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I I I t t t t I I I I I I I I I I I I . . "000641 Lower Colorado River and in the Colorado River Delta. Although the EA states that the amount of this water will be only about 100,000 aflyr, "a little more than 1% of the total average deliveries to Lower Division States and Mexico over the next 10 years", this statistic has no relevance in terms of the impact ofthe diversion of this water from the natural river course. The more relevant statement would be "This diversion could reduce the amount of Colorado River reaching the Colorado River Delta by as much as 100,000 af/yr, putting further stress on the Delta's ecosystem, especially during years in which the river's flow is average or below average. " It is time for the Department ofInterior and Bureau of Reclamation to take stock of their responsibilities of implementation of the Endangered Species Act in the Lower Basin. By allowing California to deplete more than its 4.4 maf share of the Colorado River, it is allowing water to be usurped from both aquatic and terrestrial wildlife. Added to this, Reclamation is relying on the Multi-species Conservation Program (MSCP) to support its conclusion that the Proposed Rule will not effect listed species. It is too soon in that process to tell if or how the MSCP will be able to mitigate the impacts of interstate water marketing. (p. 24-25) Section E. Cumulative and Indirect Effects Preferred Alternative We take umbrage with Reclamation's statement that it is "not able at this time to determine what cumulative impacts may result from or what indirect impacts would be caused by approval of specific interstate agreements made pursuant to the proposed rule" because, "future uses may be for the maintenance of existing agriculture and domestic water supplies, accommodation of growth, or growth inducing." It is self-evident that the result of this rule, if adopted, would be to foster further growth in the greater Las Vegas area, since it is the stated major purpose of this rule to facilitate the storage of water by Nevada in Arizona's aquifer for the next decade or two, thereby providing water that Nevada could withdraw at a later time. The net effect would be to make possible greater growth of Las Vegas than would otherwise be possible for a few decade~. Nevada would then have withdrawn all its water from Arizona, be consuming Colorado River water at the rate of, say, 350,000 af/yr. Under this scenario it would be faced with the following alternatives: (I) drastic water conservation and perhaps rationing, (2) preparation and implementation of a "Nevada.3 maflyr Plan," just as California is now being forced to prepare a "California 4.4 maflyr Plan" to reduce its Colorado River water consumption; such a plan could quite likely result in enormous pressure to use water from the Virgin River or rural areas of central and northern Nevada to meet the hyped-up demands