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<br />1:-'" ,--- <br />I '- <br /> <br />.- ..._-........,--~.:.--.-.~- ......... <br /> <br />-...... .-.-., ..... ~'- "'-'--'-- <br /> <br />Detailed Comments by EPA Region VIII <br />404(r) exemption process for the Supplemental EIS <br />Animas-LaPlata Project, Colorado and New Mexico <br /> <br />Introduction <br /> <br />EPA Region VIII has prepared the following discussion to <br />provide Reclamation with information concerning the level of <br />detail which will be needed in the Animas-LaPlata SDEIS in order <br />to make the required 404(b) (1) compliance determination. For' <br />clarity and reference, the following discussion follows the <br />organization of the 404(b)(1) Guidelines. <br /> <br />The SDEIS should address the relevant provisions of the <br />Guidelim,,, lu clele!.lLl.Lm::--whetner-the project complies with the <br />Guidelines. The level of documentation should reflect the <br />significance and complexity of the project. This documentation <br />needs to address both individual and cumulative impacts. If <br />sufficient information does not exist to make a reasonable <br />judgment as to whether the proposed project will comply with the <br />Guidelines, then the project may be concluded to be inconsistent <br />with the Guidelines (230.12 (a) (3) (iv) ) . <br /> <br />Alternative Analvsis (230.10(a)) <br /> <br />The first step of this analysis is to determine the overall <br />project purpose. Once that determination is made, alternative <br />methods to accomplish the overall, or basic, project purpose need <br />to be examined. The alternative with less adverse impact on the <br />aquatic environment (as long as that alternative does not have <br />other significant adverse environmental impacts) that still <br />attains the overall project purpose could be designated the least <br />damaging practicable alternative under the Guidelines or the <br />environmentally preferred alternative under NEPA. The level of <br />detail necessary to make this determination is based on the <br />information needed to ensure that the least damaging alternative <br />has been portrayed. Mitigation to reduce an alternative's <br />impacts to a level below another alternative is not applied at <br />this stage in this analysis. <br /> <br />1 <br />