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<br />1 <br /> <br />Interior. The suit is an action in mandamus <br />requesting a court order from the Federal <br />District Court of the District of Columbia <br />to compel the Secretary to either construct <br />protective works to prevent water from enter- <br />ing the boundaries of the RainbOW National <br />Bridge Monument or as an alternative to limit <br />the filling of Glen Canyon to about its present <br />elevation. <br /> <br />This suit is based upon two allegations. <br />One is that the Colorado River Storage Project <br />Act specifies that the Secretary of the In- <br />terior shall construct protective works to <br />prevent water from entering the boundaries of <br />the monument. The other grounds is that the <br />water backing into the canyon under the monu- <br />ment would mar the beauty of the area and <br />destroy vegetation. What vegetation I haven't <br />been able to discover. Vegetation is prac- <br />tically nonexistent in the canyon. However, <br />the fluctuating water would leave marks on <br />the canyon wall. <br /> <br />1 <br /> <br />The Secretary of the Interior in about <br />'59 or '60 requested funds from the Congress <br />to construct these protective works. This <br />would require a dam in the canyon itself on <br />Bridge Creek. A dam could be constructed at <br />the lower end of the canyon to keep the water <br />from backing up in the channel below the <br />bridge. The Congress turned down the request <br />of the Secretary of the Interior for funds. <br />Since 1960 or shortly thereafter, there has <br />been language to .the effect that no funds <br />appropriated shall be used to construct pro- <br />tective works for the Rainbow Bridge National <br />Monument. Congress has clearly indicated <br />that it thinks it is foolish to construct <br />such works. <br /> <br />We have some photographs here which portray <br />the area. The site of the proposed dam is <br />shown there near the bottom of the canyon. An <br />earthen dam could be constructed there with a <br />