XII. Transcripts€¦ · TRANSCRIPTS - Comments and Responses - Farmington, New Mexico 528 FT11-4 Comment noted. FT11-5 Navajo Reservoir is the principal water storage facility for

497Volume III – Comments and Responses

FEIS – Navajo Reservoir Operations

XII. Transcripts

Introduction

Comments in this section were presented in public hearings held October 1 and 2, 2002,at Farmington, New Mexico, and Durango, Colorado, respectively. Except for generalexpressions of support or nonsupport for the project, comments are summarized in the areascited below.

Issues Raised

� Approximately one-third of the issues touched on impacts to the trout fishery andrelated economic effects, Ind ian uses or projects, authorized purposes and theplanning process in general, limitations of proposed endangered species measures,and the reservoir fishery and recreation.

� Other areas of concern were rafting and rafting-related impacts, cumulative issuesand effects, agricultural impacts, concerns about public input and review, andmethods of analysis.

� Cited less frequently were issues centering on impacts to other resources, NEPAcompliance, alternatives formulation, perceived limitations of the Summer LowFlow Test and DEIS in general, decommissioning dams, Ind ian sacred sites, airquality, and others.

Individuals Providing Written or Oral Comment (by Surname) BarrBoretskyBran chBrossiaBu rn h amCon eCorith ersD ick in sonD oe D zin aEav esFateFord

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PollackRich m on dRogersSh ep p ardSid lowStev en sTav en n erW allW allW allW an n erW eish eitW eth in g ton

TRANSCRIPTS - Comments and Responses - Farmington, New Mexico 499


FT1-1 The issuance of water permits in the State ofColorado is a function of the Colorado StateEngineer's office.


FT1-2 Comment noted.






FT2-1 Please see the response to General Comment 34which explains the DEIS review process andtimeframe.


FT2-3 Please see responses to General Comments 29 and31b.




FT3-2 Please see response to General Comment 25.


FT3-3 Please see responses to General Comments 20f and23.

FT3-4 The reservoir release regime should not adverselyaffect the flood control capability of Navajo Dam. Reclamation follows the flood control diagrams asprepared by the Corps of Engineers, which show timeof year, elevation, projected runoff and reservoirvolume dependent.






FT5-1 Please see the response to General Comment 1a.




FT5-4 Please see the response to General Comment 1b.


FT6-1 Under the Preferred Alternative, the minimumallowable release from Navajo Reservoir would be250 cfs. This could occur any time a spring release isnot being made and whenever downstream seniorrights or the minimum target base flow in therecovery area are being met by intervening flowsbetween Navajo Dam and the critical habitat areabelow Farmington. The 65-year operation studymodeled Navajo Reservoir monthly operations. During that time, the minimum release of 250 cfsoccurred 28 percent of the time. Please refer toGeneral Comment 11 which discusses flexibility inreservoir releases under the Preferred Alternative.

FT6-2 For purposes of the DEIS, it was assumed that flowreductions below the current minimum flow of 500cfs would be implemented immediately after theFEIS is released and the Record of Decision isexecuted. The 250 cfs minimum release belowNavajo Dam, proposed under the PreferredAlternative, could occur at any time of the year. Please see the response to General Comment 11which discusses flexibility in reservoir releases underthe Preferred Alternative.





FT8-1 Comment noted.through 6




FT9-1 Please see the response to General Comment 34which discusses distribution of the DEIS and timeframe allowed for public comment.

FT9-2 Please see the response to Comment 167-30.


FT9-3 Summertime chronic reductions in flow from NavajoDam would result in reducing the extent of the troutfishery in the San Juan River, elevated rivertemperatures being the primary cause. Although it isnot known how far downstream a viable trout fisherycould be maintained associated with a 250 cfs damrelease, based on water quality monitoring during theSummer Low Flow Test the river would support troutto at least the Citizens Ditch Diversion located about1/2 mile below Archuleta. This stretch of river iswhere the vast majority of angler use occurs, soReclamation believes all but a small percentage of thetrout fishery will remain intact at releases below500 cfs, albeit at a somewhat lower quality due tophysical habitat losses.


FT9-4 Please see responses to General Comments 29 and31.


