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<br />o <br />N <br />C'>J <br />o <br /> <br />.-, <br />- ' <br /> <br />:.::) <br /> <br />CHAPTER IV <br /> <br />CONSULTATION AND COORDINATION <br />COMMENT LETTERS <br /> <br />Mr. Ronald Johnston <br />July 16, 1990 <br />Page -2- <br /> <br />4. Explain whether the cost effectiveness figures contained within the <br />Environmental Assessment are based upon construction and other <br />costs determined by the Bureau of Reclamation under competitive <br />bidding, as generally required by law, or under Bureau of Reclama- <br />tion's construction estimates for this work completed on a contract <br />basis with the irrigation districts, <br /> <br />Therefore, Table 3 should be altered to show the cost effectiveness figures <br />presented in the Final Environmental Impact Statement and the current <br />calculations based uPon the oroiect as Dresented in the Environmental <br />Assessment and the project "S c~mpetitively bid, <br /> <br />Additionally, the socio and economic figures contained in Tables 5 and 6 are <br />incomplete because they do not consider impacts from the program between <br />the project (a) competitively bidded and (b) constructed by contract with the <br />irrigation district Additionally, the liabilities to the irrigation district, if they <br />assume construction of these programs, should be defined. <br /> <br />The Environmental Assessment does not properly consider the effect on the <br />endangered species of the proposed course of action, For example, on page 26, <br />paragraph 2, it is stated that there would be no additional depletions from the <br />Colorado River. This Is an assumption not based upon an adequate consider- <br />ation of the entire ecosystem and hyc.irology effected by the proposed project. <br />The Environmental Assessment does not consider, evaluate, or define the <br />effect of the proposed project on return flow, waste water, and tail water as <br />those elements finally reach the Colorado River. Nor does the Environmen- <br />tal Assessment consider the possible effects of litigation, under Colorado <br />Water Law, upon the project because of the erroneous conclusions and state~ <br />ment of facts contained within the environmental assessment. <br /> <br />The Environmental Assessment, page 27, indicates that there is a "no effect" <br />determination by the Fish and Wildlife Service. However, that no effect <br />determination was produced in 1983 and cannot possibly have considered the <br />consequences of various decisions made by both federal and private entities <br />since that time. Likewise, that no effect determination could not have been <br />made with the consideration of the proposed project on Price and Stubb <br />Ditchs, for they were not included in the Grand Valley Unit, Stage IT Develop- <br />ment Final Environmental Impact Statement. <br /> <br />57 <br />