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,. " Mr. Ken Beck April 15,2002 Page 2 of 3 purposes and compliance with other laws arises, the authorized project purposes may be limited in some fashion but they are not changed. Decommissioning Navajo Dam and Reservoir We strongly believe that the Decommissioning or Breaching of Navajo Dam and Reservoir should not be considered in the EIS in any fashion. It is a preposterous idea that is beyond the scope of the EIS and certainly does not qualify as a dam operating alternative that can be implemented to meet the flow recommendations. It would seem more appropriate to address this crazy idea as necessary in the response to individual comments. Decommissioning is outside the scope of the proposed action, fails to meet all elements of the "Purpose and Need" for the proposed action, and would preclude meeting commitments required under existing law. Breaching will not provide a true natural hydrograph given all the other regulating structures in the basin nor help meet the flow recommendations. As a result, it would do little to improve conditions for endangered fish. There are a number of reasons the fish are endangered, including the presence of non-native fish and previous efforts to eradicate the native fish to establish more desired sport fisheries. Please, lets limit this EIS to the scope originally envisioned. Adaptive Management We were unsure what was meant by, "adaptive management" in the previous draft and now we are completely opposed to the inclusion of such language or program. It is completely beyond the scope of the "Purpose and Need" for this EIS for the USBR to commit to or implement a separate adaptive management process for Navajo Dam. The goal and objective of this EIS is much narrower. It is to operate Navajo Dam over a broader range ofreleases to maintain or improve conditions for endangered fish if possible, nothing more. While we are supportive of the "operational meetings" that USBR sponsors on Navajo Dam operations three times a year, these meetings are completely different from an adaptive management program, such as exists at Glen Canyon. The USBR's ability to consider the information provided at the "operational meetings" is very limited and constrained by the "Law of the River" and authorized project purposes. It may be appropriate to monitor the effects of the preferred alternative in this EIS on other resources as part of the SJRlP. However, it is totally inappropriate to propose a process that would require additional research and the establislunent of management goals for other resources. This goes well beyond the scope of this EIS and may go beyond USBR's statutory authority (i.e. USBR has no authority to manage other natural resources under CRSP). This entire section should be deleted and any reference to "adaptive management" deleted. USBR's discussions here should be limited to the "operational meetings" and there conduct, which is a long way from "adaptive management." Flood Prolection. Water Project Planning and Financing. Stream and Lake Protection Water Supply Protection. Conservation Planning 00707