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~4/e3/199B 15:59 I I I I I I I I I I I I I I I I I I I 52e6239797 0 ft OS '51 SWC 4 BIDDIVSTY PAGE e4 Chief, Regulatory Branch September 18, 1997 Page 4 specifically provide for protection and restoration of Colorado River ecosystems, both io the United States and Mexico, during analysis of proposed storage and redemption systems must be considered, + The effects of a net loss in ground water over time to "indirect storage" is a significant indirect effect of the proposed rule, yet no analysis of the effects of such ground water losses, in Arizona for example, were contained in the envirollIl1ent assessment. . Reclamation's conclusion that" The proposed rule does not authorize the construction of any new delivery, storage. or water treatment facilities." completely fails to consider those indirect and cumulative effects of the proposed action. For example, availability of additional water in the Las Vegas region will allow water providers to proceed with existinl! nlans for new delivery, storage, or water treatment facilities. The facilities are in twn likely to result in significant effects to the human enviromnent . Compliance with the Endangered Species Act for this proposed rule was not aCcomplished through either the CAP or Lower Colorado River Operations and Maintenance Activity biological opinions and may not be deferred to some later date_ In fact, the biological opinion for operations and maintenance was not intended for the consideration of project specific and/or programmatic future actions_ As written. this proposed rule will preclude implementation of several reasonable and prudent alternatives contained in the operations and maintenance activities biological opinioa . Direct, indin:ct, and cumulative effects of the proposed action on threatened and endangered species are not adequately considered in the environmental assessment_ But Reclamation cannot deny that less water will be available to the Colorado River Delta, for example, during periods of drought on the Colorado River, Such a reduction in the availability of water wiII result in significant effects to the hwnan environment. + Coordination with the US Fish and Wildlife Service under FWCA is required concurrent with analysis if this proposed rule. Such coordination may not be deferred until some later date_ Thank you for your careful consideration of the above comments. Comments by the Sierra Club and Defenders of Wildlife are hereby incorporated by reference, Sincerely, V~/~ David Hogan