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~ l ~ rf \ The flow recommendations were selected to attempt to create channel bed conditions that are theoretical habitat for the endangered fish based on two premises: (I) that the flows will create the channel bed conditions and (2) the endangered fish will use the habitat. The habItat IS measured by square meters and is monitored at least yearly. At the February 6, 2001 SJRBRIP Biuiugy CUlIlIlliiit:c: lIiceting the follo"Y..ring 'vvas presented: (1) the habitat decreased 50~!t_1 ~fter the 1995 mnoff and has not recovered; (2) the amount of backwaters and islands are decreasing; (3) the interstitial depth is decreasing; (4) flows above 5,000 cfs have not cleaned cobbles as indicated in modeling; and (5) there is no linkage between habitat and biological response, These troubling findings correspond to the decrease in numbers of endangered fish during this period, As one of the Peer Reviewers for the SJRRIP commented at a Biology Committee meeting "the relationship between mimicking a natural hydro graph and recovery of the fish is an untested hypothesis", Further, the abundance of razorback suckers in Lake Mojave should provide significant dOllbt concerning the need for mimicked flows to recover that species, Based on the limited data to date, the hypothesis may not be true, The EIS for reoperation of Navajo Dam is to "allow", not "meet", the Flow Recommendations by providing for releases down to 250 cfs, Adaptive Management (Chapter II, lines 297 to 303) is a component of the SJRBRlP, Is Adaptive Management an "action" of the ElS? Or described in the EIS to reference the SJRBRIP Adaptive Management program? The BO says Adaptive Management is an action of the EIS, if so why have adaptive management programs in EIS and the SJRBRIP? Needs clarification and consistency between EIS and BO. The EIS presllpposes (Chapter II, lines 588 to 594) that water allocated but not used in the short tenn will be used to provide releases from Navajo above 250 cfs. This water could also be used for short term water development. The EIS should state that releases above 250 cfs are only one possible llse of short ternl water. The application of the Impact Indicators in Chapter III, Line 300 is a can ofwomls, Specifically using shortages to NIIP and Navajo-Gallup as indicators is a problem when sh0l1ages to the Ute Tribal Water Rights are not included as indicators, NIIP can have shortages and this shollld not be used as an indicator. The Colorado Ute Water Rights Settlement is finalized just as the Jicarilla Settlement and shollld be used as an indicator before Navajo-Gallup which does not have valid approved water rights or environmental clearances, It does not appear that the Navajo-Gallllp pipeline depletions are available within New Mexico and Arizona's Compact allocations, A fifth indicator should be included for Colorado's Compact allocation, It appears USBR is overly focused on Navajo-Gallup Pipeline to the exclllsion of other water users, the purpose of the EIS is to allow the Flow Recommendations to benefit all water users in the San Juan Basin, The indicators should address impacts to ALL water users or modified to remove the bias. SPECIFIC COMMENTS Chapter I: 00817