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<br />regulations of the U. S. Department of Interior, and to <br />meet the challenges of comments of public agencies and <br /> <br />plaintiffs describing deficiencies in DES, defendants have <br />not complied procedurally or substantively with NEPA in good <br />faith and, in effect have failed to file a true final environ- <br /> <br />mental impact statement. <br />21. Defendants have failed to comply with NEPA and the <br />guidelines of CEQ in protecting the environment of 850 <br /> <br />people living within the take area of Narrows. FES demon- <br /> <br />strates that the people affected by the project are rele- <br /> <br /> <br />gated to a position lower than a pupfish. There is no <br /> <br /> <br />attempt by defendants to assess the cost and impact of <br /> <br />Narrows on the human environment of ,plaintiffs, in direct <br /> <br />violation of NEPA which requires defendants to: <br /> <br />* * * <br /> <br />(B) identify and develop methods and <br />procedures, in consultation with the <br />Council on Environmental Quality estab- <br />lished by subchapter II of this chapter, <br />which will insure that presently <br />unquantified environmental amenities <br />and values may be given appropriate con- <br />sideration in decisionmaking along with <br />economic and technical considerations; <br /> <br />(C) include in every recommendation <br />or report on proposals for legislation <br />and other major Federal actions. signifi- <br />cantly affecting the quality of the <br />human environment, a detailed statement <br />by the responsible official on-- <br /> <br />(i) the environmental impact of <br />the proposed action, <br /> <br />(ii) any adverse environmental <br />effects which cannot be avoided <br />should the proposal be implemented, <br /> <br />(iii) alternatives to the proposed <br />action, <br /> <br />(iv) the relationship between, local <br />short-term uses of man's environment <br />and the maintenance and enhancement <br />of long-term productivity, and <br /> <br />(v) any irreversible and ir- <br />retrievable commitments of resources <br /> <br />-8- <br />