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<br />i-- <br />j- <br /> <br />. <br /> <br />. <br /> <br />November 12, 1992 <br /> <br />M E M 0 RAN DUM <br /> <br />TO: <br /> <br />Daria J. Zane <br /> <br />FROM: <br /> <br />Wendy Weiss :~~ <br /> <br />Scott Hardt'::::< <br /> <br />RE: Animas-LaPlata Draft SElS <br /> <br />As we discussed a': our November 9, 1992 meeting, this memo- <br />randum outlines our ini':ial suggestions for improving the Draft <br />SElS for the Animas-LaPlata Project. Obviously, the time con- <br />straints for completing the Final SElS will influence the extent <br />to which the following issues can be addressed in the Final SEIS; <br />however, we believe that it is important that the Bureau of <br />Reclamation ("Bureau") consider these factors to ensure that a <br />legally defensible NEPA document is produced. Moreover, it is <br />critical that issues raised during the public comment period be <br />fully addressed in the Final SEIS, either in the Bureau's <br />response to the comments or, where the comments raise a reason- <br />able issue not considered in the Draft SEIS, in the body of the <br />Final SElS. <br /> <br />I. ALTERNATIVES <br /> <br />As we discussed in depth at our meeting, it is essential <br />under NEPA and the Clean Water Act that the 1980 ElS and the <br />Final SEIS demonstrate that the Bureau conducted a well reasoned <br />analysis of reasonable alternatives to the proposed action. <br />First, the SEIS should discuss whether new data obtained since <br />1980 alters the Bureau's analysis of the environmental impacts of <br />alternatives, including the "no action" alternative, considered <br />in the 1980 EIS. Second, the SElS should demonstrate that the <br />Bureau considered whether new data obtained since 1980 gives rise <br />to any new reasonable alternatives not considered in the 1980 <br />EIS. And third, the SElS should briefly describe any new alter- <br />natives that have been considered by the Bureau since 1980, but <br />which have been determined to be unreasonable and thus, excluded <br />from detailed consideration. Clearly unreasonable alternatives <br />