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<br />description on ]]-16-17. We will wait until we have had a chance to review the Advanced DEIS <br /> <br />to provide detailed comments on these sections. <br /> <br />III. CHAPTER III <br /> <br />A. INTRODUCTION <br /> <br />Chapter ill indicates that the mitigation measures are not included in the alternatives, <br /> <br />rather "[p]otential measures to mitigate fish and wildlife and other resources with statutory <br /> <br />requirements to consider mitigation are presented." ill-I, lines 34-36. NEPA implicitly requires <br /> <br />the discussion of mitigation measures in impact statements by requiring the discussion of "any <br /> <br /> <br />adverse environmental effects which cannot be avoided." 42 USe. S 4332(2)(C)(ii). The <br /> <br /> <br />Council on Environmental Quality regulations implement this implicit requirement by requiring <br /> <br /> <br />the discussion of mitigation measures in impact statements. 40 e.F.R. SS 1502.l4(f), <br /> <br />1502.l6(h). It is not clear from the statement in the PDEIS or the content of the PDEIS whether <br /> <br />Reclamation intends to comply with this provision. <br /> <br />B. AFFECTED RESOURCES <br /> <br />A summary of the impacts of each alternative needs to be addressed under each section. <br /> <br />For example, the Recreation section and the San Juan River and Navajo Reservoir Diversion <br /> <br />Structures section only address the impacts the preferred alternative would cause and fail to <br /> <br />mention the 500/5000 alternative or the no aciion alternative. <br /> <br />As noted at the Cooperating Agency meeting, the Affected Resource section requires <br /> <br />substantial revision. Thus, we have limited our comments and our consultant's comments and <br /> <br />will provide additional comments once we have had a chance to review the Advanced DEIS. <br /> <br />6 <br /> <br />(D~O',]1 <br />