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;L.... D. J. l.:ra,n<lall, Regional Uil'ector October 6, 1\176 PU&C 2 livestock interests, thus further hindering critical winter h" hi tat establishment. In effect, the deer herd receives no reprieve from the project, nor is there allY attempt to eliminate the perturbations facing the deer alld elk l](;rds. The draft EIS also mentions that a water quality problem encountered will be that of saline accumulation as a result of stream flow depletions. This salt loading would affect downstream values, particularly,agricultural uses, but tho draft EIS fails to mention the sigllificance of the impacts. Particularly on water quality through the Black Canyon of the Gunnisoll National .~lonwllent. .The draft lOIS, .aIso, does not a<idress the mitigat~on efforts to reduce or eliminate these perturbations. Ul timately, the question to be considered with respect to ti,e Fruitland Mesa Proj ect is that of li:abili ty assignment. The proj ect cost amounts to nearly 80 million dollars. Project construction costs will be reilnbursable by the Fruitland Mosa Water Conservancy District to the Bureau of Reclamation. Other costs, however,accurred as a result of recreatioll facilIties and road construction and maintenance will become taxpayer costs as will the loss of 800 deer and resulting winter habitat as well as elk calving grounds and habitat. These are costs that exist the entire life of the proj<.ct. A mountain valley providing wildlife habitat is a fiJ!:ed non-reproducuble resource, and the loss of that valley and wildlife to a dam providing moderate increases in irrigating H20 to.52 ranchers is both a dollar loss (ignored by the draft EIS) and aesthetic devaluation. ! '. The project should not be undertaken as a result. of wildlife impacts and the fact that the liability (loss of ",11dlife, wildlife habitat and resultillg dollars involved in these losses) of the proj ect is a public liability. Amenity resources are being . excluded at the eJ!:pense of a private use resulting in destr.lctio!l of the amenity resources with no recompense to those that utilize the elk and .deer herds that will be sel"iously impac'ted by the Fruitland Mesa Proj ect. The Soap Park Resevoir would inundate. approximately 85 acres of the West Elk Wilderness Study Area. The draftErS fails. to. sufficiently analyze project alterllatives which . . would avoid. conflict with the potential wilderness area. Although the Bureau. of Reclamatic withdrawal "as made prior to establislunent of th.e Wilderness Study Area, proper considerat: of this area as a potential enlargement to the West Elk Wilderness Area should not be com- promised by a project.which has a cost benefit ratio of 0.7 to 1. In addition, the draft EIS makes no mention of any studies to determine if the project would. affect endangered flora. In light of the inadequately addressed adverse impacts of the project, wildlife mitigatioll measures, insufficiellt social and economic data of to be foreclosed if the project is built and Qllostiollable COSt benefit ullacceptable resource value ratios, The " ',; ., --...... t