that <br />have managed to survive. <br />