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I I \ I I I I I I I I I I I I I I I I . ~\~ ~ 1,,- '..-." . 00064!) rule under Sec. 4 I 4.3,(1 0). Another provision which should be included in Sec. 414.3 ,is an agreement, from Arizona, because of its abysmal history in meeting its repayment obligations for CAP, requiring it to use its revenue stream from these Interstate Storage Agreements for repayment of its debt to the United States. Finally, in Sec. 414.3(e), we ask that language be inserted to instruct the Secretrary not to 3;llow speculation to occur with regard to assignments. B. Comments on the Draft Environmental Assessment (DEA): We judge the EA to be insufficient and inadequate and request the Bureau conduct a full Environmental Impact Statement (EIS) in conjunction with EPA. In our judgment, the EA does not adequately discuss the following impacts of the Proposed Rule: 1. Impacts on Endangered Species, 2. Impacts on the Colorado River downstream of the likely point of diversion, the CAP intake in Lake Havasu, alon;; the Colorado River and on the Colorado River Delta in Mexico, 3. Growth inducing impacts, to the greater Las Vegas area, which will result in predictable water shortage in that area in the future as a result of this proposed rule. The Proposed Rule could adversely impact endangered species, and almost certainly would result in fostering unsustainable growth of the greater Las Vegas area. The interstate storage of water, fostered by the Proposed rule will put extreme pressure, in the future, on existing supplies and for more water development once the credits are used up. The Proposed Rule does not meet the environmental criteria of (1) protecting and recovering endangered species, and (2) fostering sustainable development, and therefore cannot be supported as presently drafted. (p. I 0) Section C. Alternatives Eliminated 2. Onstream Storage Alternative: The text should be expanded to discuss the probable negative impacts to endangered species, including both the southwest willow flycatcher and endangered fish species, by adversely impactiiIg critical habitat, that would most likely result from increased on-stream storage (in Lake Mead). (p.12-13) Section B. River Management Environment I. River Operations - Preferred Alternative Off stream storage of water, to be diverted from the Colorado River via the CAP intake at Lake Havasu, that might otherwise flow down the Colorado River to its outlet, will impact both the natural environment along the