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is claimed that the water will be used for mitigation of wildlife habitat losses. These contradictory statements demonstrate a lack of good faith compliance with NEPA which is contrary to the law. Defendants have not ade~ quately and fairly considered alternatives such as: no project, the Weld County Reservoir (Hardin site), flood control without storage, off-stream storage, and ground water storage. The facts and data used to justify the Narrows is based on outdated studies which if updated would demonstrate that Narrows is not a feasible project. 26. Congress in authorizing Narrows, PL 91-389, pro- vided for irrigation water for 166,000 acres of land to be constructed at a cost of $68,050,000.00. The 'current project called for by the FES calls for the irrigation of 287,000 acres at a cost of $139,526,000.00. Upon information and belief it is alleged that even this high cost figure does not adequately reflect the actual cost ~f the dam in that defendants in assessing the impact of relocating the Union Pacific Railroad used probable maximum flood .criteria which does not accurately project the actual risk of damage to which the railroad would be exposed from Bijou Creek when it flows into the South Platte River below the Narrows Dam. Bijou Creek flowed at a rate of 466,000 cubic feet per second" of time (cfs) during the 1965 flood and at a rate of 282,900 cfs during the year of 1935, either of which flows would destroy the railroad as presently designed in FES. A proper design of the relocation of the railroad would cause defendants to exceed their cost-ceiling on the Narrows. The inadequacy of design is emphasized by the fact that the flood protection criteria for Narrows is quite substantially higher than the floods mentioned above and higher than the flood hazard to be met by th~ proposed railroad relocation. Ad~itionallY, the cost of the project will be increased when all the -11-