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-I CJ N c;.) . , - , .--; CHAPTER IV CONSULTATION AND COORDINATION COMMENT LETTERS Mr, Ronald Johnston July 16, 1990 Page -3- Therefore, no decision can be based upon that 1983 decision by the Fish and Wildlife Service, and likewise, can no decision be made until the cumulative impacts are examined. In any event, the Environmental Assessment should include the results of the Bureau of Reclamation's latest study on providing water to the endan- gered fish in the section between Palisade and Grand Junction, and should consider those effects in light of successful and unsuccessful mitigation pro. grams by the federal government For example, the Environmental Assess- ment assumes that all federal programs for the endangered fish would be successful. However, to be a proper evaluative tool for the decision maker, the Environmental Assessment must consider what happens if proposed federal programs are not implemented, are not funded, or fail to achieve their desired results. Finally, the Environmental Assessment needs to reconsider its statement concerning the impacts on the water rights as stated on page 7, 16, and 26. The statement is too conclusiary to be valid and any effect of the project should be evaluated only after identifying the effect of the project on wastewater, return flows, consumptive usage 1U\d tail waters. Additionally, the Bureau should not attempt to wash its hands from responsibility for claims by others for what the Bureau estimates to be 1,760 acre feet per year, Therefore, the cost of litigation in state water Court, who would bear those costs, and the final results of such litigation must be assessed, The final use of the water that the Bureau claims would become "salvaged or saved" must be evaluated for the Environmental Assessment to have any validity. Since the environmental impacts of the proposed project cannot be ade- quately determined without a complete assessment of what will happen to the water involved, the Environmental Assessment must be considerably expanded in this area, It may be that such an expansion will reveal that the assumption that there is salvaged or saved water, when the project is viewed in the totality of the use of water within the Grand Valley, is erroneous. Fur- thermore, the same two paragraphs indicate that no additional land could be benefited by the water, The proposed alternatives, such as irrigating mancos shale north of 1-70, should at least be evaluated in the Environmental Assess- ment to determine their cost effectiveness and potential for success. Also, various exchange, lease, or sale options for such water should be evaluated to determine if there is any benefit to the current owners of those water rights from the Bureau's proposal and to also define the dangers involved from the Bureau's proposal. 58