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<br />06/2i/00 TUE10:30 F.U: 303 312 689i <br /> <br />SUPERFl:~V <br /> <br />~UVI <br /> <br />230.10(a)) The next steps of the process are to evaluate: 1) compliance with the water quality <br />standards and Endangered Species Act (ESA) (40 CFR 230.1 O(b )); 2) mitigation to assure that <br />any remaining impacts are addressed (40 CPR 230.10(d)); and 3) the potential for significant <br />degradation (40 CFR 230.1 O(e)), <br /> <br />In practice, the alternatives analysis involves sequential questions, First, a practicability <br />determination is made: what is the basic project purpose, will the alternative m~ that purpose, <br />and does the alternative meet the basic project purpose after considering cost, logistics, and <br />technology? In the case of the ALP Project, after detailed analysis the BOR bas determined that <br />two alternatives (Refined Alternatives 4 and 6) meet the basic project purpose. While there are <br />still concerns about the "practicability" of Refined Alternative 6; our analysis presumes, as the <br />BOR does, that Refined Alternative 4 and Refined Alternative 6 are practicable for the purposes <br />of taking the next step, which is to determine which of the two is least environmentally <br />damaging. <br /> <br />BOR considered Refmed Alternative 4 to be the least damaging alternative largely <br />because Refmed Alternative 4 would have fewer impacts to wetlands, taking into account <br />acreage (134 acres (Alternative 4) to 1,200 acres (Alternative 6)), and the relative value of <br />affected wetlands. Alternative 6 wetlands were determined to be of higher value for many <br />functions as portrayed in a functional assessment conducted by BOR, US Fish aI1d WLldlife <br />Service and the Colorado Department of Wildlife. The wetlands affected by either alternative are <br />associated with irrigation. EP A agrees with the BOR determination that Refined Alternative 4 is <br />less damaging to wetlands, <br /> <br />In addition to wetlands, other aquatic resources that would be affected by the two <br />alternatives need to be considered. Refined Alternative 4 may result in significant impacts on <br />native fish species as a result of impingement/entrainment at the pumping plant, reduction in <br />habitat and increased competition with non-native species in the Animas River. Refined <br />Alternative 6 may also result in impacts to the Pine River native fisheries with the loss of <br />wetlands as a result of the conversion ofriparian overstory to upland habitat with the removal of <br />irrigation waters. Furthermore, the BOR Section 404(b)(1) evaluation indicates that under both <br />alternatives, there is a potential for water depletions in the lower La Plata River to have an <br />adverse impact on native fisheries. Considering all these factors, EP A believes that either <br />alternative could be considered less damaging to the aquatic ecosystem, including wetlands and <br />fisheries taken together. <br /> <br />With regard to non-aquatic impacts, the Guidelines allow consideration of mitigation in <br />the overall determination of the least environmentally damaging practicable altemative <br />determination. The BOR's Guidelines evaluation indicates that for Refined Alternative 4, 1500 <br />acres of upland habitat will be eliminated as a resnlt of reservoir construction and inundation and <br />that indirect impacts associated with recreation will affect an additional 1200-1500 acres of <br />upland now utilized by a variety of wildlife, including elk and deer. Although existing native <br />wildlife in the area would be affected by implementation of Altemative'4, equivalent-acreage <br /> <br />3 <br />