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<br />, <br /> <br />;> <br /> <br />viii. Have Defendants adequately <br />and fairly considered alternatives such as: no project, <br />Weld County Reservoir, flood control without storage, aff- <br />stream storage; groundwater storage? <br /> <br /> <br />ix. Does the cost figure of <br /> <br /> <br />one hundred thirty-nine million, five hundred twenty-six <br /> <br /> <br />thousand ($139,526,000.00) dollars in the FES reflect the <br /> <br /> <br />actual cost of the dam? <br /> <br />x. Are the facts and data <br />used to justify the Harrows based upon outdated studies <br />which if updated would demonstrate the infeasibility of the <br />project? <br /> <br />xi. Has the railroad relocation <br />been inadequately designed, thus presenting excessive flood <br />damage risk? <br /> <br />xii. <br /> <br />Did the FES fail to <br /> <br />specify the countervailing federal pOlicies which allegedly <br />justify the adverse impacts of Narrows? <br />(2) Did the Defendan"ts comply with the rules <br />and regulations of the u.s. Department of Interior regarding <br />the substantive and procedural requirements relating to <br />EIS and cost indexing for'"the Narrows? <br />(3) Have the Defendants failed to comply with the <br />mandates of the Fish and Wildlife Coordination Act? <br />(4) Have the Plaintiffs suffered and would they <br />continue to suffer irreparable injury in fact in their use <br />and enjoyment of the private and (public lands) affected by <br />the proposed construction of Narrows? <br />a. Would construction and use of Narrows <br />have a profound adverse impact upon the human environment of <br />Plaintiffs? <br /> <br />b. What damages have Plaintiffs suffered? <br />(5) Have the Defendants, by abuse of authority <br />and actions outside ~Ile scope of authority damaged plaintiffs <br /> <br />-1 3- <br />