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<br />Line 261. Replace "Non-Indian" with "Unspecified future non-Indian". <br /> <br />Line 264. Replace "CRSP intended to develop" with "Colorado River Storage Project (CRSP), <br />which was implemented to provide for the comprehensive development of'. <br /> <br />Lines 270-283. Delete or correct Table I-I. The Interstate Stream Commission objects to the <br />inaccurate representation of authorized purposes of the Navajo Unit which is carried throughout the <br />ADEIS. Misrepresentation of the authorized purposes of the Navajo Unit leads to many statements <br />in the ADElS being unclear, especially as to the meaning of the purpose and need statement and the <br />objectives of the proposed adaptive management program for Navajo Dan] operations. It also leads <br />to several statements in the ADEIS that appear to incorrectly relegate the development and use of <br />the Upper Basin States' Compact apportionments to an additional, secondary or subservient purpose <br />as compared to the providing of incidental recreational and fish and wildlife benefits. Confusion as <br />to the authorized purposes of the Navajo Unit lIIay influence how the adverse impacts to incidental <br />benefits are considered in selecting or implementing a preferred alternative. Here, Table I-I does <br />not present an accurate summary of the authorized purposes of the Navajo Unit or the legislation <br />enabling such purposes. <br /> <br />The Reclamation Project Act of 1939, as stated in section I of the Act, provided for federal <br />reclamation projects "... a feasible and comprehensive plan for an economic and equitable treatment <br />of repayment problems and for variable payments of construction charges which can be met ... <br />during periods of decline in agricultural income... as well as during periods of prosperity ..., and <br />which will protect adequately the financial interests of the United States in said projects, ..." While <br />the Reclamation Project Act provided bases for cost allocation and repayment contracting for federal <br />reclamation projects, this does not establish Congressionally-authorized purposes for any project <br />authorized by specific Act of Congress before or after 1939. <br /> <br />The authorized purpose of the CRSP, including Navajo Dam and Reservoir, as given in Section I <br />of Public Law 84-485, the Colorado River Storage Project Act of 1956, is: "... to initiate the <br />comprehensive development of the water resources of the Upper Colorado River Basin, for the <br />purposes, among others, of regulating the flow of the Colorado River, storing water for beneficial <br />consumptive use, making it possible for the States of the Upper Basin to utilize, consistently with <br />the provisions of the Colorado River Compact, the apportionments made to and among them in the <br />Colorado River Compact and the Upper Colorado River Basin Compact, respectively, providing for <br />the reclamation of arid and semiarid land, for the control of floods, and for the generation of <br />hydroelectric power, as an incident of the foregoing purposes, ..." Public Law 84-485 limited <br />authorization for construction and operation of the Navajo Unit, however, to the dam and reservoir <br />only (no hydropower facilities). Section 8 of Public Law 84-485 also authorized construction and <br />maintenance of"(1) public recreational facilities on lands withdrawn or acquired for the development <br />of said project [CRSP] or of said participating projects, to conserve the scenery, the natural, historic, <br />and archeologic objects, and the wildlife on said lands, and to provide for public use and enjoyment <br />of the same and of the water areas created by these projects by such means as are consistent with the <br />primary purposes of said projects; and (2) facilities to mitigate losses of, and improve conditions for, <br />the propagation offish and wildlife." The construction of recreational and fish and wildlife facilities <br />under Public Law 84-485 does not confer upon such facilities a primary purpose of the CRSP, <br /> <br />8 <br />