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<br />e <br /> <br />000283 <br /> <br />. <br /> <br />37. As a result of the acts and omissions of Reclamation as described above, <br />Petitioners will suffer immediate and irreparable injury, for which there is no <br />adequate remedy at law. <br /> <br />v. CLAIMS FOR RELIEF <br /> <br />FIRST CLAIM FOR RELIEF <br />(Declaratory and Injunctive Relief- <br />Green Mountain Reservoir Capacity) <br /> <br />1. Petitioners incorporate by reference all preceding paragraphs. <br /> <br />2. Senate Document 80 and the Blue River Decree require that Green Mountain <br />Reservoir be maintained with an active, usable capacity of 152,000 acre feet to <br />ensure delivery to West Slope beneficiaries, including Petitioners of their full <br />entitlement. <br /> <br />3. Reclamation has failed to maintain Green Mountain Reservoir with an active 1 <br />capacity of 152,000 acre feet of water. p <br /> <br />4. Pursuant to Senate Document 80, the Blue River Decree, and the Declaratory <br />Judgment Act, Petitioners request that the Court declare that Reclamation is <br />required to provide at least 152,000 acre feet of active, usable storage in Green <br />Mountain Reservoir, or suitable substitute storage if such storage cannot be made '2. ...!f, 1/ <br />available in Green Mountain Reservoir. ~ <br /> <br />5. Pursuant to Senate Document 80, the Blue River Decree, and the Administrative <br />Procedure Act, the Court should require Reclamation to take whatever steps are <br />necessary to provide at least 152,000 acre feet of active, usable storage. <br /> <br />SECOND CLAIM FOR RELIEF <br />(Declaratory and Injunctive Relief- <br />Releases of 100,000 Acre Foot Pool) <br /> <br />6. Petitioners incorporate by reference all preceding paragraphs. <br /> <br />7. Senate Document 80 requires that so long as sufficient physical supplies are <br />available, in a condition where reduced Green Mountain Reservoir capacity <br />exists, Reclamation must first satisfy releases from the compensatory pool before 7 <br />making releases available from the 52,000 acre foot pool to replace diversions to <br />the East Slope. <br /> <br />8. Pursuant to Senate Document 80, the Blue River Decree, and the Declaratory <br />Judgment Act, Petitioners request that the Court decree that in conditions of ) <br />reduced Green Mountain Reservoir capacity, Reclamation is required to make <br />releases from the 100,000 acre foot pool sufficient to satisfy the requirements of <br />West Slope users in preference to releases to replace C- BT Proj ect diversions to <br />the East Slope. <br /> <br />13 <br />