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<br />121111200111:25 PH FRQH: ,alC TO: B,19102~B060] PAGE: Oll4 or 001 <br /> <br />at which impact occurs, eilher of the reoperation alternatives maintain nows at or above <br />500 crs all the time. There is no utilization or either historical or modeled now data. The <br />assumplion of 50% impact is not supported by (he now dala. The river has had very high <br />utilization. resulting in use restriction during the last 9 years when nows were not <br />maintained at Of above 500 cfs. 'Illis section should be entirely recomputed based on <br />now data. I would anticipate that eilher aClion alternative would have either no impact or <br />positive impact, by maintaining base flows above 500 efs and providing the more popular <br />high flows during spring runoff. <br /> <br />Page 111-37, Table III-II, No roundation ror 250/5000 impacts, A carefiIl review of <br />minimum flows would show lillie, if any dilTerence beL ween 500/5000 and 250/5000. <br /> <br />Page III-3? Reservoir Recreation. This should be the conclusion for the 250/5000 <br />alternative since it has less drawdown. <br /> <br />Page 111-37, River Recreation, The conclusions should be based on the flow data. not a <br />wild guess by the author as to what will happen. There is practically no difference in <br />minimum flows between the lwo action alternalives, yet a huge difference in assessed <br />impacts. <br /> <br />Socioeconomics <br /> <br />General: ^ conullon metric for analysis should he used. Some times impacts are grO!L'i <br />sales, sometimes retail sales, somctimesjubs, elc. Those measurcmcnts to he used should <br />be clearly specified and thell unifnnnly analYI.~d 'I'he section does not unifonnly include <br />all socio-economil: impacts. II would he more appropriately l:allcd Sllcioeconomics of <br />fishing and rafting guides in the San Juan Uasin as other impacts receive a total of I <br />paragraph. The conclusions are 110t summarized and there is no opportunity (0 truly <br />compare the impacts 10 socioeconomics on the ba~is oflhe data presented. Compare to <br />socioeconomics oflhe ALP [IS. It is a reasonable model for how to analyze these <br />impacts. A much more balanced and thorough analysis is required f(lr meaningful <br />consideration of the alternatives. <br /> <br />Page 111.40. Issue statement should fairly compare all alternati\'es, nol just focus on the <br />250 cfs aUemati\'e. <br /> <br />Page III-40, lines 1120.1121. This line is un,lear. Does it refer 10 agriCulture of Ute <br />Tribes and local conununities as it presently reads? <br /> <br />o <br />o <br />("'') <br />OJ <br />C.:l <br /> <br />Page 111-41, lines 1130-1136. These impact indicators are not evenly weighted. For <br />example, the number of river fishing guides and/or commercial rafting companies, elc. <br />receives the same weight as gruss sales revenue of the call Illy or the number of jobs in the <br />county. An alternative that increased jobs overall in the county could have a significant <br />negative impact ifit had a 10% impact on Ihis one small sector. The indicators seem <br />biased. The Navajos would argue that an impact to their jobs or economic security would <br />