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001537 , Public Scoping Comments, Gunnison River Contract, cont. ~:;~f:i> .):~;"~.)'iJ ...,..,-, 1. The Gunnison River Contract must be completed before the AB Lateral Project can be analyzed in compliance with NEPA; the AB Lateral Record of Decision should be withdrawn pending completion of the contract. . 19a., GREENO+; p7, '3. (Issue H: A-B Lateral, cont.l) The Bureau of Reclamation sbould withdraw its Record of Decision (ROD), dated December 20, 1991, approving the proposed AB Lateral Hydropower Facility because the Bureau cannot analyze the proposed facility's environmental consequences well enough to meet the "hard look" requirements of NEPA until the proposed Gunnison River Contract--a major mitigating measure listed in the ROD--is completed and clearly defined. Protection of the National Monument and compliance with NEPA require that the ROD be withdrawn and reissued only after the Gunnison River Contract has been completed and a Supplemental EIS on the proposed facility has been 'prepared. 13b. e;iJ:) 19a. GREENO + ; p7, '4. (Issue H. A-B Lateral, con!.l) These fundamental procedural questions concerning the AB Lateral Project are vitally important to the success of the proposed Gunnison River Contract. The Bureau observes in the ROD that the AB Lateral Facility would use the "run-of-the- river" (Le. t use flows only as they are released from the Aspinall reservoirs with no call on senior rights and no active storage) as approved in the ROD. It would divert 324,679 acre-feet annually through the Gunnison Tunnel. The AB Lateral diversions combined with existing diversions of 337,824 acre-feet for irrigation through the Gunnison Tunnel would equal more than half of the 1.1 million acre-foot average annual flow of the Gunnison. The ROD concludes that "average flows downstream from the Gunnison Tunnel would be reduced from 1,103 cfs to approximately 654 cfs" and that "frequency of minimum flow levels of 300 cfs would increase significantly." GREENO+; p7,'4. (Issue H. A-B Lateral, cont.l) These fundamental procedural questions concerning the AB Lateral Project are vitally important to the success of the proposed Gunnison River Contract. The Bureau observes in the ROD that tbe AB Lateral Facility would use the "run-of-the- river" (i.e., use flows only as they are released from the Aspinall reservoirs with no call on senior rigblS and no active storage) as approved in the ROD. It would divert 324,679 acre-feet annually through the Gunnison Tunnel. The AB Lateral diversions combined with existing diversions of 337,824 acre-feet for irrigation through the Gunnison Tunnel would equal more than half of ihe I. I million acre-foot average annual flow of the Gunnison. The ROD concludes that "average flows downstream from the Gunnison Tunnel would be reduced from 1,103 cfs to approximately 654 cfs" and that "frequency of minimum flow levels of 300 cfs would increase significantly." 19a. GREENO+; p7,'5. (Issue H. A-B Lateral, cont.l) The Bureau qualifies the scenario outlined in the previous paragraph by noting that Aspinall Unit water contracted to the National Monument in the future could not be diverted to the AB Lateral Facility and that flows to benefit endangered fish may reduce the AB Lateral water supply. It gives absolutely no quantitative analysis in the EIS or in the ROD of how these constraints (Le., environmental commitments) would reduce or otherwise alter diversions to the AB Lateral Facility. They appear to be very substantial constraints (especially in combination with the run-of-the-river limitation) and we commend the Bureau for putting them in the ROD. The lack of a defined contract and uncertainty about the requirements of the endangered fish, however, make it impossible to predict or analyze the environmental consequences of the proposed action. NEP A requires such analysis in order to inform the public abouttbe likely consequences of the proposed action and to ensure that all reasonable steps are taken to minimize environmental degradation. 59