WSP05183

• File Number: 8443.600
• Description: Narrows Unit - Studies
• State: CO
• Basin: South Platte
• Water Division: 1
• Date: 6/28/1976
• Author: various
• Title: Various Documents Related to the Narrows Unit
• Water Supply Pro - Doc Type: Report/Study

providing supplemental irrigation water with LSPWCD and
CCWCD, but upon further information and belief, plaintiffs
allege that defendants will enter into such a contract

if not immediately enjoined.

16. Construction and use of Narrows will ,have'

profound adverse impacts upon the human environment of

plaintiffs, citizens and residents of Morgan County and all
citizens of the State of Colorado.

CLAIMS FOR RELIEF

17. The Administrative Procedure Act (5 U.S.C. Sec.

702, et. seq.) states in part:

A person Suffering legal wrong
because of agency action, or adversely
affected or aggrieved Oy agency
action within the m~aning of a
relevant statute, is entitled to
jUdicial review thereof. (5 U.S.C.
Sec. 702)

The plaintiffs have suffered legal' wrong by agency actions,

findings, and conclusions which have either been arbitrary,

capricious 'or otherwise not in accordance with law or;

contrary to constitutional rights or; in violation of

statutes or; in violation of procedures whose observance is

required by law.

(5 U.S.C. Sec. 706)

The relevant statutes

which supply meaning are the National Environmental POlicy

Act, the Freedom of Information Act, the Federal Water

Project Recreation Act, Fish and wildlife Coordination Act

and the U. S. Constitution as is hereinafter more fully set

forth.

18. Congress, recognizing the profound impact of

manls activities upon his way of life and his environment,

declares that "it is the continuing policy of the Federal
Government in cooperation with state. and local governments,
and other concerned public and private organizations to
use all practicable means and measures, including financial

and technical assistance, in a manner calculated to foster

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