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<br />. . '~ <br />~!.,;.-. un {, <br />:;'\ ~(it J <br />t"", .....~ <br />.--1 ""'l PRo1t.l;," <br /> <br />I <br /> <br />I, <br />I ~ <br />I <br />I <br /> <br />.::'1 <br /> <br />UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br />--- <br />REGION VIII RECEIVED <br />1860 LINCOLN STREET USBR.. Grand Junction <br /> <br /><.-;:'" <br /> <br />Ref: <br /> <br />DENVER, COLOR,^~D r;Q~\ ~~. <br />C~r;-s1~ ::IIi! :~ 'I <br />\';f} nG \918 ) *l ~ I' <br />\. '\ !\?R \J Jf-L-I 7JT <br />b~ . y.Jf>,\f..R 0 <br />COLO. ON 60f\\1 <br />CONSf..R\lf\11 <br /> <br />I Susp clale <br />O;;le ^"\ '.~ <br />(:7 ;,;.- .;,:Z;:~~';!. 0,' }:l co <br />The Region VIII office of the Environmental Protection ,~gcncy has 'c~_.c;~~ <br />reviewed the environmental assessment for the Grand Valley Unit, Colorado ~ <br />Ri vel' Basi n Sa 1 i nity Control Proj ect. EPA has seri ous envi ronmenta 1 con- <br />cerns with the proposed project because there are less environmentally <br />damaging and less costly alternatives and there is no indication of the <br />eventual use of the developed or salvaged water. Pursuant to our authority <br />under section 309 of the Clean Air Act, EPA believes that this environmental <br />assessment is inadequate for a project of this scale and impact. Therefore, <br />vie recommend that a complete environmental impact statement be prepared <br />according to section 102 of NEPA. EPA also suggests that this EIS should <br />follow the recently released draft regulations for EIS preparation issued <br />by the Council on Environmental Quality and thoroughly analyze the follow- <br />ing problems of concern to EPA. <br /> <br />8WEE <br /> <br />MAR 3 0 1978 <br /> <br />,I <br /> <br />Mr. J.F. Rinckel <br />Bureau of Reclamation <br />Western Colorado Project Office <br />P.O. Box 1728 <br />Grand Junction, Colorado 81501 <br /> <br /> . <br />, i I " <br /> 1/" <br /> '/- I <br /> -) ('"-t. <br /> /?L' <br /> '/ ''l ( <br /> <br />/s-o <br /> <br />Dear Mr. Rinckel: <br /> <br />I' <br />i <br /> <br />c <br /> <br />Alternatives to the Project <br /> <br />EPA certainly concurs in the need for salinity control projects of <br />this nature, particularly in Grand Valley where salt loading is excessive. <br />As indicated in our con~ents on the Colorado River Water Quality Improve- <br />ment Program EIS, EPA stated that these projects should be done on a cost <br />effective basis and l'ecol1111ended that those projects vlith the highest bene- <br />fit/cost ratio be completed first. Your own analysis, however, indicates <br />there are less costly and less environmentally damaging alternatives. For <br />instance, the alternative that includes the Irrigation Management Service <br />(IMS) combined with other on-farm improvements has a significantly higher <br />cost effectiveness ratio than the proposed project, 2.3 versus 1.0. Hhile <br />this alternative only reduces Colorado River salinity by 14 mg/l which is <br />not as desirable as the proposed pl'oject at 43 mg/l, the alternative to re- <br />place the proposed lateral pipelines with open latel'als would still reduce <br />salinity by 39 mg/l and is also more cost-effective, 1.1 versus 1.0. Both of <br />the above options would have significantly less impact on wildlife habitat. <br />The high capital expenditures for canal and lateral lining are the least <br />cost-effective portion of the proposed project and the most damaging' in terms <br />. of wildl ife habitat losses. <br /> <br />_....-- <br /> <br />~ ,...." <br />