FT9-5 Reclamation has acknowledged in the EIS that anaverage loss of 34 percent usable habitat would occurat a 250 cfs release as compared to a 500 cfs release. Also, an increase in river temperatures associatedwith reduced summertime releases would limit theextent of usable habitat. (See response to Comment176-3). Lower releases in the winter would not havenearly as much impact on the trout fishery, althoughgrowth rates could decline to some degree in lowerreaches of the trout fishery area due to colder rivertemperatures.


FT9-6 Approximately half of the DEIS team members livewithin the San Juan River Basin, in particular in andaround Durango, Colorado. These individuals,though maybe not directly, will also experience theeffects of a change in operations at Navajo Dam.

FT9-7 Reclamation appreciates the cooperation receivedfrom the San Juan Fly Fishing Federation and allwater users along the San Juan River during thedrought contingency operations of 2002 and early2003. During this time period, minimum releasesfrom Navajo Dam had to be reduced below 500 cfsbecause of severe drought conditions.


FT10-1 Please see the response to General Comment 34which discusses the DEIS distribution and publicreview period.

FT10-2 Please see the response to General Comment 7.

FT10-3 The relatively short distance between Lake Powelland the cold releases from Navajo Dam are a limitingfactor on the endangered fish. The SJRBRIP andassociated Flow Recommendations are designed toaddress limiting factors and recover the endangeredfish in the San Juan River.


FT10-4 Please see the response to General Comment 27which discusses adverse impacts to the trout fisheryand associated recreation economies.

FT10-5 Please refer to General Comments 27 and 28.



FT11-1 As indicated in the EIS, the goal of the PreferredAlternative is to help both recovery of the endangeredfish and to facilitate existing and future waterdevelopment.

FT11-2 Please see General Comment No. 20c. There aremany factors that may limit populations of theendangered fish in the San Juan River and, as pointedout in the biological assessment, the shortening of theriverine system by Navajo Dam and Lake Powell isone of them. The SJRBRIP and the FlowRecommendations have been developed as a programto overcome the limiting factors and recover the fish. Success is not guaranteed; monitoring will determinethe degree of success.


FT11-2 (cont.)

FT11-3 Please see the responses to General Comments 20cand 12.



FT11-5 Navajo Reservoir is the principal water storagefacility for the Navajo Indian Irrigation Project(NIIP). Public Law 87-483, enacted in 1962,authorized the Secretary of the Interior to construct,operate, and maintain the NIIP for the purpose offurnishing irrigation water to approximately 110,630acres. The NIIP includes a water storage and deliverysystem, lands, roads, utilities, and other facilities forirrigation of lands located south of Farmington, NewMexico. The Navajo Agricultural Products Industry(NAPI) is a Tribal business enterprise formed in 1970to develop, farm, operate, and manage the NIIP lands. Both NIIP and NAPI were established to providebenefits to the Navajo people. NAPI currentlyprovides approximately 250 permanent jobs and 800seasonal jobs.

FT11-6 Please see the response to General Comment 12which discusses decommissioning Navajo Dam andthe response to General Comment 20 which discussesthe recovery of endangered fish.









FT13-1 Navajo Reservoir evaporation is accounted for in thepermits held by Reclamation for Navajo Dam; likewise, water rights for Lake Powell take intoaccount evaporative losses.


FT14-1 Comment noted.through 4








FT16-1 Reclamation acknowledges receipt of the December5, 2001, letter from the Corps of Engineers and hasreferenced that letter and the channel capacitylimitation of 5,000 cfs in this EIS.

FT16-2 Reclamation acknowledges receipt of the Corps ofEngineers written comments on the DEIS. Reclamation has agreed to the changes submitted bythe Corps, and the EIS will be modifiedaccordingly.


FT17-1 Please see the response to General Comment 11which discusses flexibility and Reclamation's beliefthat flexibility exists to reduce adverse impacts to thetrout fishery.


FT18-1 Please see the response to General Comment 34which explains the DEIS public review process andtimeframe.

FT18-2 Please see responses to General Comments 29 and31b.







FT21-1 Reclamation has acknowledged that reservoir stagefluctuations in Navajo Reservoir could have anadverse effect on game fish populations by impactingspawning success. It must be remembered, however,that the majority of the reservoir's drawdown in 2001was related to the drought conditions present, not bydam operations.

FT21-2 Many of the impacts on reservoir recreation in 2002were related to continuing drought conditions. Although the EIS indicates differences in reservoirelevations among the alternatives, in droughtconditions these differences are exacerbated.




