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i. November 15, 2001 Email Memo 'T'_. Tr_L'.I__n r\___ lV. I'\..aLlIICt;11 V~bd From: Steve Harris, Southwestern Water Conservation District Re: Comments on Draft Navajo Re-Operation EIS Due to a commitment to attend a water court trial in Alamosa the entire week of November 26, I will be unable to attend the Cooperators meeting on November 28 and 29, unless the trial schedule changes (which is always possible). I am submitting these comments on the DEIS for your consideration. The Southwestern Water Conservation District (SWCD) is a supporter of recovery of the endangered fish in the San Juan River in the most efficient and effective manner possible, The Navajo Re-Operation EIS is an important component in the recovery actions in order to allow releases from Navajo Reservoir to be made as described in the Flow Recommendations, All comments provided by SWCD are to recover the fish as quickly as possible, The comments are separated into General and Specific Issues as described below. GENERAL COMMENTS SWCD is supportive of the selected alternative, The selection of the 250/5000 cfs alternative will allow implementation of the Flow Recommendations, yet provide Reclamation with jI',...L........ flexibility to schedule releases to address unforeseen conditions or modification of the Flow ;:::::r Recommendations, The EIS is significantly improved from previous drafts in ternlS of both fornlat and organization of content. SWCD comments do not include changes in fornlat nor significant content issues, A good editing is still necessary but no major changes, The EIS and 80 are inconsistent in the purpose of the Flow Recommendations, Statements of "The Flow Recommendations are designed to maintain and improve habitat for these fish," Is correct. Statements that "Reclamation would modify the operation of Navajo Dam and Reservoir to provide releases of water designed to protect the razorback suckers and Colorado pikeminnow "..," are incorrect. Neither the Flow Recommendations nor the action altematives in the EIS will "protect" the endangered fish, rather the Flow Recommendations are designed to "maintain and improve habitat", Cannot "protect" the endangered fish because there is essentially no fish in the river to protect and there is presently no data to support the hypothesis that habitat created by the Flow Recommendations is necessary to recover the fish (see following paragraph), Many of the incorrect references are listed below in Specific Comments but some may have been missed, 00816