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studies necessary for human safety are p~rformed in an adequate manner as is hereinafter more fully set forth. The Congress has authorized a specific expenditure for the completion of the project. A safe and practical complete project will cost more to construct than the amount author- ized by Congress. Therefore, the project is presently unauthorized and any expenditures are contrary to law. 27. Defendants have admitted in FES that seepage loss studies will not be completed until some time in May of 1976 (XI-ll4, FES) and upon information and belief, since there are no facts set forth in the DES or FES to account for the rate of seepage losses at various elevations for water surface levels of dead storage, inactive, conservation, joint use, flood control, surcharge or maximum water storage, FES is inadequate and in violation of NEPA. without benefit of the facts regarding seepage at various surface water elevations, plaintiffs have no way of determining the feasibility of the project for storage of water and flood control or even-whether the reservoir will be a safe structure. Defendants admit (V-14, FES) that they may have to "place a clay blanket over the potentially high seepage areas in the reservoir. The location and extent of high seepage areas has not been determined; hQwever, these areas might include most of the first 2 miles of the south side of the ~eservoir below the top of the joint,.-use pool." Defendants admit that the reservoir banks are subject to erosion .from high winds and associated wave action so that even if the cost of such protection were not excessive the clay blanket would wash away endangering the safety of the project. Defendants before proceeding further with the project have a duty to fully investigate and report on whether the Narrows Dam is setting on geologic formations similar to the Teton Dam. -12-