FT22-1 Please see the response to General Comment 12which discusses decommissioning Navajo Dam.


FT22-2 The concrete diaphragm wall which was constructedin 1988-89 in the left abutment area was part of asuccessful seepage remediation program.

FT22-3 Inundation studies and associated maps have beencompleted as part of Reclamation’s Safety of Damsprogram. Inundation maps show the upper limits ofthe potential flood areas and have been distributed toapplicable emergency preparedness organizations.



FT22-5 Please see responses to General Comments 1a, 1b, 1c,and 1d.


FT23-1 The EIS recognizes that a 500 cfs minimum would bebetter for trout habitat than the 250 cfs minimumunder the Preferred Alternative. The PreferredAlternative is designed to help recover theendangered fish while allowing existing and futurewater development to proceed. Flexibility asdiscussed in General Comment 11 may reduceimpacts to the trout fishery.

FT23-2 Reclamation acknowledges that there will be a loss in native fish habitat in the area cited. It isdifficult to predict the effect to native fishes withinthis reach because they are far more resilient than aretrout to poorer water quality conditions and losses inphysical habitat.

TRANSCRIPTS - Comments and Responses - Durango, Colorado 551

DT-1 Comment noted.


DT1-2 Please see the response to General Comment 20d. Inaddition, the New Mexico Interstate StreamCommission has made state funds available toconstruct or install flow measurement flumes on non-Indian ditches that divert from the San Juan River. Once the flumes are installed, the New Mexico StateEngineer can monitor diversion rates at each non-Indian ditch. The New Mexico State Engineer haspublicly committed to measurement andadministration of ditch diversion in the San JuanRiver Basin. (Reference Interstate StreamCommission letter to Reclamation dated November26, 2002.)


DT2-1 Comment noted.

DT2-2 Please see the response to General Comment 27.




DT2-4 Please refer to the response to General Comment 13which discusses drought conditions. Themanagement of Navajo Reservoir requires protectionof endangered fish and the delivery of water to NIIPand others. Under the present extreme droughtconditions, Reclamation is working with water usersof Navajo Reservoir storage water to share in theavailable water supplies.


DT3-1 Please see the responses to General Comments 5, 6,and 18k.


DT3-2 The response to General Comment 15 addressesmonitoring of base flows and the EIS has beenmodified accordingly. Reclamation's intent is to meetthe base flows in areas of critical habitat for theendangered fish. There are also provisions in the EIS(page II-11) "to share shortages" during severedrought periods such as 2002.



DT4-2 Please refer to the "Water Uses and Water Resources"and the "Indian Trust Assets and EnvironmentalJustice" sections in Chapter III of the EIS forinformation on Indian water rights.



DT4-4 To address and analyze whether an agriculturalenterprise is profitable or not and the provision offederal assistance to agriculture is beyond the scopeof this document. Also, please refer to the responseto General Comment 31.


DT4-5 The 250 cfs minimum "saves" water for futuredevelopment and for spring peaks for the endangeredfish. Also, see the responses to General Comments10 and 20c.

DT4-6 Comment noted. After the ALP Project constructionis completed, then the water will be available forIndian use. Project benefits were based onnon-binding uses as a means of addressing theColorado Ute Tribe water rights settlement.


DT4-6 (cont.) Please see the response to General Comment 34which addresses distribution of the DEIS and thepublic comment period.


DT5-1 The Flow Recommendations are an attempt to imitatethe natural hydrograph via replicating certain flowvalues and duration statistics. It is not Reclamation’sjob to “imitate nature”, but to describe the impact ofre-operating Navajo Reservoir in a manner that willmeet the Flow Recommendations.



DT6-2 Please see the responses to General Comments 15,18a, and 20d.


DT6-3 Please see General Comment 15 concerningmonitoring of base flows and General Comment 32concerning rafting impacts.



DT7-1 Please see the response to General Comment 11. Reclamation will utilize the Navajo Operationsmeetings to determine where flexibility occurs anduse this flexibility to reduce short-term impacts. Until full development occurs, some flexibility willexist.


DT8-1 Navajo Reservoir serves many uses and needs. Releases are made to meet target elevations for wintercarryover and to keep the reservoir at a safe operatinglevel. Releases are also made to meet minimumtarget base flows other times of the year. The EISrecognizes that the reservoir would operate anaverage of 10 feet lower under the PreferredAlternative.

