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of any project to which this subsection is applicable. The State of Colorado on December 29, 1967 (Appendix E, FES) on page 3 thereof stated: "It is therefore the intent of the State of Colorado in connection with these features of the project (recreation and fish and wildlife features) to administer the project lands and water areas for recreation and fish and wildlife purposes, to bear the entire costs of such operation, maintenance and replacement, and to pay not less than one-half of the separable con- struction and acquisition costs of the project allocated to recreation, fish and wildlife purposes as contemplated by the Federal Water Project Recreation Act." The defendants used the benefits of recreation and fish and wildlife features of the project to obtain authorization of Narrows from Congress. Defendants plan to mitigate only 70% of the wildlife habitat losses which is contrary to the law. 32. The Fish and Wildlife Coordination Act requires consultation by the Federal agency (Bureau of Reclamation) with U. S. Fish and Wildlife Service (FWS) "... with a view to the conservation of wildlife resources by preventing loss of and damage to such resources as well as providing for the development and improvement thereof..." (16 U.S.C. Sec. 662(a)) [Emphasis added]. After consulting with a sister agency (FWS), defendants failed to comply with this mandate in violation of law. 33. Defendants, by their abuse of authority and actions outside the scope of authority have damaged plaintiffs under color of governmental authority. WHEREFORE plaintiffs pray that this Court enter judgment against defendants and provide relief to plaintiffs as follows: A. Against defendants Kleppe, Stamm, Hall, Plummer and Bechley and each of them declaring their proceeding -16-