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'\ ... ~Y'\Tl . THE FINAL ANALYSIS THE FOOTHILLS PROJECT The Board of Water Commissioners of the City and County of Denver (hereinafter Denver) has applied to the U.S. Bureau of Land Management, Department of the Interior (BLM) and the U.S. Forest Service, Department of Agriculture (U.S.F.S.) for rights-of-way to use federally-owned land in connection with Denver's proposed Foothills Water Treatment Complex (Foothills) which entails construction of the Strontia Springs Dam and Reservoir, pressurized tunnel, filtration plant and conduits for carriage of treated water to the Denver system. The Secretary of the Interior arid Chief of the U.S. Forest Service are to render appropriately finalized decisions on Denver's right-of-way applications no later than March 21, 1978. This deadline results from an Order arising out of the case of the City and County of Denver, etc., et al. v. Cecil D. Andrus, etc~et al., CIvil Action No. 77-W-306,-Pending In the U.S. DistrICt-COurt for the District of Colorado. This Memorandum is to provide Denver's comments for the record for consideration cy the decision-makers in rendering their final decisions. Dale Andrus, State Director of the BLM, has estaclished the date of March 13, 1978, as the deadline for submission of comments which will ce used in the decision process. This Memorandum will address the need for Foothills and the impacts attributable to the project and will discuss the various alternatives which have ceen suggested during the course of the federal agency review. On March 9, 1978, Douglas M. Costle, Administrator of the Environmental Protec- tion Agency (EPA), wrote Cecil D. Andrus, Secretary of the Interior, (The Secretary) requesting that the Court Ordered deCision-making ce held in abeyance. Mr. costle also requested that Charles Warren, Chairman of the Council on Environmental Quality (CEQ), intervene to abate this decision-making process. This Memorandum will also address in detail this EPA action and will establish conclusively that EPA acted with insufficient factual basis, in violation of their own guidelines, resulting in arbitrary, capricious and unlawful behavior. The EPA action has no legal force and effect and should not interfere with the process designed to meet the Court's requirement for a final decision by March 21, 1978. NEED FOR THE PROJECT The Foothills Water Treatment Complex is an integral part of the Denver Water Works. It is designed as a tech- nologically advanced facility which will result in signi- ficant operational cost reductions. The response to a DES