WSP00097

• File Number: 8443.600
• Description: Narrows Unit - Studies
• State: CO
• Basin: South Platte
• Water Division: 1
• Date: 3/21/1977
• Author: Various
• Title: Various Report Items Related to Narrows Unit
• Water Supply Pro - Doc Type: Report/Study

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proposed by Defendants will make the Narrows a different
project than authorized by Congress. Therefore Defendants
should be enjoined from proceeding with the Project until
such time as Defendants resubmit the Narrows Project to
Congress for reauthorization.
(8) uefendants have failed to comply
with the rules and regulations of the U. S. Department of
the Interior regarding the preparation, completion and
public hearing requirements relating to the EIS and related
studies and project cost data provided to Congress to obtain
appropriations.

(9) Construction of the Narrows based
on an inadequate FES without compliance with NEPA will
ueprive Plaintiffs of property without due process of law
and just compensation as guaranteed by the Fifth Amendment
of the U. S. Constitution.
b.) Plaintiffs'-Intervenors' (Wildlife
Federation) Claims:
(1) National Wildlife Federation,
Nebraska Wildlife Federation and Colorado Wildlife Federat-
ion as Plaintiffs-Intervenors were granted permission to
enter this case and protect their interests in the perpetu-
ation of the critical water file resources of the Platte
River system in Colorado and Nebraska, particularly the Sand
Hill Crane and the federally protected Whooping Crane (Grus
Americana), which are threatened by Defendants' proposed action.
(2) The Platte River ecosystem as it
relates to migratory water fowl and in particular the federally
protected \vhooping Crane, (an endangered species), rely for
their survival on three physical characteristics: (l)
shallow, submerged, unvegetated sand bars in broad stretches

of river used as night roosting sites; (2) wet meadows,

particularly those :lear roosting areas used for feeding,

resting, courtship and as secondary roosts; and (3) corn and

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