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t 'II . . Area Manager DRAFT 4 received language describing the trigger for "extreme conditions" on Decemeber 23, 2003. The JicanJia Apache Nation is currently engaged in Goverruneni-io-GoverruJ1t:ni Wl1sultation with the Service, and has expressed concerns about how past and future section 7 consultations may affect the Nation's ability to use its 25,500 af of San Juan River Basin water rights. The Nation, consistent with Secretarial Order 3206, is consulting with the Service to ensure that: (1) they do not bear a disproportionate burden of endangered species conservation, and (2) any reasonable and prudent alternatives do not discriminate against the Nation. Action Area The action area for the proposed action consists of the entire San Juan River Basin, to the full pool of Lake Powell. DRAFT BIOLOGICAL OPINION Description of the proposed action Reclamation proposes to operate Navajo Dam and Reservoir in accordance with the Flow Recommendations. The two-fold purpose of the proposed action (referred to as the 250/5000 alternative in the draft envirorunental impact statement (Reclamation 2002)) is to: 1) Develop operating criteria for Navajo Dam and Reservoir in order to assist in creating and maintaining habitat in the San Juan River to help conserve and recover populations and designated critical habitat of the pikeminnow and razorback sucker, and 2) maintain the authorized purposes of the Navajo Unit, including future water development. The intent of the proposed reservoir operations is to mimic the San Juan River's natural hydrograph downstream from its confluence with the Animas River to Lake Powell. Although the pre-dam hydrograph cannot be precisely replicated, releasing between 250 to 5,000 cubic feet per second (cfs) will provide a hydrograph that is similar to the pre-dam conditions (Figure 2). The peak releases (5,000 cfs) would be planned to meet the statistical requirements of the spring Flow Recommendations. A decision chart (Figure 3) would be used to determine spring releases, which would occurin approximately 70 percent of the years, The summer, fall, and winter base flow releases are intended to meet the Flow Recommendations in the river downstream of Fannington of 500 to 1,000 cfs. The operation criteria are also designed and intended to consistently meet endangered fish minimum base flows downstream from Farmington (500 cfs). Maximum recommended base tlows (1,000 cfs) downstream from Farmington would occasionally be exceeded because of high inflows from the Animas River. Figure 2 The Flow Recommendations call for using a moving average of 2 of the 4 downstream gages to monitor whether flows are kept between 500 and 1,000 cfs. There can be significant variability in these gauge readings and the selective use of any 2 gauges could give results above or below OOH04