DT8-2 Recovery efforts are long term and their success willbe determined by monitoring. There have been somepositive actions under the program--reproduction ofendangered fish has been noted and stockingprograms are proceeding. Long-term success cannotbe determined at this time.


DT8-2 (cont.) Also, see the response to General Comment 20c.

DT8-3 Please see the response to General Comment 18k.


DT9-1 Please see the response to General Comment 34which explains the DEIS review process andtimeframes.


DT9-2 Please see the responses to General Comments 22 and28 which discuss the low flow test and the troutfishery impact analysis.

DT9-3 Please see the responses to General Comments 29 and31b.




DT9-6 Please see the response to General Comment 11concerning flexibility that exists prior to completionof NIIP and the ALP Project.


DT10-1 Some future water development is assumed to occurunder the Preferred Alternative with the largest usesthe completion of NIIP and the ALP Project. TheEIS also addresses how water use in the future will beaddressed under the ESA. In general terms, futurewater use means development of compact-allottedwaters by the States of New Mexico and Colorado. One of the Congressionally authorized purposes ofthe Navajo Unit is to assist the states in developingtheir compact water. Also see the response toGeneral Comment 11 which discusses flexibility.


DT10-2 Please see the response to General Comment 27which acknowledges the impact to the trout fisheryunder the Preferred Alternative. Also, the response toGeneral Comment 11 discusses flexibility whichexists to reduce adverse impacts to the trout fishery.


DT10-4 Please see the response to General Comment 2 whichdiscusses mitigation.


DT10-5 The Physical Habitat Simulation (PHABSIM) thatwas conducted for the San Juan River trout fisheryhad both a hydraulic and a biotic component. Withinthe Quality Waters Section of the trout fishery, datawas collected relating to the river's depth, velocityand substrate compared to changes in flow. From thisinformation it is possible to predict physical changesrelated to a variety of flows. Second, preferences oftrout were identified that show the probability of troutusing portions of the river based on their preferencesfor specific velocities, depths and substrates. Theproblems that occurred running the model werecomputer-related, not data-related. The output thatwas generated, that of predicting an overall 34percent loss in trout habitat within the Quality WatersSection, constitutes Reclamation's best efforts atassessing the effect of reducing dam releases to 250cfs.


DT10-6 The EIS recognizes that a 500 cfs minimum releasereduces impacts on the trout fishery and otherresources. Please see the responses to GeneralComments 3 and 10 concerning the No Action andthe Preferred Alternatives.



DT11-2 Please see the response to General Comment 5a.

DT11-3 Reclamation recognizes that Flow Recommendationscould be met if water users were shorted, but ourassumptions were that senior water rights wouldremain whole. Please see response to GeneralComment 18.

DT11-4 Please see the responses to General Comments 22,23, and 28.


DT11-4 (cont.) quality, and the trout fishery, respectively.




DT11-8 Please see the responses to General Comments 5 and9.


DT11-9 Reclamation believes the Preferred Alternative is thebest alternative to meet the two goals of the SJRBRIP(i.e., recovery of endangered fish species and futurewater development) while maintaining the authorizedpurposes of the Navajo Unit.

DURANGO WRITTEN - Comments and Responses - Durango, Colorado 578

DW1-1 Please refer to the responses for General Comments29 and 30.

DW1-2 Please see the responses to General Comments 18c, d,and e.


DW2-1 See response to Comment DW1-2.

DW2-2 Please see the responses to General Comments 3 and6 which discuss releases at 500 cfs and the PreferredAlternative, respectively.


DW3-1 Please see the responses to General Comments 3, 5,9, and 10.

DW3-2 Please see the response to General Comment 34which discusses the public review/comment periodand subsequent review extension.

DW3-3 Please see the response to General Comment 29a.


DW3-4 Comment noted.


DW4-1 See response to Comment DW1-2.

BLUFF WRITTEN - Comments and Responses - Bluff, Utah 583

BW1-1 Please see the response to General Comment 32.

BW1-2 Please see the response to General Comment 6 foradditional information.

BLUFF WRITTEN - Comments and Responses - Bluff, Utah 584

BW2-1 The EIS has been revised to accommodate yourconcern.

Documents

XII. Transcripts€¦ · TRANSCRIPTS - Comments and Responses - Farmington, New Mexico 528 FT11-4 Comment noted. FT11-5 Navajo Reservoir is the principal water storage facility for