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<br />~ <br />The Honorable Man~~~ Lujan <br />August 23, 1989 <br />Page Two <br /> <br />t~[p1ft <br /> <br />Third, regulations implemented by CEQ at 40 CFR 1506.1(c) require <br />that "while work on a required program environmental impact <br />statement is in progress... agencies shall not undertake in the <br />interim any major federal action covered by the program which may <br />significantly affect the qua Ii ty of the hwnall envirorunell t. " The <br />CEQ regulations further provide that" interim action prej udices the <br />ultimate decision on the program when it tends to determine <br />subsequent development or limit alternatives." We feel that <br />adoption of interim criteria would be a violation of CEQ <br />regulations. <br /> <br />, <br />, <br />{ <br /> <br />',I <br /> <br />c;' <br /> <br />t- <br /> <br />~ <br /> <br />Fourth, in addition to NEPA and the CEQ regulations, the operation <br />of the reservoirs on the Colorado River are also subject to <br />specific legislation (the Colorado River Basin Act of 1968, PL 90- <br />537) which requires the Secretary of the Interior to consult with <br />representatives of the seven basin states before any modifications <br />to the operating criteria are made. <br /> <br />q <br /> <br />~ <br /> <br />Mr. Secretary, we fully support the EIS process and are anxious to <br />have it begin and will give our best efforts to bring j t to a <br />successful conclusion. As a part of that process, we will support <br />temporary changes in operations to gather needed data. We cannot, <br />however, support' adoption of interim flow criteria which are a <br />violation of legislation and regulations and will most assuredly <br />cast a serious doubt on the validity of the entire EIS process. <br />We find it especially difficult to do so given the complete lack <br />of data to support such an action. <br /> <br />~ <br />g; <br />~ <br />I <br />ii <br />~ <br /> <br />We would be pleased to meet with you to discuss this matter in more <br />detail if you would like to do so. You can contact me in my office <br />at (602)975-2151. <br /> <br />" <br /> <br />Sincerely, <br /> <br />'" <br /> <br />CREDA <br /> <br />J!!:. ~a~~ /J;( <br /> <br />President <br /> <br />,. <br />~ <br />i'!! <br />..- <br />{,J:;; <br />~~'J <br /> <br />JAF/sk <br /> <br />cc: Frank Bracken, Under Secretary <br />John Sayre, Assistant Secretary/Designate <br />Dr. Harlen Watson, Deputy Assistant Secretary <br />Joe Hall, Acting Commissioner <br />Roland Robison, Regional Director, Upper Colorado Region <br />Ed Hallenbeck, Regional Director, Lower Colorado Region <br /> <br />1 <br />.! <br />