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A'" ... Mr. Bob McCue February 14, 1997 Page <\ NWU refers the Service to its comments fiied on June 15, 1992 with the FERC concerning the draft environmental impact statement for a detailed discussion of the devastating economic and ecologic costs associated with mandatory on-farm efticiency measures, More than $53 million in capital and maintenance costs were identified by NWU. These are not evaluated or discussed in the DBO. Although the Service recognizes that ground water quantities and quality are interrelated with the surface water projects, it does not acknowledge the effect of water conservation measures on groundwater recharge rights nor does it evaluate the associated economic losses. Other significant economic costs are detailed in NWU's June 1992 comments amounting to more than $100 million associated with mandatory on-farm efficiency measures. The Service should give ~erious attention t6 these ecohOOlicCertaintics in its considera:ion-of- water conservation proposals. Drought Protection Projects 1417 and 1835 were constructed for primarily for the purpose of providing protection to irrigation supplies in the event of a prolonged drought. Yet the DBO completely ignores the potentially devastating economic implications of the various operating proposals that deteriorate the projects' drought protection capabilities. In its June, 1992 comments to the FERC, NWU demonstrated that the loss of one year's crops for farnlers lacking an alternative irrigation source would exceed $42 million, This is an issue of fundamental concern to NWU deserving significantly more serious consideration. CONCLUSION Thank you in advance for your consideration of these comments. We will provide supplemental comments once we are able to review any additional information the Service provides with respect to the DBO. Sincerely, ~~9 ~) Richard P. Hutchison General Counsel cc: FERC Service List