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<br />et. seq., and Fifth ~endment of the U. S. Constitution <br />and is based upon alleged unlawful acts of defendants <br />concerning the proposed construction and operation of the <br />Narrows unit of the Pick-Sloan Missouri Basin Program, <br />Colorado, hereinafter called lINarrows." <br /> <br />JURISDICTION <br />2. Jurisdiction is based _upon 28 U.S.C. subsection <br />1346 (United States as a defendant), 5 U.S.C. Sec. 701, <br />~. seq. (Administrative Procedure Act), 28 U.S.C. Sec. <br />1361 (mandamus) and 28 U. S. C. Subsection 2201-220,2 <br />(declaratory judgment), and the action arises under the <br />Fifth Amendment of the Constitution of the United States, <br />Freedom of Information Act, 5 U.S.C. Sec. 552, et. seq., <br />Federal Water Project Recreation Act, 16U.S.C. Sec. 460 <br />1-12, Fish and Wildlife Coordination Act, 16 U.S.C. Sec~ <br />661 et. seq. and the National Environmental Policy Act, <br />42 u.s.c. Subsection 4321, eta seg., as is hereinafter more <br />fully set forth. <br />3. Venue is properly laid in this Court under 28 <br />U.S.C. Sec. 1391. <br />4. Plaintiffs have no adequate, speedy remedy at <br />law and the actions of the agencies involved are so far <br />matured as to constitu~e final agency action for which <br />there is no other adequate remedy in a court. (5 U.S.C. <br />Sec. 704) <br /> <br />PARTIES <br />5. Plaintiff, Regional Landowners Group" Inc., is a <br />non-profit corporation of the State of Colorado. The <br />purposes for which the Regional Landowners Group was <br />formed are as follows: <br />a. TO encourage productive and enjoyable <br />harmony between its members and the environment. <br /> <br />-2- <br />