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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(9) Is the failure of the Defendants to plan

to implement FES recommendations to fUlly mitigate the
wildlife habitat losses a direct violation of the Narrows

construction authorization and the "Federal Water Project

Recreation Act?

(IO) Can a FES for the Narrows dam construction

which is written without the benefit of basic studies con-

cerning project operation and safety factors be considered

adequate and in compliance with NEPA?

a. Can a review of stability studies

of other dams in other locations, without such studies at

the proi:losed site, suffice as compliance with HEPA's mandate

lito use all practicable means to:

(2) assure for all Americans safe,
healthful, productive, and esthetically
and culturally pleasing surroundings;

(3) attain the widest range of
beneficial uses of the environment
without degradation, risk to health
or safety, or other undesirable
and unlntended consequences
(emphasis supplied)?

"

b. Can the construction of a dam

without the benefit of transient analysis of seepage losses

on the Narrows site be considered in compliance with the

above mandate?

c. Can a 1948 memo be considered an

adequate study of groundwater velocity and its accompanying

safety factors, when the present amount of water proposed to

be stored in Narrows Dam has increased from the 194a volume.

The parties reserve the right to list additional issues

of fact and law based on subsequent discovery or amendment

of pleadings.

7. WITNESSES.

(A) The counsel for the parties shall provide to

every other counsel its list of witnesses two (2) weeks

before trial.

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