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<br />OD1532 <br /> <br />., <br /> <br />Public Scoping Comments, Gunnison River Contract, conI. <br /> <br />/~~~{.~}:: <br /> <br />..'-";~ .. <br /> <br />needed to establish the feasibility of altering operating criteria. The Gunnison Basin Planning <br />Model will be needed before alternatives can be developed and before environmental <br />consequences can be adequately analyzed. <br /> <br />22. GREENO+; pI4,'2. Issue O. Public Involvement - One of the most fundamental objectives of the <br />National Environmental Policy Act is meaningful public participation in federal decision-making. <br />Meeting this objective requires: I) an 'EIS written in plain language with a clear and thorough <br />presentation of issues, alternatives, and impacts and 2) adequate comment periods. <br /> <br />22. GREENO+; p14, '3. (Issue O. Public Involvement, cont) The Bureau of Reclamation's recent EIS <br />on the AB Lateral Project is a good example of a poor ElS. The most important issue in the entire <br />EIS--the acre-feet per year of water currently flowing in the river below the Gunnison Tunnel and <br />changes in that flow under the various altematives--is not clearly discussed, The most important water <br />supply data are hidden in contradictory appendices or in unindexed responses to public comments. This <br />sort of obfuscation whether intentional or unintentional sbould not be allowed in the EIS for the <br />proposed Gunnison River Contract. The draft should be rigorously edited by a professional editor who <br />not only corrects spelling and grammar but also identifies missing information and improves <br />organilAtion. The plain language requirements of NEPA and the CEQ regulations were established in <br />past litigation and they need to be taken seriously. <br /> <br />22. <br /> <br />GREENO+; pI4;'4. The public comment period on the draft EIS should extend for at least six <br />months. The proposed contract involves an enormously complicated set of issues that can begin to be <br />understood only after many hours of study. The public should be given an opportunity to digest the <br />EIS and to ask questions before the comment period ends. Hearings should be held in Denver and <br />Boulder as well as in Western Slope cities. <br /> <br />':.~fL~.; <br /> <br />, '. <br /> <br />11. GREENO+; pI4,\l6. <Alternatives) <br />I) Selection of alternatives should be 20al-driven--after studies have been done to deteniline <br />optimum flows for the various environmental ~d economic values, values with similar <br />optimum flows should be grouped together to define alternatives. For example, the goal of <br />optimizing flows for endangered fish, riparian vegetation, campsite restoration, and sediment <br />transport might define one alternative. <br /> <br />11. GREENO+; pI5,'2. '(Alternatives, cont) <br />2) The statement of alternatives should include contract lamrualZe--In order for conuncntors to <br />comprehend the .actual environmental consequences of each alternative, they will need to see <br />specific contract language that sbows how that alternative would be implemented. The January <br />1992 draft contract is very helpful in identifying potential problems and focusing questions; <br />draft contract language for the EIS alternatives would do the same. <br /> <br />12. GREENO+; pI5,'3. (Alternatives, cont) <br />3) Alternatives should be analvzed with a hi.h level of quantitative and qualilative sDecificitv--The <br />effect of each alternative on historic flows since 1970 should be quantitatively simulated and <br />presented in the EIS along with qualitative analysis of the probable environmental impacts of <br />those flows. Also the potential impact of future projecis and diversions should also be <br />quantitatively and qualitatively analyzed (e.g., AB Lateral, Union Park, transfer of <br />downstream rights for upstream diversion, etc,). <br /> <br />54 <br /> <br />:';.~~,.,~;.':,~.;: <br />'~:,.' ";/;-".: <br />.,,:,!''-, <br />